SANA Privacy Policy
SANA Privacy Policy
This explains how we collect, store, protect, and share your information, and with whom we share it. We suggest you read this in conjunction with our brilliant Terms and Conditions of Use. While you're using the SANA application ("App") and website Sana.love ("Site"), we collect some information about you. In addition, you may choose to use the App to share information with other SANA users, including your friends and contacts ("Users"). We may also need to share your information sometimes.
SANA is a global app, and your information will be sent to and used in the United States regardless of the country you reside in. This Policy explains how we protect your personal data when we transfer it overseas, so please read very carefully!
If you have any questions or comments about this Policy, please feel free to contact us at privacy@SANA.Love
COLLECTION OF INFORMATION.

Registration Information

When you download the App or visit Website and create an account ("Account"), we may collect certain information ("Registration Information") about you, such as:


  • Username;
  • Name;
  • Email address;
  • Mobile number;
  • Gender identity;
  • Date of birth;
  • Personal preferences and interests;
  • Photographs;
  • Location;
  • Login information and friend lists for social media accounts that you connect to your SANA Account (this could include, for example, your Facebook and Instagram accounts ("Social Media Accounts").

  • Search history
  • Chat history
  • Liked and disliked (skipped) profiles
  • Crashreports
  • Device characteristics
  • Links to social profiles

You will also be required to create a password in connection with the registration of your Account. Once you register, you will be able to review and change this information at any time by accessing your "Profile" page!

You control your user profile and are able to correct or update (other than your email address, Lovele number, date of birth, gender and location (which is automatically updated)) your information at any time by just logging in to SANA.

The information we collect helps to enhance the App and verify our Users (robots are not welcome!!). Registration Information such as your name and username may be visible to the public on your profile page.


Additional Information

We may ask you to provide your full name, address and email address for security or marketing purposes.

We may also collect additional information in connection with your use of SANA, for security or marketing purposes.
We will inform you about it.

If you contact our Customer Support team, we will receive your email address, and may track your IP address as well as the information you send to us to help resolve your query. We will keep records of our communications with you, including any complaints that we receive from you about other Users (and from other Users about you).

We recommend and encourage you (and all our members) to think carefully about the information you disclose about yourself. We also do not recommend that you put email addresses, URLs, instant messaging details, phone numbers, full names or addresses, credit card details, national identity numbers, drivers' license details and other sensitive information on your profile which is open to abuse and misuse.

Please be careful about posting sensitive details about yourself on your profile such as your religious denomination and health details. You may also choose to add sensitive information about yourself when you add certain badges and symbols to your profile, relative to your religion and political leanings. While you may voluntarily provide this information to us when you create your profile, including your sexual preferences, there is no requirement to do so. Please remember that photographs that you post on SANA may reveal information about yourself as well. Where you upload and choose to tell us sensitive information about yourself, including through adding certain badges and symbols to your profile, you are explicitly consenting to our processing of your information and making this public to other users.

When you post information about yourself or use the messaging function, the amount of personal information you share is at your own risk. Please see Section 4 below for more information on who can access what you post on SANA. If you post anything that is inconsistent with our Terms and Conditions of Use, we reserve the right to terminate your Account - we really don't want to have to do this so please play by the rules!

For safety and security and to ensure you have the best possible user experience, we require users to verify their accounts and might ask for your phone number. We want to make sure you are not a robot! And we also want to avoid fake SANA accounts being created which can be used for malicious activities and cybercrime – they threaten the SANA network and spoil things for everyone. We use a third party provider for account verification who will keep your phone number for up to 90 days for fraud identification purposes. We collect and use your phone number on the basis of our legitimate interests identified in section 11 below and for the prevention of fraud.

It is your responsibility to ensure that your account details are kept up to date. If your phone number changes, please ensure that you update this in your account.

To prevent abuse of the app/site, SANA may use automated decisions to block accounts as part of its anti-spam procedures. In order to do this, our systems check accounts and messages for content that indicates breaches of our Terms and Conditions of Use. If an account or message meets certain criteria that demonstrate that the Terms and Conditions of Use are likely to have been breached, the relevant account will automatically be blocked.

Please note that if your account is blocked, any account(s) that you have on our other group platforms/applications may also be blocked as part of our anti-spam and anti-fraud procedures.

If you decide to purchase any of our premium services, we will process your payment information and retain this securely for the prevention of fraud and for audit/tax purposes.

We process some limited data (demographics and information that you have optionally provided us) to drive targeted advertising in our legitimate interest, via promo cards and ads on our App. We also process limited data (device identifiers) and share this with third party advertising networks which host our ads. Through your device's security settings you also have the option to prevent or limit device identifiers being shared with third party advertisers and what use is made of the device identifiers. If you would like more information about this practice and to know your choices about not having this information used by these companies, please visit this page https://optout.networkadvertising.org/?c=1

Finally, we want to keep in touch with you to make sure you know about the great promotions and offers we have available. If you've told us it's OK, we will use your email address and phone number to send you information on these. You can withdraw this consent at any time via Settings in the App.

For users who are California residents.

If you are a California resident, you can request a notice disclosing the categories of personal information about you that we have shared with third parties for their direct marketing purposes during the preceding calendar year. To request this notice, please submit your request by e-mail support@SANA.Love

Please allow 30 days for a response. For your protection and the protection of all of our users, we may ask you to provide proof of identity before we can answer such a request.

The data we may collect falls within the following categories of "personal information," as defined by the California Consumer Privacy Act (CCPA):

  1. Identifiers, such as name and location;

  2. Personal information, as defined in the California customer records law, such as contact (including email and telephone number) and financial information;

  3. Characteristics of protected classifications under California or federal law (if you choose to provide them), such as age, gender identity, marital status, sexual orientation, race, ancestry, national origin, religion, and medical conditions;

  4. Commercial information, such as transaction information and purchase history;

  5. Biometric information (not relevant here);

  6. Internet or network activity information, such as browsing history and interactions with our websites and apps;

  7. Geolocation data, such as Lovele device location;

  8. Audio, electronic, visual and similar information, such as photos and videos;

  9. Professional or employment-related information, such as work history and prior employer;

  10. Non-public education information; and

  11. Inferences drawn from any of the personal information listed above to create a profile or summary about, for example, an individual's preferences and characteristics.
Data storage

By using the App and Site, you acknowledge that SANA is a global service operating through servers located in a number of countries around the world, including China and the United States. If you live in a country with data protection laws, the storage of your personal data may not provide you with the same protections as you enjoy in your country of residence.

Geolocation Information

If you turn these features on, when you use SANA, we will collect information about WiFi access points as well as other location information about your longitude and latitude and may save your device's coordinates to offer certain features to you. This information helps us identify your physical location and we may use it to personalise the App and make it easier for you to interact with other Users, by enabling the information to be displayed and shared with other members choosing to view "nearby" posts.

If you have enabled location services, but wish to turn them off, you can do so by the following methods:

iPhone app — settings, privacy, location services, SANA

Android — settings, location, SANA, permissions, location

Log and usage data

We keep your personal information only as long as we need it for legitimate business purposes (as set out in Section 11 below) and as permitted by applicable law.

In practice, we delete or anonymise your information upon deletion of your account (following the safety retention window), unless:

we must keep it to comply with applicable law (for instance, some "traffic data" is kept for one year to comply with statutory data retention obligations);

we must keep it to evidence our compliance with applicable law (for instance, records of consents to our Terms, Privacy Policy and other similar consents are kept for five years);

there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or

the information must be kept for our legitimate business interests, such as fraud prevention and enhancing users' safety and security. For example, information may need to be kept to prevent a user who was banned for unsafe behavior or security incidents from opening a new account.

Where SANA uses machine learning, for example, to help us detect and prevent fraudulent card transactions, and to detect and prevent spam communications on the App (as explained above), we may need to keep personal information for a longer period than the retention periods explained above, to enable the machine learning to work properly. Where this is the case, we always seek to minimize the amount of personal information that is used and we ensure that it is ring-fenced and kept securely from other user personal information. We regularly review the period for which personal information is required for machine learning purposes and delete any identifiable information when it is no longer required.


Device Information

We may collect information about your device when you use the App including the unique device identifier, device model, operating system, and MAC address. In addition, if you permit us to do so, the App may access your device's address book solely in order to add someone to your contacts.

Links

We may keep track of how you interact with links available on SANA including third party services and clients by redirecting clicks or through other means. We may share aggregate click statistics such as how many times a particular link was clicked on.

Data we collect automatically

When you use our services and features, we collect information on your activities on the Application:

Activity data (private) (registration date, last connection, interactions with Members and third-party accounts, number of transactions, etc.)

When you access our Services and use the Application and its features, information on the way you use them is collected and processed. SANA is obliged to collect such information when you use the Services. Without this data we cannot supply the Services linked to the SANA application.

More specifically, this includes your registration date, last connection, the type and number of interactions with other Members (such as messages, likes, mutual connections, crossings, and comments), with the third-party accounts connected to your Account (such as Facebook, Google, Apple, Instagram), or the number of transactions performed (purchasing Hellos or subscription(s)).

Cookies

What are cookies?

Cookies are small text files that are sent to or accessed from your web browser or your device's memory. A cookie typically contains the name of the domain (internet location) from which the cookie originated, the "lifetime" of the cookie (i.e., when it expires) and a randomly generated unique number or similar identifier. A cookie also may contain information about your device, such as user settings, browsing history and activities conducted while using our services.


We may use and share non-personal information (meaning information that, by itself, does not identify who you are such as device information, general demographics, general behavioral data, geolocation in de-identified form), as well as personal information in hashed, non-human readable form, under any of the above circumstances. We may also share this information with other partners and third parties (notably advertisers) to develop and deliver targeted advertising on our services and on websites or applications of third parties, and to analyze and report on advertising you see. We may combine this information with additional non-personal information or personal information in hashed, non-human readable form collected from other sources.

If for any reason you decide that you do not want all of your SANA activities to be stored you may set your browser and Lovele settings to block cookies and local storage devices, but please remember that if you do so, you may not be able to access all of the features SANA offers!


We use cookies for analytics and research.

We use Google Analytics and Facebook Pixel to collect information about how visitors use the site. The cookies collect information in an anonymous form, including the number of visitors to the App, where visitors have come from and the pages they visited. For more information about Google's Privacy Policy and Facebook Pixel, please visit http://www.google.com/intl/en/policies/ and https://developers.facebook.com/docs/facebook-pixel


If you would like to know more about cookies, including flash cookies/local storage devices, the following websites provide useful information:

www.allaboutcookies.org
www.youronlinechoices.eu

http://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html

2. USE OF INFORMATION.

Our main goal is to ensure your experience on SANA is an enjoyable one and you don't end up getting stung! In order to deliver an enjoyable experience to you, we may use your Registration and other information to:


offer you our services and features;

contact you with information about the App/Site (e.g., updates and new offerings);

personalize the App/Site and the content we deliver to you;

conduct research and analytics about how you use and interact with the App;

resolve disputes between you and other Users; and

investigate fraud, protect our legal rights, and to enforce our Terms & Conditions.


What about other tracking technologies, like web beacons?


Other technologies such as web beacons (also calls pixel tags or clear gifs), tracking URLs or software development kits (SDKs) are used for similar purposes. Web beacons are tiny graphics files that contain a unique identifier that enable us to recognise when someone has visited our service or opened an e-mail that we have sent them. Tracking URLs are custom generated links that help us understand where the traffic to our webpages comes from. SDKs are small pieces of code included in apps, which function like cookies and web beacons.

For simplicity, we also refer to these technologies as "cookies" in this document.


Aggregated Information – We may share aggregated information with third parties that includes your personal data (but which doesn't identify you directly) together with other information including log data for industry analysis and demographic profiling. You may opt-out of receiving marketing messages by using the opt-out mechanisms and links provided in each email.


We ensure these parties must adhere to strict data protection and confidentiality provisions that are consistent with this Policy. Measures are taken to ensure that the data shared is non-attributable to the greatest extent possible.


SANA does not sell your data and has not sold your personal data in the previous 12 months.


Exercising your rights over your Data

Your rights

In compliance with the GDPR, every Member has a right to access, rectify, and a right to data portability and removal of his/her personal data, along with a right to object to or limit processing of his/her personal data, and the right to decide on the way to handle the personal data after his/her death. In an effort to address its Members' concerns, SANA commits to respecting the protection of personal data and to process requests as soon as possible.


Exercising your rights

Members may exercise their rights, subject to proving their identity, by sending an email to support@SANA.Love



How We Use Information

The main reason we use your information is to deliver and improve our services. Additionally, we use your info to help keep you safe and to provide you with advertising that may be of interest to you. Read on for a more detailed explanation of the various reasons we use your information, together with practical examples.


To administer your account and provide our services to you

  • Create and manage your account

  • Provide you with customer support and respond to your requests

  • Complete your transactions

  • Communicate with you about our services, including order management and billing

To help you connect with other users

  • Analyze your profile, activity on the service, and preferences to recommend meaningful connections to you and recommend you to others; For more information on our profiling and automated decision-making, please see our FAQ

  • Show users' profiles to one another

To ensure a consistent experience across your devices

  • Link the various devices you use so that you can enjoy a consistent experience of our services on all of them. We do this by linking devices and browser data, such as when you log into your account on different devices or by using partial or full IP address, browser version and similar data about your devices to help identify and link them.

To provide new SANA services to you

  • Register you and display your profile on new SANA features and apps

  • Administer your account on these new features and apps

To serve you relevant offers and ads

  • Administer sweepstakes, contests, discounts or other offers

  • Develop, display and track content and advertising tailored to your interests on our services and other sites

  • Communicate with you by email, phone, social media or Lovele device about products or services that we think may interest you

To improve our services and develop new ones

  • Administer focus groups and surveys

  • Conduct research and analysis of users' behavior to improve our services and content (for instance, we may decide to change the look and feel or even substantially modify a given feature based on users' behavior)

  • Develop new features and services (for example, we may decide to build a new interests-based feature further to requests received from users).

To prevent, detect and fight fraud or other illegal or unauthorized activities

  • Address ongoing or alleged misbehavior on and off-platform

  • Perform data analysis to better understand and design countermeasures against these activities

  • Retain data related to fraudulent activities to prevent against recurrences

To ensure legal compliance

  • Comply with legal requirements

  • Assist law enforcement

  • Enforce or exercise our rights, for example our Terms

To process your information as described above, we rely on the following legal bases:


Provide our service to you: Most of the time, the reason we process your information is to perform the contract that you have with us. For instance, as you go about using our service to build meaningful connections, we use your information to maintain your account and your profile, to make it viewable to other users and recommend other users to you.

Legitimate interests: We may use your information where we have legitimate interests to do so. For instance, we analyze users' behavior on our services to continuously improve our offerings, we suggest offers we think might interest you, and we process information for administrative, fraud detection and other legal purposes.

Consent: From time to time, we may ask for your consent to use your information for certain specific reasons. You may withdraw your consent at any time by contacting us at the address provided at the end of this Privacy Policy.

How we share and disclosure information

Our policy is to not disclose your Registration Information without Your Consent, except in the limited circumstances described here:


Since our goal is to help you make meaningful connections, the main sharing of users 'information is, of course, with other users. We also share some users 'information with service providers and partners who assist us in operating the services and, in some cases, legal authorities.


For Moderators

To monitor activity on the apps and approve content. Name and user registration details, profile information, content of messages and photographs (CCPA Categories A, B, C, E, and H)


With other users

You share information with other users when you voluntarily disclose information on the service (including your public profile). Please be careful with your information and make sure that the content you share is stuff that you're comfortable being publically viewable since neither you nor we can control what others do with your information once you share it.

If you choose to limit the audience for all or part of your profile or for certain content or information about you, then it will be visible according to your settings.

With our service providers and partners

We use third parties to help us operate and improve our services. These third parties assist us with various tasks, including data hosting and maintenance, analytics, customer care, marketing, advertising and security operations.


We may also share information with partners who distribute and assist us in advertising our services. For instance, we may share limited information on you in hashed, non-human readable form to advertising partners.


We follow a strict vetting process prior to engaging any service provider or working with any partner. All of our service providers and partners must agree to strict confidentiality obligations.


We may also share information with othercompanies for legitimate business purposes such as corporate audit, analysis and consolidated reporting as well as compliance with applicable laws. We may also share user information with other companies to remove users who violate our terms of service, or have been reported for criminal activity and / or bad behavior. In some instances, we may remove that user from all platforms.


For corporate transactions

We may transfer your information if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control.


When required by law

We may disclose your information if reasonably necessary: (i) to comply with a legal process, such as a court order, subpoena or search warrant, government / law enforcement investigation or other legal requirements; (ii) to assist in the prevention or detection of crime (subject in each case to applicable law); or (iii) to protect the safety of any person.


To enforce legal rights

We may also share information: (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary to protect our legal rights and legal rights of our users, business partners or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.


With your consent or at your request

We may ask for your consent to share your information with third parties. In any such case, we will make it clear why we want to share the information.

We may use and share non-personal information (meaning information that, by itself, does not identify who you are such as device information, general demographics, general behavioral data, geolocation in de-identified form), as well as personal information in hashed , non-human readable form, under any of the above circumstances. We may also share this information with other Match Group companies and third parties (notably advertisers) to develop and deliver targeted advertising on our services and on websites or applications of third parties, and to analyze and report on advertising you see. We may combine this information with additional non-personal information or personal information in hashed, non-


How long we retain Your information

We keep your personal information only as long as we need it for legitimate business purposes and as permitted by applicable law. To protect the safety and security of our users on and off our services, we implement a safety retention window of three months following account deletion. During this period, account information will be retained although the account will of course not be visible on the services anymore.


In practice, we delete or anonymize your information upon deletion of your account (following the safety retention window) or after two years of continuous inactivity, unless:

we must keep it to comply with applicable law (for instance, some "traffic data" is kept for one year to comply with statutory data retention obligations);

we must keep it to evidence our compliance with applicable law (for instance, records of consents to our Terms, Privacy Policy and other similar consents are kept for five years);

there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or

the information must be kept for our legitimate business interests, such as fraud prevention and enhancing users' safety and security. For example, information may need to be kept to prevent a user who was banned for unsafe behavior or security incidents from opening a new account.

Keep in mind that even though our systems are designed to carry out data deletion processes according to the above guidelines, we cannot promise that all data will be deleted within a specific timeframe due to technical constraints.


For UK and EU residents


Under UK and EU law, UK and EU users have the right to lodge a complaint with data protection regulators, and the Information Commissioners' Office (ICO) is the UK's lead regulator. You can find out how to raise a concern with the ICO by visiting their website at www.ico.org.uk. If you're within the EU, you may also get in touch with your local Data Protection Regulator who may liaise with the ICO on your behalf.

You have a number of rights under European Data Protection law if you are an EU citizen.

Right to be informed: what personal data an organisation is processing and why (this notice).

Right of access: you can request a copy of your data.

Right of rectification: if the data held is inaccurate, you have the right to have it corrected.

Right to erasure: you have the right to have your data deleted in certain circumstances.

Right to restrict processing: in limited circumstances, you have the right to request that processing is stopped but the data retained.

Right to data portability: you can request a copy of your data in a machine-readable form that can be transferred to another provider.

Right to object: in certain circumstances (including where data is processed on the basis of legitimate interests or for the purposes of marketing) you may object to that processing.

Rights related to automated decision making including profiling: there are several rights in this area where processing carried out on a solely automated basis results in a decision which has legal or significant effects for the individual. In these circumstances your rights include the right to ensure that there is human intervention in the decision-making process.

If you want to exercise any of your rights listed above please visit our Feedback Page or email us at privacy@SANA.Love


Changes to this Policy.

As SANA evolves, we may revise this Privacy Policy from time to time. We will notify you before any material changes take effect so that you have time to review the changes.The most current version of the policy will govern our use of your information and will always be at SANA.Love/privacy/.

If we make a change to this policy that, in our sole discretion, is material, we will notify you, for example, via an email to the email associated with your Account or by posting a notice within SANA. By continuing to access or use the App after those changes become effective, you agree to be bound by the revised Privacy Policy.


How to contact us

If you have questions about this Privacy Policy, here's how you can reach us by e-mail policy@SANA.love


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Afterword...


We created this application to make people's lives better.

If we did not take into account something in our work, then let us know via email.

If you think that using this application may somehow harm you, then delete your account and app immediately. You'r sensitive data will be deleted in 30 days.

By continuing to use the application you agree to all the rules described above.

We reserve the right to block and delete any account if its actions harm other users and our application.

We are also entitled to unilaterally change any technical aspects of our application to ensure the comfort of our users.

SANA is a global application.

First of all, we proceed from the security considerations of the community and each user. We are guided in our activities by international laws and best practices in the field of IT. There may be times when some content or technical solution will not comply with the laws of all countries of the world at the same time. Under any disputed conditions, we are guided by the laws of the Republic of Belarus.


16 march / 2023

For all questions, contact us in any convenient way:
E-mail: ak@sana.love
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