Effective date: 2017-05-16

1. Introduction

We believe that open communication and transparency are important, especially when it comes to processing your personal data. When you use our platform we process personal data. Personal data is data that allows us (regardless, whether we do this or not) to identify the User (cf. 'you') as a natural person. You are not required by law to share your information with Twoo or to accept this Privacy Policy. Please do not use our website if you do not agree with this Privacy Policy or do not want to share your information with Twoo.

Who are we?

This platform, including website and (mobile) (web) applications, is managed by:

Massive Media Match NV
18 Emile Braunplein
9000 Ghent, Belgium
Company number: VAT-BE 0537.240.636

2. How do we collect personal data?

2.1. Via the User

When you use our platform we collect some of your data, such as:

  • Information that you provide us with when setting up your profile; including registration data, account settings and content that you add to your profile such as photos, text etc.
  • Data that we generate from your use of our platform. For example: data regarding the pages you visit, your interaction with other users, posts you share and data regarding the use of platform functionality.
  • When you activate our paid services: data we use for invoicing, delivery and payment of our paid services.

With the exception of gender and birthday, your Twoo profile details can be edited at any given moment via your Profile. Information about your name, email address, gender, date of birth and location is necessary to provide our service to the user. If you choose to give additional information about yourself, you explicitly give us permission to use that information as described in this Privacy Policy.

2.2. Via various technical resources

On our platform we use various technical resources, which optimize the user experience and the functionality of our platform. The data that we collect by using those technical resources are:

  • Information regarding appliances used, such as data on the type of hardware and/or software.
  • Cookies and local storage information: these are small data files in which your preferences are stored to offer more efficient functioning of the platform.
  • Login information: all information generated from your login onto our platform. For example the IP address you login from and various telecommunications data.

Based on your IP address, your (probable) location can be stated on a geographical map.

2.3. Via external partners

A User can create various links on our platform with other social network sites. The User must manually set up those links. Through these social network sites we can retrieve missing profile information with which we can complete your profile.

Our platform offers the possibility to invite your personal contacts to our platform. This can enlarge your network. As a User you select the contacts that you want to invite to the platform. As soon as you activate this feature, you will be able to send the people you want to add to your network a personal invitation or reminder. We will ensure that this can be done simply and automatically. The data we collect for this is only processed for this purpose.

3. For what purpose do we use your personal data?

We collect your personal data for one main purpose: to give every User of our platform a safe, optimal and personal user experience. The more you, as a User, use our platform, the more of your personal data we will process.

Our unique user experience includes the following:

  • The publication of your user profile: A social platform means that you can make contact with other users. We process your data in a unique user profile that will be visible for other Users, visitors of the platform and users of some search engines. A User controls the information on his or her profile (via Profile) and can choose whether or not his or her profile is included in public search results (via Settings). User profiles may be visible on other social websites, who are property of Massive Media Match NV, and its sister, daughter, or mother companies.
  • The improvements and development of matching results, techniques and other functionalities: We are specialized in successful matching. Our results are more accurate and more successful as we have more details on our users.
  • Providing various (commercial) communications: We may use the obtained personal data to send various (commercial) communications. These communications can be sent by us, or by third parties on behalf of us. We may use third parties that ensure efficient distribution of the communication. Third parties may only use personal data for purposes determined by Massive Media.
  • The improvement of platform functionality by analysis and interpretation of user statistics: We are happy to make use of new techniques to improve and renew our products and services.
  • The detection of, and protection against fraud, errors and/or criminal behavior and breaches of our code of conduct: This is necessary in order to be able to offer a secure and a high-performance platform.
  • General member management and carrying out our paid services. By this we mean any action necessary to ensure proper service to our users.

Some of the data we receive can, due to their nature, be qualified as โ€œsensitiveโ€. Sensitive data is data considering your health, racial or ethnic origin, political opinions, religious or philosophical beliefs and sexuality. Users are not required to share personal data on their profiles, but they can choose to do so. Personal data will only be processed in function of previous mentioned objectives. During the registration process, the user agrees explicitly to the processing of all of his personal data.

4. Is my personal data shared with third parties?

Relax! Personal data is only shared with third parties in the following circumstances:

4.1. Our specialized processing partners

We make use of numerous technologies and techniques to ensure the proper functioning of our platform and services. This is made possible by the products and services of our specialized partners.

Users can rely on the following guarantees:

  • We select our partners after a strict selection procedure and in accordance with legal requirements.
  • We have made clear arrangements with our specialized partners concerning the functioning of products and services.
  • But above all: our specialized partners cannot use your personal data for their own purposes.

Personal data will always be anonymised when we transfer them for external analysis.

4.2. Our links with other platforms

Our platform contains integrations with various social networking platforms, such as Facebook, VK, Instagram, Google, LinkedIn, Twitter and QQ. These integrations are provided by these platforms. The provider of the social network platform may use the obtained personal data for its own processing. We would like to refer you to the privacy statement of each social network platform for more information concerning the processing of your personal data by those platforms. The various social network platforms are responsible to provide an appropriate level of protection for the processing of personal data.

4.3. Other third parties

Certain personal data may be transferred to other third parties for the purpose of additional services. Such additional services are carried out exclusively at the initiative of the informed and consenting user. The third party will use the acquired personal data for its own processing operations in response to the additional services. For more information we would like to refer to the privacy statement of the respective third party. We only suggest third parties who we believe can be of added value to our services for our Users.

4.4. In case of fraud, criminal offence or criminal investigation

Our platform revolves around security and trust. We work on this on a daily basis. We therefore provide all necessary information in case we are asked to do so by any applicable law or regulation or by any competent court or any regulatory authority. We do not provide any more information than is requested or is really necessary.

4.5. Data processing outside the European Union

Massive Media Match NV is a European company. Personal data is (in principal) only being processed within European territory. Nevertheless, we cannot completely rule out that processing and/or transfer of data to countries outside of the European Union occurs. In accordance with the European Privacy Policy personal data may only be transferred to countries that ensure the same adequate level of protection. The level of protection relates to the storage period, storage and nature of the data and precise purposes for processing. We guarantee that no data will be transferred to countries, which do not ensure an adequate level of protection. Data shared with the United States is shared based on a data transfer agreement incorporating the standard contractual clauses of the European Commission.

4.6. The IAC family

Massive Media Match NV is part of the IAC family (<a href="http://www.iac.com">www.iac.com</a>). Personal and non-personal data of members can be exchanged between the various companies and websites of the IAC family. All members of the IAC family apply the same standards and guarantees for fair and lawful processing of personal data.

4.7. Aggregated and/or non-personal data

We may share non-personal data we collect under any of the above circumstances. We may also share it with Match Group companies and third parties to develop and deliver targeted advertising on our site and on websites or applications of third parties, and to analyze and report on advertising you see. We may combine non-personal data we collect with additional non-personal data collected from other sources. We also may share aggregated, non-personal data, or personal data in hashed, non-human readable form, with third parties, including advisors, advertisers and investors, for the purpose of conducting general business analysis, advertising, marketing or other business purposes. For example, we may engage a data provider who may collect web log data from you (including IP address and information about your browser or operating system), or place or recognize a unique cookie on your browser to enable you to receive customized ads or content. The cookies may reflect de-identified demographic or other data linked to data you voluntarily have submitted to us (such as your email address), that we may share with a data provider solely in hashed, non-human readable form. We may also share your geolocation information in de-identified form with Match Group companies and third parties for the above purposes.

5. What are my rights as a data subject?

Every User can be assured that we will process his or her personal data in a fair and lawful manner. We guarantee the following:

  • Your personal data will only be processed for expressly stated and legitimate purposes;
  • Processing of personal data will always be sufficient, proportionate and never excessive;
  • We will never store your personal data longer than is strictly necessary. The standard term is twelve (12) months after deleting data or profiles.

We have taken sufficient technical and organizational measures to guarantee safe processing of your personal data. These measures are consistent with the nature of the personal data and proportionate to the potential severity of the risk.

The risk of accidental or unauthorized destruction, loss, alteration of, or access to, and any other unauthorized processing of personal data is reduced to a minimum. This is a best efforts obligation.

Every user has the following rights:

  1. The right to object: Each User can oppose to the processing of personal data when there are sufficient legitimate and serious grounds relating to his or her particular situation. The User may at any time, free of charge and without further ado, oppose the proposed processing of personal data if the data was obtained for the purpose of direct marketing.
  2. Right to access: Each User has the right of access to all information regarding the processing of his personal data.
  3. Right to correct and delete: Each User can, at any time, ask for a correction or deletion of his personal data. The User itself must have undertaken all other possible actions for the purpose of correction or deletion. The removal is mainly related to visibility.

6. About this Privacy Policy

The completion of your registration contains an explicit acceptance of the processing of your personal data.

Given the fact that technology will always innovate, we cannot estimate what the future functionalities of our platform and services will be. Therefore your consent will also apply to the processing of your personal data by new technologies and techniques, which fall within the original purpose of our platform.

We preserve the right to change our Privacy Policy. Every substantial change will be communicated via our Privacy Policy. We recommend our users to check our Privacy Policy on a regular basis. Changes in our Privacy Policy will be effective within thirty (30) days after being adjusted in our Privacy Policy.

In case of an acquisition or sale of our company, all the rights and obligations deriving from this Privacy Policy will be transferred to the new owner. If the new owner changes the Privacy Policy substantially, he will provide the users with all the necessary information regarding those changes.