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Privacy Policy Salt Group Limited

Thank you for using SALT! Here you will find information about which personal data SALT collects, how we handle this data and what  options you have as a user. The entity responsible for processing your data is SALT Group Limited (referred to here as "SALT" or "we" or "us"). 

Information about the processing of data in connection with cookies and other tracking technologies when using the SALT website/app can be found here

Table of contents

Contact / Responsible party
Collection, processing and use of personal data
Processing purposes
Legal basis for the processing of personal data
Transfer of data to third parties; service providers
How do we protect your data?
Duration of storage; retention obligations
Overview of data subject rights
Social media

Contact / Responsible party
Unless otherwise stated in this Privacy Policy, the data controller is SALT Group Limited.  The entity responsible for data processing is SALT Group Limited, 17 Railton Road, Kempston, Bedford, MK42 7PN, United Kingdom. 
If you would like to contact us, you can reach us as follows:
Contact email address - [email protected]
Help centre - https://support.be-salt.com

You can reach our data protection officer at: 
[email protected]

Collection, processing and use of personal data
Personal data is any information that relates to an identified or identifiable natural person (e.g. name, address, telephone number, date of birth or e-mail address), whether living or recently deceased. We do not process personal information relating to juristic persons.
When we process personal data, this means that we e.g. collect, store, use, transmit to others or delete.
SALT only collects and processes your personal data in the following cases: 
- When you visit us on our website/app, whether you create an account or not.
- When you contact us directly.
- When you install our SALT app. 
- When you create an account  with SALT and subsequently use SALT.

SALT recognises that technology changes over time so how we collect and process your personal data can also change. While we shall update this policy from time to time, you can always contact us and ask for information about all the data we collect about you.
It is entirely your choice if you decide to create an account with SALT and provide personal data. However, if you do proceed to open an account, it is necessary for you to provide certain special category personal data (e.g. your faith, details about your personal life, your gender, your sexual orientation etc.) as well as personal data to create your SALT profile. Also the use of the SALT service requires that your profile information is visible to  other SALT users.  In this context, please also note that we offer the SALT service in other countries (you can see the list of these countries in the Support Centre on our Help centre support.be-salt.com) and the information contained in your profile is visible to users in these countries as well. You can search for your partner in any of these countries. If you do not want SALT to process your personal data, SALT will not be able to provide the services set out in the Terms and Conditions
You can find details on what data SALT collects below. 

Data processing by app stores
If you install the SALT app, you may have to sign a user agreement with an app store operator (e.g. Google or Apple). This access requires a valid account with the app store operator and a suitable end device (e.g. smartphone). SALT has no control of  the data processing carried out by app store operators. If necessary, please obtain information directly from the app store operator about their data processing.
 
What data does SALT collect from its users in order to perform its contractual obligations?
In order to provide the services described in more detail in the Terms and Conditions, it is necessary for SALT to collect the personal data described below, which the SALT user provides during the registration process when creating an account. 

Registration process 
During the registration process the user is asked to provide certain minimum mandatory information, without which the registration process cannot be completed. This information includes a request for personal data such as an email address.
Required information membership

During registration, the following information is requested 
- Geolocation
- Date of birth
- First name
- Full face photo
In addition, SALT requires further information from its users in order to provide its services, including a personal statement, preferences, appearance and other characteristics specific to the user which may include special category or sensitive information such as faith-related information, sexual orientation or health-related data such as whether you smoke. This information is used to create your SALT profile. Photos of SALT users are also stored in such a way that these photos are visible to other members in recognisable form in the user’s profile next to the first name of the user. The information which you supply to us in answer to these questions is used to create your SALT profile and helps us to suggest partners with characteristics and results matching your personality. The matching characteristics and results are also made available to other members in the profile.
All SALT profile data is visible on the app for other registered users. In particular, the photograph, first name, age, and other information you may choose to share are visible. 

I confirm that I have read this Privacy Policy and I agree that you may process special category data relating to me.

Communication by users among themselves, communication with Customer Service and communication via video chat
SALT stores the communication between users that takes place via the SALT website/app, as well as communication with Customer Service. 
As a user you can communicate with other registered users via video chat in selected countries. SALT uses a third party service provider Twilio.io to enable such communication. If you do not want SALT to transfer your IP address and your box number to its processor,  you should not use the video chat function. Please familiarise yourself with Twilio’s Privacy Policy.

Advertising emails - newsletters - messages
When you create an account , you provide us with your e-mail address or we receive this from Apple / Facebook. This e-mail address or any new e-mail addresses you may subsequently provide will be used by SALT for sending emails. without the need for your consent. 

I confirm that I have read this Privacy Policy and I agree that you may send me advertising emails, newsletters and other messages. I understand that my consent is not a condition for you providing SALT services to me.

If you no longer wish to receive emails, newsletters or individualised communication from SALT you can at any time opt out of the use of your profile for such purposes free of charge: 
(1) Click on the unsubscribe link at the end of the e-mail; or 
(2) contact SALT Customer Service. 

Push notifications
When you create an account on  the SALT app, you will receive push notifications from us, even if you are not using the app at the time. These are messages that we send you as part of providing our service. 
You can stop receiving push notifications at any time via the device settings of your mobile end device or in the SALT app.

​What data does SALT collect when I use the SALT  app and website/app?
Every time the SALT website/app is accessed, the data of the website/app visitors, even if they are not registered SALT users - unless otherwise indicated below-  is transmitted by the respective Internet browser and stored in so-called server log files. These data are:
- Information about the type of browser and the Internet service provider of the user as well as the operating system used (e.g. Windows 7, Apple OS, etc.)
- IP address (Internet protocol address) of the accessing computer, tablet or smartphone (the IP address is also compared with a geo-database and the database and the origin or the country, state and city of the user is determined) 
- Name of the page accessed
- date and time of the retrieval
- the referrer URL (origin URL) from which the user accessed the page accessed 
- Amount of data transferred
- Status message on whether the retrieval was successful
- Session identification number
- Session participant pseudonym
- Screen resolution used
In addition to the data listed above, when using the SALT website/app, cookies or pseudonymous IDs (such as user ID, ad ID) are stored on your end device during or after your visit to us online. You can find more information on this here LINK to Cookies and other tracking technology Policy.
You can contact us at any time if you would like any information about how we collect data.

GPS data when using the SALT app
If a user uses the setting options for a proximity search, the location data of the device is accessed at that time (GPS, possibly Wi-Fi, etc.) information, and device ID). This information is used to determine the location of the user so that he or she can set a suitable search radius.

Processing purposes
SALT processes the personal data of its users for the following purposes:
- To perform the services described in the Terms and Conditions. The legal basis for the data collection is the performance of the contract concluded with you as a registered  SALT user. For special category data, the legal basis is your consent. 
- For prevention and defence against abuse. SALT collects, processes and uses personal data as well as geodata, which are collected in connection with your registration and the completion of the SALT profile. This data is accessible only to certain designated members of the SALT administration team who have secure access.
We also comply with our legal obligations in the area of data security, system security and the detection of  unauthorised access or access attempts.
- For the protection and defence of our rights and the performance of legal obligations. The legal basis is our legal obligations and our legitimate interest in asserting and defending our rights). 
- For self-promotion through emails. The legal basis is the legitimate interest of SALT   in direct marketing for its own products and services. In some cases, the legal basis is also your consent.
The processing purpose and the legal basis for the processing of personal data using Cookies and other tracking technologies when using the SALT website/app can be found here.

Legal basis for the processing of personal data
- Where we obtain your consent as a data subject for the processing of personal data, Art. 6 para. 1 (a) EU General Data Protection Regulation (“GDPR”, referenced in Germany as DSGVO) is the legal basis.
- Where we process special categories of data pursuant to Art. 9 para. 1 GDPR, Art. 9 (2) (a) GDPR - your consent - is the legal basis.
- When processing personal data that is required for the performance of a contractual relationship with SALT, Art. 6 para. 1 (b) GDPR is the legal basis. This also applies to processing operations that are required to carry out  any pre-contractual measures that are necessary.
- When processing personal data to fulfil a legal obligation, Art. 6 para. 1 (c) GDPR is the legal basis.
- If the processing is necessary for the protection of a legitimate interest of SALT or of a third party, such as its users, and the interests, fundamental rights and freedoms of you as the data subject do not outweigh the first -mentioned interest, Art. 6 para.1 (f) GDPR serves as the legal basis for the processing.
- When processing personal data that is required for self-promotion, Art. 6  para. 1 (f ) GDPR and your consent is the legal basis.
If the legal basis is your consent, you are entitled to revoke your consent at any time without affecting the lawfulness of the processing carried out until revocation of the consent. If the legal basis is legitimate interest, you are also entitled to object at any time to the processing of personal data relating to you for personal reasons. In this respect, Art. 21 GDPR applies. 

Transfer of data to third parties; service providers
Your personal data will only be passed on to third parties by SALT if this is necessary for the performance of your contract with SALT or if you have given your consent to this.
If personal data is transferred to third parties on the basis of a legitimate interest, we have explained our legitimate interest in this Privacy Policy. In addition, personal data may be transferred to third parties if SALT is required to do so by law or by an enforceable official or court order.

Service providers
SALT reserves the right to use service providers for the collection or processing of personal data. Service providers only receive the personal data from SALT that they need for their particular activities. 
SALT may use service providers not already mentioned in this Privacy Policy for sending emails, push notifications and newsletters to members. Furthermore SALT uses server capacities.  SALT uses a third party provider for  the processing of payments. You should refer to the third party providers’ Privacy Policies for more information. As a rule, service providers operate as order processors, who may only process personal data of SALT users according to the instructions of SALT. 

Transfer of data to non- EU/EEA countries/Transfer of data outside the UK/transfer to third countries
We transfer personal data to third parties or processors who are based in non-EU/EEA countries. We need to make these transfers in order to fulfil our contractual obligations to you. In addition, prior to the transfer, we either ensure that either an adequate level of data protection exists in the recipient country (e.g. due to an adequacy decision of the EU Commission for the country in question) or we use an agreement with the recipient containing the EU-approved  standard contractual clauses or, when transferring data from the UK to a country which does not have an adequacy decision, we use the “old” EU standard contractual clauses approved by the UK Information Commissioner. for  the recipient). We also transfer your data to third countries. 

I confirm that I have read this Privacy Policy and I agree that you may transfer my personal data to third countries, including outside of the EU/EEA and outside of the UK.

How do we protect your data?
SALT operates a privacy by design and default policy. SALT implements various security measures such as strict access criteria when dealing with your personal data, encryption and authentication tools in line with current best practice to ensure the security, integrity and availability of its users' personal data. SALT aims to keep its security policies up to date and you can contact us at any time via the details given above to ask about our security policy.

Duration of storage; retention obligations
We store your data for as long as is necessary to provide our online services and the associated services, or for as long as we have a legitimate interest in continuing to store it. In all other cases, we will delete your personal data with the exception of data that we need to comply with contractual or legal (e.g. tax or commercial law) retention periods. The following applies to users: you can cancel the storage of the personal data contained in your profile at any time. This cancellation does not affect the legality of the processing of your data by SALT up to the point of cancellation. You can also start the deletion process data yourself by logging into the SALT website/app. If you want to delete  your SALT account completely you need to contact us. 

Uninstalling the SALT app from your end device does not automatically delete the data in your profile. SALT automatically deletes the personal profile data of members who have been inactive for 60 months. 
Please note that your data will initially only be blocked if there is a duty to retain the data.
In the case of a user asserting data subject rights, SALT stores those data which are necessary for performance or proof during any relevant national  limitation period.

Data subjects' rights
You have important rights in respect of your personal data under the GDPR. 
To assert your rights, please use the information in the Contact section and enable us to clearly identify you when you assert your rights. You should address your requests to SALT Customer Service or to our Data Protection Officer.  If you wish to object to direct marketing and cannot find the answer in our Cookies and tracking technologies policy here, please contact us using the details above.
For a more detailed explanation of your rights, including your rights to lodge an official complaint against us, you should contact the relevant data protection authority in your place of residence

Social media 
The SALT app/website contains social media plug-ins. The operator of the social media site is responsible for its own data protection and you should refer to its policies. 

I have read this Privacy Policy and I agree that you may process my personal data as described here.


Last updated July 2021