Privacy Policy and Terms

for the mobile app Lea and the website lea.dating as offered by Planet Mobile Services Ltd..

Introduction

Planet Mobile Services Ltd., 78 York Street London, Germany (hereinafter “Planet Mobile Services Ltd.” or “we/us”) operates a platform and service for chatting, getting to know and meeting other people (hereinafter “Lea”) under the domain lea.dating and with the help of the mobile app Lea (hereinafter “Lea app”), which is available for download in various app stores for various operating systems.

The user of Lea (in the following: "user" or "you") can create a profile (in the following: "user profile") free of charge via the Lea domain or Lea app, upload pictures and exchange information with other users and their user profiles in case of interest. The user has the possibility to use functions such as the chat, the flirt radar or the match game and many other functions of Lea. A registration is possible from the age of 18.

Your data will be collected, processed and used in accordance with the EU-General Data Protection Regulation (GDPR) 2016/679 applicable as of May 25th 2018 and the related privacy laws.

This privacy policy explains how we handle personal data. Personal data is individual information about personal or factual circumstances of a certain or determinable natural person. This includes, for example, name, birthday, telephone number, but also e-mail address and usage data, such as IP address. Furthermore, the data protection declaration serves to inform about which data is collected, stored and processed and how Planet Mobile Services Ltd. guarantees the protection and security of personal data.

Planet Mobile Services Ltd. does not enforce the use of a real name. Instead of a name, the user can register with and make use of Lea under a pseudonym.

§ 1. How is my data collected, processed and used upon download of the Lea app?

§ 1.1 Download of the Lea app

Upon download of the Lea app, the necessary information is transmitted to the respective app store operator. This is for example, but without limitation and subject to the app store, the email address or the customer number of the app store user for the respective app store, the time of download and an individual device ID. However, Planet Mobile Services Ltd. has no influence on any data collection by the app store and is not responsible or liable in such way. The corresponding privacy policy / settings of the respective app store operator are applicable and it is recommended that you check those accordingly.

Planet Mobile Services Ltd. processes the data made available by the respective app store operator solely to the extent necessary for the download of the Lea app.

§ 1.2 Installation and permissions

Lea requires various access capabilities and information for the technical functionality of the Lea app and for the provision of the services offered through the Lea app.

Depending on the operating system, your permission to us in order to access individual functions and information will be requested during the installation process. The access permissions may include, among others, location, messages as well as mobile data.

These permissions can partly be manually controlled and organized by you in the settings of your device. In doing so, however, it should be considered that, without the respective approvals, the Lea app will only provide for limited usability or may be completely unusable. Depending on the app version, permissions will be requested either before, during or after installation.

§ 2. How will my data be collected, processed and used upon visiting the Lea domain or the Lea app without creating a user profile?

Planet Mobile Services Ltd. uses the personal data that the user provides or that incurred in the use of Lea without creating a user profile, without separate consent solely for the implementation of the user relationship and as presented in this privacy policy.

Upon visiting the Lea domain (to a so-called “landing page” or“homepage”) or installing the Lea app without the creation of a user profile, Planet Mobile Services Ltd. collects the following data transmitted by the user’s device/browser:

IP address, name of the website accessed, data, date and time of the request, transferred data volume, browser type and version, referrer URL (original URL) of the user who accessed the page. Lea also collects the following data transmitted by the user’s device upon simple installation of the Lea app without registration or creation of a user profile:

Push handle (for sending push notifications), location data (GPS location), country code, language, device name, name and version of the operating system.

These data are necessary for the use of the Lea domain or the installation of the Lea app, and as such are necessary for statistical purposes and to optimize Lea. The data is processed and used to prevent and combat illegal acts and spam as well as to ensure the stability and integrity of the Lea platform.

The location data is collected, processed and used so that the user can make use of the so-called location-based service, that includes tailored recommendations for the respective location. For more details please check 3.3 and 4.3 of this policy.

Furthermore, Lea uses cookies (see item 4.1), analytics services and tracking providers (see item 4.2).

§ 3. How is my data collected, processed and used after creating a user profile and upon use of the Lea app and Lea domain services?

Planet Mobile Services Ltd. uses the personal data that the user communicates or that becomes available when using Lea after creating a user profile, solely for the implementation of the user relationship and as presented in this privacy policy. For such use, your additional consent is not required.

The creation of a user profile is necessary to be able to use Lea to its full extent and you herewith agree to this. In addition, you may provide further personal data, which Planet Mobile Services Ltd. may use in order to provide the respective service and the best user experience.

§ 3.1 Mandatory details for the creation of a user profile

For the creation of a user profile, the following details are essential and shall be provided:

  • Gender
  • Age
  • User name (pseudonym)
  • City
  • E-mail address
  • Password
  • The data provided by you will be collected, processed and used for the purpose of using Lea. Without limitation these details serve for the mandatory data like personal address, authentication, age verification, profile personalization, the display of suitable user profiles. They may also be used in connection with and for advertising purposes (see item 4).

    § 3.2 Voluntary data

    In addition, you can provide various voluntary details in your user profile. This serves, in particular, for the Lea function whereby recommendations for other user profiles according to various criteria are selected for the user and displayed within Lea. Additional information increases the chance of, matching and meeting suitable user profiles. These details may be provided by you optional and can be viewed, entered, modified or deleted by you at any time in the profile under Details.

    The data provided is collected, processed, and used by us for the purpose of delivering the Lea service.

    These voluntary details are visible to all users logged in within Lea, but can be deleted or modified at any time by the owner of the user profile under the settings in the user profile.

    § 3.3 Location data

    Lea also includes so-called location-based services, under which the user will have access to special functions that are tailored to the respective location. Hereby, the user or, in particular, other users, who are around and nearby, can be displayed. In order to offer these functions within the Lea app, Lea collects location data via the GPS of the device in use as well as location data via radio access nodes. When the location service is active, with permission, the location will be regularly transmitted to Planet Mobile Services Ltd., where it will be processed and used.

    The user can modify this function in the operating system settings on their device at any time. This means to permit or revoke the acquisition of location data.

    § 3.4 IP addresses

    User IP addresses are recorded for security and testing purposes. This should prevent any misuse of the service. The data is processed and used to prevent and combat illegal activities and spam as well as securing the integrity and stability of the Lea platform.

    § 3.5 Payment data

    Any in-app purchases or the purchase of so-called “Credits” will be charged by external payment providers. No payment data is collected or processed by Planet Mobile Services Ltd. for any of such purchases. The entry as well as the processing of the payment data is solely by the payment provider. Technical data (the transaction ID and other) is being exchanged between Planet Mobile Services Ltd. and the chosen payment provider in order to validate the purchase.

    § 4. Which cookies, tracking providers, analytical services does Lea use? How are Social Media and Like buttons embedded?

    § 4.1 Cookies and cookie policy

    In order to be able to use the Lea domain as comfortably as possible, we use cookies on the Lea domain. Cookies are small text files that are stored locally in the cache of the Internet browser (so-called session cookies) or on the hard disk of the mobile device or computer used (so-called permanent cookies). The browser settings can be selected so that cookies are rejected or a reference is made to them before cookies are set. By setting cookies, users are assigned pseudonymized IDs. Cookies do not run programs on the user's end device or even transmit viruses. Session cookies are deleted from the cache after the end of the browser session.

    Planet Mobile Services Ltd. also uses cookies to increase the security of the Lea domain. For example, to authenticate the user during a session, to avoid cross-site scripting or to prevent phishing and fraudulent actions such as scamming.

    Furthermore, tracking providers / analysis services (see also the explanations under point 4.2 Use for the use of tracking providers / analysis services) place cookies on the user's device on behalf of Planet Mobile Services Ltd. in order to record the usage data. This is data that can be collected while the user is z. B. moves on the pages of the Lea domain or clicks on advertising. These cookies are used to display targeted advertising, to optimize reports on advertising campaigns and to prevent identical advertising from being displayed multiple times.

    Users can influence the use of cookies. Most browsers have a setting option with which the storage of cookies is restricted or completely prevented.

    However, we would like to point out that the use and in particular the comfort of use of Lea can be restricted without the use of cookies.

    § 4.2 Tracking providers, analytics services

    Lea carries out user tracking analytics in order to optimize the Lea services and user experience. Planet Mobile Services Ltd. implements analytical methods that enables Lea to analyse visits to the Lea domain and Lea app. Furthermore, third-party tracking tools are integrated to analyse the range of different advertising campaigns and marketing activities. Personal data can also be transmitted under use of third-party tools.

    In addition to troubleshooting, the purpose of data processing is the optimization of Lea with regard to user experience. With web analysis methods, Planet Mobile Services Ltd. also obtains statistics on visitor numbers and their temporal browsing of popular content as well as the duration of visits per click and page. When appropriate, it can be tracked whether a user profile was created subsequent to viewing an advertisement. The data is processed and used to prevent and combat fake profiles, unlawful activities and spam as well as to ensure the security of the Lea platform. User data is transmitted to various third parties to carry out the analysis.

    The following analysis and tracking providers are currently in use with Lea:

    Crashlytics
    The Lea app uses the Firebase Crashlytics analysis tool by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland (hereinafter “Crashlytics”). This analysis program uses IP addresses of the users for analysis purposes, which are used only anonymously however. It is not possible to trace a specific person. Crashlytics delivers analysis to Planet Mobile Services Ltd. on system crashes and thereby facilitates maintenance and improvement of the Lea app and Lea domain. A user ID, the clicks and the technical device data is transmitted to analyse the error.

    If you have voluntarily and expressly agreed to submit a crash report in the App settings or after a crash, anonymous information (device type, version of the operating system, hardware data of the mobile device, current position in the source code, time of the crash and the state of the application for Time of the crash) will be transmitted to the servers of Google and stored for evaluation. Crash reports contain no personal information. For more information about privacy, visit https://firebase.google.com/support/privacy.

    Google Analytics
    Lea uses “Google Analytics”, a service by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (hereinafter: “Google”). Planet Mobile Services Ltd. points out that for use with Lea, Google Analytics has been extended with the IP masking function “_gat. _anonymizeIp”, to guarantee the recording of anonymized IP addresses.

    The following information on the use of Google Analytics should be noted:

    Google Analytics uses cookies that are stored on the device and enable an analysis of the use of Lea. The Lea usage information produced by the cookie is generally transmitted to a Google server in the USA for storage. However, since IP anonymization is active, the IP addresses of all uses in the EU and associated countries are shortened by Google prior to transmission to the USA. Under contract between Planet Mobile Services Ltd. and Google, Google uses the information to evaluate the use of our services, to compile reports on activities and to provide the operator with further services.

    The user has the option to opt out:

    Google Analytics data acquisition and storage can be revoked at any time with future effect. The user also has the option to install a browser plugin issued by Google. This is available for various browser versions and can be downloaded here. You can learn more about data usage for advertising purposes, settings and opting out on the following Google webpages:

    (“Google’s data usage when you use our partners’ websites and apps”),

    (“Data usage for advertising purposes”),

    (“Data usage for advertising purposes”) and

    (“Determine what advertising Google places”).

    Adjust
    Lea uses the app “adjust”, a product of the company adjust GmbH, Saarbrücker Str. 37a in 10405 Berlin, Germany, as a usage analysis tool. When the user installs the Lea app, adjust stores installation and event data from the iOS or Android app. Using this, we can understand how our users interact with the Lea app. Moreover, we can thereby analyze and improve our mobile advertising campaigns. adjust uses the IDFA or advertiser ID as well as your anonymized ID and MAC address. The data is unilaterally made anonymous. This means that it is not possible to identify you or your mobile device. If you don’t want adjust tracking, please select here.

    Rapidmail
    Send out of newsletters and other emails is carried out by our email marketing service provider rapidmail GmbH, Augustinerplatz 2, 79098 Freiburg i.Br., Germany. You can see the privacy policy of the email marketing service provider here. The email marketing service is used on the basis of our legitimate interests in accordance with Article 6, paragraph 1, point f of the GDPR and a processor contract in accordance with Article 28, paragraph 3 of the GDPR.

    Google Firebase
    Furthermore, we use the service “Google Firebase” for the analysis and characterization of our user groups and the delivery of push notifications. You can find Firebase’s privacy policy here (insert link) as well as Google’s privacy policy here.

    Fyber
    For app monetization, we use Fyber, a Fyber GmbH service from Berlin (insert full address). The company Fyber also sets cookies. We do not use Fyber via JavaScript integration. Your IP address is not made accessible. Fyber only receives pseudonymized data from us for billing purposes. The data cannot be used by Fyber to trace a specific person. Further details on data protection can be found here.

    Google-Tag-Manager
    We use Google Tag Manager. Google Tag Manager is a solution, with which marketers can manage website tags via an interface. The Tag Manager tool itself is a domain without cookies and the tool does not collect any personal data. The tool triggers other tags, which for their part may collect data. Google Tag Manager does not access this data. If disabled at the domain or cookie level, this remains the case for all tracking tags that were implemented with Google Tag Manager.

    Google Adwords
    We use the online advertising program “Google AdWords” and conversion tracking within the framework of Google AdWords. Google Conversion Tracking is an analytical service by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland ("Google"). When you click on an advertisement placed by Google, a cookie for the conversion tracking will be placed on your computer. The cookies have limited validity, contain no personal data and do not enable a personal identification. If you visit certain internet pages on our website and the cookie has not yet expired, we and Google can recognize that you clicked on the advertisement and were redirected to this site. Every Google AdWords customer receives a different cookie. It is therefore not possible for cookies to be tracked over the websites of Google AdWords customers. The information obtained with the help of the conversion cookie serves for the creation of conversion statistics for AdWords customers, who have selected conversion tracking. Hereby, the customers learn the total number of users that have clicked on their advert and have been redirected to a page with a conversion tracking tag. They receive, however, no information that can be used to personally identify users. If you do not want to participate in tracking, you can opt out by blocking the installation of cookies through a corresponding setting in your browser software (deactivation option). Upon opting out you will not be recorded in the conversion tracking statistics. You can find further information as well as Google’s privacy policy here.

    Google ReCaptcha
    We integrate the function for the recognition of bots (“ReCaptcha”), e.g. for entries in online forms, offered by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. You have the right to opt out.

    Facebook Pixel and SDK
    We use the "Facebook Pixel" on our websites https://www.lea.dating and https://lea.blog/ and in our Lea App the "Software Developer KIT" (SDK) of the social network Facebook, 1601 South California Avenue, Palo Alto, CA 94304, United States. These counting pixels are integrated on our pages and in the Lea app. When visiting our websites and using our app, a direct connection between your browser or mobile device and the Facebook server is being established.

    Facebook gets the information from your browser that our website has received from your device. If you are a Facebook user, Facebook may assign your visit to our Sites and the use of our App to your account. We point out that we are not aware of the content of the transmitted data and their use by Facebook. We can only choose which category of Facebook users (such as age, interests) our ad should display.

    By calling the pixel from your browser, Facebook can also tell if a Facebook ad was successful. In this way we record the effectiveness of Facebook advertisements for statistical and market research purposes.

    We use the data obtained from the Facebook pixel in the Facebook analysis tool "Facebook Analytics" to optimize our websites and our app.

    For more information, see the Facebook Privacy Policy at https://www.facebook.com/about/privacy/. Please click on the following link if you do not want to collect data via Facebook Pixel: Opt out of Facebook Pixel Tracking here

    § 4.3 Social media links

    Links to Planet Mobile Services Ltd. accounts with the social networks Instagram and Facebook are incorporated on the Lea domain. After clicking on the integrated graphic, the user will be redirected to the respective provider of Instagram or Facebook. This means that only then will user information be transmitted to the respective provider.

    If the user is logged in to their user profile on the respective social network, after activation of the button, an association with the Lea visit is made.

    If the user does not want data to be collected via the Lea domain by the social networks, they should log out of these before visiting the Lea domain. However, every time the corresponding button is activated through a click, a cookie or cookies with an identifier are set by Lea. Data could be collected and a profile created through the use of this function, which could, under certain circumstances, be traced back to an individual person. If the user does not want this, they can deactivate the link within the Lea domain with a click. The user can also set up their browser in such a way so as to generally exclude the use of cookies. We point out, however, that, in this case, functionality of Lea could be limited.

    Information on the handling of personal data when using these websites can be taken from the respective provider’s privacy policy.

    Facebook
    Facebooks’s privacy policy (operated by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA) can be found here.

    Instagram
    Instagram’s privacy policy (operated by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA) can be found here or here.

    YouTube
    The privacy policy of Google and YouTube (each operated by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland) can be found here.

    § 4.4 Facebook-Connect

    Planet Mobile Services Ltd. offers the user the option to register for Lea with Facebook Connect. The user will be redirected to the Facebook website (operated by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA) to register, where they log in with their user data as long as they are not already logged in. With a click, the respective Facebook profile and the Lea user profile are linked. Upon linking, Planet Mobile Services Ltd. automatically receives user data from Facebook in the form of the email address and further data from the user’s public Facebook profile. The public Facebook profile contains data, which the user has made publicly accessible on Facebook. The public Facebook profile typically comprises the following data: name, profile picture, sex, language, country, age range, Facebook ID, friends, likes and relationship status.

    Of the data transmitted by Facebook, Planet Mobile Services Ltd. uses the email address, Facebook ID, profile picture and date of birth. This information is used for the user profile. Further information on Facebook Connect and the privacy settings can be found in Facebook’s data protection information and terms of use.

    §5. How is data disclosed / transmitted?

    Planet Mobile Services Ltd. does not forward personal data of a user to third parties, unless the user has given his or her consent to do so, or the transmission is prescribed by law or permitted by law.

    § 5.1 General information on the transmission of personal data

    User data and other data

    Lea is permitted to transmit customer data to the following third parties for the execution of the agreement:

    External service providers and representatives. Lea can employ external companies or individuals to process customer data.

    Affiliated companies. Lea can employ affiliated companies to process customer data.

    Other disclosures

    Lea is permitted to transmit and disclose customer data as follows:

    As part of changes to business structure. In connection with mergers, acquisitions, insolvency proceedings, liquidation proceedings, restructuring measures, divestment of all or part of Lea's assets, financing, acquisitions of part or all of our business, similar transactions or procedures or steps in consideration of such activities (e.g. due diligence).

    As part of legal regulations. To comply with legal or regulatory requirements and in response to legitimate requests, court orders and legal actions. As part of the implementation of the rights of Planet Mobile Services Ltd., to prevent fraud and to ensure security. To protect and defend the rights, property or security of Lea or third parties, including the implementation of contracts and policies, and in connection with the investigation and prevention of fraud.

    Lea is entitled to use aggregated data, or data that has been adjusted for personal characteristics, for any purpose. Lea can transmit aggregated data to a partner or other for commercial or analytical purposes, by publishing how many messages are sent through Lea in a single day for example. None of this data includes your personal data.

    § 5.2 Categories of data recipients

    Lea currently uses external data processors for the following services:

    Email marketing services (e.g. Rapidmail), analysis and tracking services (see item 4.2). Depending on the nature of the services provided, Lea may also call in affiliates as data processors to provide some or all of the services offered to the user.

    § 6. What is the procedure for deleting data and creating backups?

    All data collected from a user will be deleted upon deletion of the user profile (caution: not by just the deleting the Lea app!). This excludes data that must be retained due to legal regulations or the performance of the user agreement. Furthermore, you can delete selected data in the profile at any time or make an appropriate request to us. Deletion of data from the productive databases and subsequently from the Lea interface will be executed within 48 hours.

    Planet Mobile Services Ltd. reserves the right to check profile files before deletion and, if necessary, to secure them if, due to certain facts, there is a suspicion in the usage profiles that they are using Lea in contradiction to the law or the user agreement. This serves to protect users of the Planet Mobile Services Ltd. services.

    In addition to deletion of data triggered by the user, Lea automatically deletes historical data that is no longer needed for the fulfilment of the agreement (e.g. historical location data as well as IP data) from time to time.

    § 7. What data security measures does Lea provide?

    We are taking the trust of our users and the protection of your data very serious. Planet Mobile Services Ltd. implements appropriate physical, technical and administrative procedures to protect the information collected by Planet Mobile Services Ltd. in order to prevent unauthorized access or disclosure of user data, to preserve the integrity of the data and to ensure the appropriate usage of the data.

    In order to provide optimized protection of user data, the Lea domain and Lea app are operated under an encrypted SSL connection. This guarantees encrypted data transmission between the servers and the browser as well as between the servers and the app.

    § 8. User rights: consent and revocation, disclosure, rectification, deletion, transmission

    § 8.1 Consent and revocation

    In the course of registering with Lea, the user agrees that his personal data may be collected, stored and processed in accordance with this privacy policy and the terms and conditions. The user must expressly declare this consent when creating the user profile. This consent, as well as the entire process of creating the user profile, is recorded by Planet Mobile Services Ltd..

    The user can revoke his consent at any time with effect for the future. This can be done by deleting the user profile (not the Lea app), at the indicated places in the Lea app or Lea domain within the user profile or by e-mailing us at:

    E-mail: info@lea.dating

    § 8.2 Disclosure, rectification, deletion, transmission

    In accordance with the applicable laws, you are entitled to receive full disclosure of your stored personal data as well as, if necessary, to a right of rectification and / or deletion or transmission of your privacy data.

    For performing such a request, please e-mail us at info@lea.dating.

    § 9. Changes to the Privacy Policy

    Planet Mobile Services Ltd. reserves the right to update this privacy policy from time to time. The use of the user personal data is subject to respective updated version which can be found here

    § 10. Data protection officer

    If you have any questions or concerns regarding privacy, please contact our data protection officer:

    Sven Weschler email: kontakt@iqanta.com