PRIVACY POLICY

1. Introduction

This is the privacy policy of Bender Dating Limited (“Bender Dating”, “us” or “we”), which applies to all personal data we process.

Privacy policies are also sometimes referred to as a ‘privacy notices’ or ‘fair processing notices’.

We are committed to protecting and respecting your privacy. This policy explains the types of personal data we collect, how we use that information, who we share it with, how we protect that information, and your legal rights in relation to your personal data.

2. About this policy

This policy governs the collection and use of personal data by Bender Dating. This includes any personal data you may provide as part of any contract you enter into with us (when using our app), any personal data you provide (or is available to us) through your use of our website or app and any personal data which we may obtain from other sources.

When we refer to personal data in this policy, this means any information about an individual from which that person can be identified. More details about this are set out in section 6.

It is important that you read this policy together with any other privacy notice (or ‘fair processing’ notice) we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This policy supplements any such other notices and is not intended to override them.

We have appointed a Data Protection Officer who is responsible for overseeing questions in relation to this policy. If you have any questions about this policy, including any requests to exercise your legal rights, please contact the Data Protection Officer using the contact details set out in section 15.

This version of the privacy policy is effective as of 17 July 2021.

3. Who we are

For the purpose of applicable data protection laws, the controller of your personal data is Bender Dating Limited, whose registered office is at Westgate House, Seedhill, Paisley, Renfrewshire, United Kingdom, PA1 1JE. For more information about Bender Dating please see: www.benderdating.com.

4. Keeping your information up to date

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes at any time, either by contacting our Data Protection Officer using the contact details set out at the bottom of this policy.

5. Changes to this policy

We reserve the right to amend this policy at our sole discretion, without prior notice to you. We will notify you of any such changes (including when they will take effect). Your continued use of our services or our app following the posting of changes to this policy means that you consent to those changes (but this does not affect your rights set out in section 14).

6. Information covered by this policy

This policy covers all personal data collected and used by Bender Dating.

In this policy “personal data” means information that (either in isolation or in combination with other information held by us) enables you to be identified as an individual or recognised directly or indirectly. Page 3 of 12

This may include information such as your name, title, date of birth, gender, postal address, email address(es), telephone number(s) and IP address.

The different types of data we may collect are referred to below. We use these terms elsewhere in this policy to cover the type of personal data referred to:

  • Identity Data – which may include your first name, surname, last name, title, date of birth, gender and photographic images of yourself.
  • Contact Data – which may include your telephone number(s), email address(es) and postal address.
  • Contractual Data – which may include includes details of the existence of (and the terms and conditions applicable to) any contract we have with you and details about the services we have contracted to provide to you.
  • Location Data – which may identify your location at any given time, indicating your proximity to a certain location or your distance from other users of our app, or potentially indicating your exact location.
  • Payment Data – which may include information about the amounts you have paid to the relevant App Store or their designated payment provider for access to any Bender Premium features, including the subscription duration you have paid for and details of any applicable refunds you have received;
  • Technical Data – which may include your internet protocol (IP) address, internet browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology used to access our app and/or our website.
  • Profile Data – which may include details of your hobbies, interests and preferences, status a s a smoker or non-smoker, characteristics, occupation or employment status, physical traits (such as height, weight and body shape), relationship status, star sign, health, ethnic origin, nationality, religion and/or sexual orientation.

Please note – some of this data is, of course, sensitive in nature and is classified in law as ‘Special Categories of Personal Data’). Please see below for further information about our processing of Profile Data.

  • Feedback Data – which may include details of your feedback relating to the app or our website and your responses to any surveys we may issue.
  • Usage Data – which may include information about how you use app and/or our website and services.
  • Marketing Data – which may include your preferences in receiving marketing information from us and your communication preferences.

7. Collection of personal data

We may collect personal data about you from different sources detailed below.

Information you give us:

Unless expressly stated below, you are not bound by any contractual or statutory obligation to provide personal data to us. However, if you choose to enter into a contract with us in order to use our app then we will need certain information for the purposes of entering into and performing that contract (which may include personal data) and we may not be able to conclude a contract with you without Page 4 of 12

that information.

In connection with your use of our app, you may choose to provide us with certain sensitive personal data about yourself (which the law refers to as ‘Special Categories of Personal Data’). In this policy, when we refer to ‘Profile Data’, this may include any such sensitive personal data. Your use of the app may also indicate (or give rise to assumptions relating to) your sexual orientation. When you register to use the app, you consent to us using all such Profile Data, but you will be entitled to withdraw your consent at any time (please see section 14 for more information).

You may give us information about yourself when you:

  • • register for our app;
  • access and browse our website;
  • use our app (including by completing your profile details, posting other material or sending contact messages to other users of our app);
  • correspond with us by phone or email or other electronic means (including via any chat facility on our app or any contact form on our website);
  • subscribe to our publications or request information to be sent to you;
  • • enter a competition, promotion or survey; or
  • • give us some feedback.

Information we collect about you:

With regard to each of your visits to our website, we may also use cookies and other technologies to automatically collect the following information:

  • technical information, including the internet protocol (IP) address used to connect your computer or device to the internet, internet browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology used to access our website; and
  • information about your visit, including the full Uniform Resource Locators (URL) clickstreams to, on and from our website, information you viewed or searched for, page response times, download errors, length of visits to certain pages or features of our website, page interaction information (such as scrolling, clicks and mouse-overs) and methods used to browse away from the page.

We collect the above information by using cookies, server logs and other similar technologies connected to our website. Our website also use cookies to distinguish you from other users. This helps us to provide you with a good experience when you browse our website and also allows us to improve website. Our app does not use cookies, but it does link to certain pages on our website which use cookies. For detailed information on the cookies we use and the purposes for which we use them, please see our Cookie Policy.

Information we receive and collect from other sources:

We may obtain certain information about you from third party service providers.

The different kinds of personal data about you which we may collect and process from third parties are:

  • Technical Data and Usage Data from analytics providers (such as Google).

Page 5 of 12

  • Identity Data, Contact Data, Location Data, Payment Data, Technical Data, Profile Data and Usage Data from service providers associated with the provision of our app (such as the App Stores and their designated payment providers, including RevenueCat, and providers of chat messaging services, including CometChat).

It is also possible that other users of our app may provide us with information about you (for example by referring to you in chat messages) and this may comprise Profile Data, including certain sensitive personal data as referred to above. As we do not monitor what users may post on the app, including any such messaging, you must inform us if you wish to exercise the right to have such personal data erased or wish to restrict the processing of such personal data (please see section 14 for more information).

Please note that when you have enabled location services on your device when using our app (which we refer to in this policy as ‘Location Data’), your use of the app may indicate or reveal your exact or approximate location at that time.

Other information and uses:

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Such aggregated data may be derived from your personal data but is not considered personal data in law (as this data does not directly or indirectly reveal your identity). For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific app or website feature. However, if we combine or connect any such aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this policy.

8. How we use your personal data

We will only use your personal data when the law allows us to. Each basis on which we are lawfully permitted to process your personal data is known as the ‘legal basis’ for processing.

The purposes for which we may use your personal data and the types of legal basis that we will rely on to process your personal data are set out in the table below. Note that we may process your personal data for more than one legal basis depending on the specific purpose for which we are using your data (as shown in the table). Where more than one is shown, please contact us if you would like details about the specific legal basis we are relying on to process your personal data. Purpose/Activity

Type of data

Legal basis for processing

To register you as a user of our app.

  • • Identity Data
  • • Contact Data
  • • Necessary for the performance of a contract to which you are a party, or to take steps at your request before entering into such a contract.