Privacy Policy


Last Updated:  November 18th, 2016


The Ona application and services (the "Service"), are owned and operated by ONA Connect, LLC. (“Ona”, “we” or “us”).  This Privacy Policy describes how we collect, store, use and distribute information through the Service, as well as via our website located at www.onadates.com (the “Site”).  

We are dedicated to treating your personal information with care and respect.

The Service provides an online marketplace and platform (including the mobile applications and related technology, the “Platform”) for end user customers (“Users”) to browse, to be connected with and to hire the services of matchmakers, dating services consultants, therapists and related service providers (collectively, “Service Providers”) for the purpose of meeting romantic matches and receiving content, advice and counseling relating to dating, romance and related topics.   

The Platform will offer messaging and video chat functionality to allow Users to directly interact with Service Providers and potentially, hire them (each hire an “Engagement”) and (ii) to potentially be connected with other persons for dating relationships (each a “Match.”)  

Your use of the Service is governed by our user Terms and Conditions of Service which you should read carefully and which this privacy policy interoperates with.

We may change this Privacy Policy by posting an updated policy within applicable areas of the Service and Site (please see “Changes” below.)


1. Consent.  By using the Service, the Platform and/or visiting the Site, you consent to the use of your information as described in this Privacy Policy. 

 
2. Collection of Information. 
 
The Types of Information We Collect
We may collect personally identifiable information (“Personal Information”) and non-personally identifiable information (“Non-Personal Information”) from you.  
This policy is primarily concerned with Personal Information.  Personal Information is information that can be used to identify or locate a particular person or entity. This includes, but is not limited to: name, address, telephone number, email, date of birth and, if applicable, billing information. 
Non-Personal Information cannot, by itself, be used to identify a particular person or entity and includes any aggregate information and/or usage information relating to the Service or Site that we have gathered, as long as Personal Information has been removed from it. This policy does not restrict our use of Non-Personal Information and you agree that we may use or transfer any Non-Personal Information that we collect from you or based on your usage, at our discretion. 
However, if we combine your Non-Personal Information with Personal Information that we collect about you, we will treat the combined information as your Personal Information. 
 
Information You Provide To Us
Service Registration.  At registration, we require you to provide, your email address, date of birth and gender categorization.    If you have registered with us via a social media platform such as LinkedIn or Facebook, you must consent to have the applicable platform share that information with us, as well as personal images for your User Profile.    
User Profile.  Your registration information will be used to create your service user profile (a “User Profile.”)  After you register, we will request that you review your User Profile, to confirm any pre-populated information shared with us and to edit and supplement it, with your personal information and dating preferences that we think are relevant to your Service usage experience.  We will also encourage you to upload photo and potentially video content of yourself, for Service usage purposes.   Over time, we may change or supplement the information that we ask or require to provide.   
Commerce.  When you book any Engagements (and/or make any other Service purchases from us, if we add additional commerce), we may request that you provide additional billing-related information (“Billing Information”).  We may also provide purchase links directly to properties that are operated by third parties, which will be governed by their own privacy policies.
Sharing and Community Features. We may offer features within the Service or Site that allow you to further communicate with us or with Service Providers and/or other Users, including by uploading files.        
Promotions, Surveys, Contests. We may conduct promotions, offer voluntary surveys and host contests, as part of which we may request additional information from you.
We are not responsible for verifying the accuracy of any information that you provide or post. 
 
Information We Automatically Collect 
As you use our Service or Site (or access service or marketing emails or other messages we send to you) we may use technologies that automatically collect information about your usage, including but not limited to: data about your mobile device (such as your device-type, software and language preference) or desktop interface and IP address, your channel viewing information and interests, and your movement through our properties and on to external links, as well as your location. Collectively, this information is referred to as “Analytics Information.”   We may create a unique device or user ID for you so we can recognize you.  
 
Some tools that we may use to collect Analytics Information include:
      Cookies.   Cookies are small pieces of data that are stored on your computer or mobile device.  
      Tags/Pixels/Beacons.  These terms are generally used to describe small blocks of code on webpages that do things like allow another server to measure viewing of a webpage. 
      Location:  We can normally automatically detect your location data via your phone.  However, your operating system may require you to grant us permission to access your GPS.  If you do not permit this access, you may not be able to use the Service.
      Other.  We may use technology available on your device, technology similar to cookies and pixels and technology that is later developed, all for similar purposes.

Information We May Automatically Collect via Third Parties.
We sometimes use third party services to help us track activity and user flows within our properties, using similar tools to the ones we described (see Information We Automatically Collect).  Such tracking would track an individual user’s movements but the data would not be tracked in a personally identifiable way and would be treated as Analytics Information (below).
We may work with advertisers and others whose products and/or services are promoted on our properties that may also use similar technologies.  In those cases, we advise you to check their privacy policies.  To learn more about behavioral advertising or to opt-out of some types of behavioral advertising for participating ad networks, you can visit the Network Advertising Initiative (http://www.networkadvertising.org/choices/) or the Digital Advertising Alliance (http://www.aboutads.info/choices/).

Information We Receive From Third Parties.
There are instances where we may receive information from third parties.
As highlighted earlier, if you register via Facebook, LinkedIn or another social network or other future promotional partner, we will receive registration information from them. 
You may click through certain links or promotions via the Service or Site that will enable you to purchase products or use services provided by promotional partners or other sites or commerce providers.  Some of those entities may share with us certain information that you provide to them.   You agree to allow us to receive and use any information that you may provide to such entities, under the same terms as if you provided it to us directly. 
We may purchase or otherwise receive data from third parties and add it to our existing user database. Ona is not responsible and assumes no liability if another site or commerce provider uses any information about you in violation of its own privacy policy, or applicable law. 
 

3.Use of Information.  We use the information we collect in the following ways:
 

Registration, User Profile and Service Usage Information*
To provide the Service and manage your account, including, relevant to certain data, to share with Service Providers and/or Match partners, to facilitate their connection with you and potential Engagements and Matches (as described in our terms of use)
to maintain our customer lists 
for authentication purposes, including the conduct of criminal background checks, as detailed in our terms of use.
for Service improvement, 
to provide updates and announcements and to address issues like malicious use of the Service. 
for limited marketing purposes, namely, to contact you regarding your interest in the Service, to send you information about us or our partners and to personalize advertising or promotions for you. 
For internal purposes, we may retain logs of all comments that you post via any facilities that we provide, though we will not be obligated to do so.

 All information you send or post to areas of our properties (if any) that are public or semi-public (such as message boards) becomes public information that will not be treated as Personal Information.  So please be careful about posting any Personal Information to such areas. 

* We will not record any video or audio conversations that you engage in via the Platform, whether with Service Providers or with Matches or other third parties; however, we may keep records of any text messaging that you conduct via the Platform and also log the timing and other metrics relating to your use of any Platform functionality.
 
Geo-Location Information
Unless you have blocked the functionality on your mobile device, our Platform collects GPS location information from your mobile device, for the purpose of tailoring your Service experience based on your current location, including by sharing the same with Service Providers so that they can do the same, and for our internal analytics and other business purposes.  

Billing Information
If we offer premium products, we will use your Billing Information solely to check the financial qualifications of prospective customers and to collect payment for Engagements and any addition premium services or products that we may offer from time to time. 

Criminal Background Check
Per our Service user terms and conditions, in order to utilize certain parts of the Service, you agree that we may conduct a criminal background check on you.  The results of those checks will be retained by us for use as part of the provision of Services; specifically, to confirm or deny your eligibility for some all or of the Service.  Certain Service Providers may also have access to end-result of such (i.e., pass/fail but not the actual details behind the results) background check, also to be used by them for the purpose of determining eligibility for certain aspects of the Services.  

Quizzes and Surveys
Unless we state otherwise at the time, your responses to any quizzes and surveys posted through the Service will become part of your User Profile.  We may use that to improve the Service, for analytics and for our business purposes.    Service Providers will be able to view and access these responses as well when they view your User Profile via the Platform for the potential provision of Services.

Contests and Sweepstakes
Any Personal Information will be used only by us unless we specify otherwise when we ask you to participate.  However, we may share aggregate survey or contest result information with others. We will use the information you provide to conduct the contests or sweepstakes and for any other purposes to which you consent.  If we offer contests or sweepstakes with our partners, we may notify you that we will share the information we obtain from you with them and will give you the opportunity to choose whether or not to participate.

Analytics Information
We may use your Analytics Information in conjunction with an analytics service such as Google Analytics to monitor and analyze use of the Service or Site, for technical administration, to improve functionality and security to personalize the Service and improve your experience, and for internal analysis or for shared analysis with our partners. 
 
Information We Receive From Third Parties
We will use this in accordance with this Privacy Policy.

 
If we plan to use your Personal Information in the future for any other purposes not identified above, we will only do so after informing you by updating this Privacy Policy.  See further the section of this Privacy Policy entitled “Changes”.
 

4.Disclosures & Transfers.  We have put in place contractual and other organizational safeguards with our agents to ensure a proper level of protection of your Personal Information.  In addition to those measures, we will not disclose or transfer your Personal Information to third parties without your permission, except as specified in this Privacy Policy.
 
Unless you consent to receive information from our partners (or from a specified partner) during your Service registration or otherwise, we will never share, sell rent or trade your Personal Information with any marketing or promotional partners other than described in this Privacy Policy.  If you do consent to share your information with our partner(s), their use of such information, including targeted promotions, will be subject to their privacy policy.     The only other third parties with whom we may ever share some of your information are described in the bullet point list of exceptions below.
 

5.Exceptions.  The following are the ONLY exceptions, with respect to whom we may share your information with:
any of our affiliated companies;
companies acting as our agents in hosting, building, developing or otherwise supporting the Service or Site, including but not limited to any component thereof (e.g. customer/support services, email providers, billing processing) to you, all of which agree to use it only for that purpose and to keep the information secure and confidential;
Service Providers, in the context of their participation in the Service and any Engagements that they may provide, all of which agree to use it only for that purpose and to keep it secure and confidential.
entities into which our company is merged, or to which a substantially majority of our assets, equity, site or operations have been transferred or merged into (including during any diligence efforts in support of such an action), will be able to use your personal information under the terms of this Privacy Policy. We will notify you if any of these events occur by updating this Privacy Policy and, if practically possible, via other means; and/or
any entity with whom we are required to do so by law, for example, in response to a court order or a subpoena or other legal obligation, in connection with a bankruptcy proceeding, in response to a law enforcement agency's request, or in special cases when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property.

 

6.Security.  The security of your Personal Information is very important to us.  We use commercially reasonable efforts to store and maintain your Personal Information in a secure environment.  We take technical, contractual, administrative, and physical security steps designed to protect Personal Information that you provide to us.  We have implemented procedures designed to limit the dissemination of your Personal Information to only such designated staff as are reasonably necessary to carry out the stated purposes we have communicated to you.
 
You are also responsible for helping to protect the security of your Personal Information.  For instance, protect your devices and never give out your password. 
 

7.Sharing Information with Third Parties.  You may be able to share information with third parties through use of the Service or Site.  The privacy policies of these third parties are not under our control and may differ from ours.  The use of any information that you may provide to any third parties will be governed by the privacy policy of such third party or by your independent agreement with such third party, as the case may be.  If you have any doubts about the privacy of the information you are providing to a third party, we recommend that you contact that third party directly.
 

8.Third Party Widgets and Links.  We may display links to other sites and we may provide tools and widgets from other sites and services.    We are not responsible for those other sites and services, their privacy policies or how they treat information about their users.  We advise you to check their privacy policies to find out how they are treating your personal information.
 

9.Retention.  We will retain your Personal Information for as long as we believe that it remains useful to us for the identified purpose or as required by law, which may extend beyond the termination of our relationship with you.  We may retain certain data as necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, non-personally-identifiable data, account recovery, or if required by law.  All retained Personal Information will remain subject to the terms of this Privacy Policy.  Please note that if you request that your name be removed from our databases, it may not be possible to completely delete all of your Personal Information due to technological and legal constraints.
 

10.Changes.  We reserve the right to change this Privacy Policy at any time and without prior notice by posting an updated policy within applicable areas of the Service and Site.  If we do, the new terms will take effect at the posted effective date.  You should review this policy often, to make sure you have not missed any updates.  Additionally, if we believe that any updates reflect material changes to your rights, we will use reasonable efforts to provide additional notice to you, such as by email or by means of a notice on our home page and/or sign-in page that you must view to enter the Service.  Unless stated otherwise, our current Privacy Policy applies to all Personal Information that we have about you and your account. The date on which the latest update was made is indicated at the top of this document.  We recommend that you print a copy of this Privacy Policy for your reference and revisit this policy from time to time to ensure you are aware of any changes.  Your continued use of the Services signifies your acceptance of any changes.
 

11.Access.  You have the right to access the Personal Information we hold about you in order to verify the Personal Information we have collected in respect to you and to have a general account of our uses of that information.  Upon receipt of your written request, we will provide you with a copy of your Personal Information although in certain limited circumstances, we may not be able to make all relevant information available to you such as where that information also pertains to another user.  In such circumstances we will provide reasons for the denial to you upon request.  We will endeavor to deal with all written requests for access and modifications in a reasonably timely manner.
 

12.Your California Privacy Rights.  If you are a California resident and you decide that you do not want us to share your personal information with third party companies for their marketing and promotional purposes, please send an email to privacy@onadates.com. In this e-mail, state that you do not want Ona to share your personal information with third parties for their marketing purposes.  Your request will be processed within thirty (30) days of the date of which we receive it.
 

13.No Access to Children Under 13.   If you are under the age of 13 you may not use our apps or websites in any way. We don't knowingly collect data from anyone under the age of 13 and we do not direct any of our products or services at this age group. If we become aware that we have inadvertently captured any personal data about a person who is under 13 years of age, then we will take the appropriate steps to shut down the account of that person.

 

14.Contact Us.  You can help by keeping us informed of any changes such as a change of email address or telephone number.  If you would like to access your information, if you have any questions, comments or suggestions of if you find any errors in our information about you, please contact us by emailing privacy@onadates.com or by writing to us at:
 
    ONA 
    Attn: Privacy Officer
    118 West 22nd St., 3rd Floor, 
NY NY 10011
 
If you have a complaint concerning our compliance with applicable privacy laws, we will investigate your complaint and if it is justified, we will take appropriate measures.