Privacy Policy

Publication date: August 15, 2022

RusWife is committed to protecting your personal data. This privacy policy (“Privacy Policy”) covers how and why we collect information provided by using our services, including personal data and how we use it.

1. Who Are We:

   This privacy policy applies to WayToHey FZE, LLC. services, United Arab Emirates company residential in UAE; Our address is: A-62-01-04-06 - Flamingo Villas, Ajman (“RusWife” and also referred to as “our”, “us” and “we”). This Privacy Policy applies to websites, apps and other services we operate under the RusWife brand. For simplicity, we refer to all of these as our “services” in this Privacy Policy.

2. Information We Collect

   We can’t provide good service without your information, that will help us to identify or contact you, get you better user experience and meet new people. Information about your use of our services such as access logs, as well as information from third parties, like when you access our services through your different service accounts (e.g. Gmail and others) or when you upload information from a different service account to complete your profile. If you want any additional information, we go into more detail below.

   1. 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:

      • Name
      • Email address
      • Gender identity
      • Date of birth
      • Sexual preference
      • Photos
      • Location; and
      • Login information for third party accounts that you connect to your RusWife Account (this could include, for example, your Gmail account and others).

      You will also be required to create a password (using a third party account might not require setting up 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 just by logging in to RusWife. It is your responsibility to ensure that your account details are kept up to date. If your information changes, please ensure that you update this in your account.

   2. Profile Information

      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 which is open to abuse and misuse on your profile.

      When using the RusWife Services, you should assume that anything you post or submit may be public, both by Users and non-users of the services.

      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 RusWife may reveal information about yourself as well. Where you do upload and choose to tell us sensitive information about yourself, including through the addition of badges to your profile, you are explicitly consenting to our processing of this information and making it public to other Users.

   3. Profile Verification Information

      For safety and security and to ensure you have the best possible user experience, we require Users to verify their accounts in some instances, we might also ask that you carry out photo verification and e-mail confirmation. We also want to avoid fake RusWife accounts being created which can be used for malicious activities and cybercrime – they threaten the RusWife network and spoil things for everyone. This verification might be required by us for the prevention of fraud.

   4. Geolocation Information

      If you have given RusWife access to your location on your device or browser settings, when you use the service, we will collect information about location information including longitude and latitude information and may save your coordinates to offer certain features to you. This information helps us identify your physical location and we use it to personalize the services and make it easier for you to interact with other Users, by enabling the general locality information to be displayed to Users seeing your profile and showing you the profiles of other Users who are near you.

      If you have given RusWife access to your location, but wish to turn this off, this won’t affect availability of the provided services. You can do so by the following methods:

      • iPhone app — settings, privacy, location services, RusWife
      • Android — settings, location, RusWife, permissions, location
      • Browser — please check for suitable privacy settings within your browser.

   5. Device Information

      We may collect information about your device when you use the App or website including the unique device identifier, device model, operating system, and MAC address, for analytical purposes, as set out in this policy.

   6. Links

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

   7. Customer Support Information

      Your emails and other correspondence to and from us may be recorded for various purposes including monitoring customer service quality or compliance, checking the accuracy of the information you provide us, preventing fraud, or providing training for our staff or customer service representatives. Any information obtained from you through Customer support will be treated in accordance with the provisions of this Policy.

   8. Information We Collect Automatically

      Even if you do not provide information to us, we automatically collect certain information about your usage and interaction with our Site and/or Services. For example, when you visit our website, our systems automatically maintain web logs to record data about all visitors who use our website and store this information in our database. These weblogs may contain information about you including the following: IP address, type(s) of operating system you use, type of device you use, date and time you visited the website, your activity, and/or referring websites. We use your log information to troubleshoot problems, gather demographic information, customize your experience when accessing our Site, Services, and other business purposes.

   9. Information Collected From Other Sources

      We may receive information about you from outside sources, such as commercially available demographic or marketing information, and add or combine it with your information to provide better service to you and inform you of Services or other information that may be of interest to you. Our Site offers you the functionality of using your third party accounts (e.g. Google and others) to enter our Site, and in that manner, we may also collect certain information from you as you log on. We will not collect more information from you when using your social media credentials beyond the information such third parties disclose to us.

3. Cookies

   Different “cookies” and other related technologies to track your activities within our services. It might contain information how, when and how long you visited our service. You can always configure your browser to refuse cookies. For more information, please visit www.allaboutcookies.org.

4. How We Use Information

   Provided information is used to provide and improve our services and for security reasons.

   1. To provide our services. This might consider creation and management of your account. Reaching for customer support services. Make transactions within service.

   2. To recommend other users within the service that might interest you. Including representing your profile to other users.

   3. To provide new services to you. We develop different features and apps that might be of interest to you.

   4. Advertising and marketing. Service might provide different offers, discounts.

   5. To improve our services. Check on interactions with user support teams to improve our quality of service to improve our service and your user experience.

   6. Fraud prevention. To prevent, detect and fight fraud and other illegal or unauthorized activities that violate the Terms of Service and/or applicable laws. Enforce or exercise our rights, for example our Terms of Service.

   7. To ensure legal compliance. Comply with legal requirements. Assist law enforcement. For information on how we process personal information through profiling and automated decision-making, please see our FAQ.

   To process your information as described in this Privacy Policy, we rely on the following legal bases:

   Provide our service to you: The reason we process your information for purposes listed in 4.1., 4.2. and 4.3. above 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, make it viewable to other members and recommend other members to you and to otherwise provide our free and paid features to you and other members.

   Legitimate interests: We process your information for purposes 4.4., 4.5. and 4.6. above, based on our legitimate interest. For instance, we analyze users’ behavior on our services to continuously improve our offerings, we suggest offers we think might interest you and promote our own services, we process information to help keep our members safe and we process data where necessary to enforce our rights, assist law enforcement and enable us to defend ourselves in the event of a legal action.

   Comply with applicable laws and regulations: We process your information for purpose 4.7. above where it is necessary for us to comply with applicable laws and regulations and evidence our compliance with applicable laws and regulations. For example, we retain traffic data and data about transactions in line with our accounting, tax and other statutory data retention obligations and to be able to respond to valid access requests from law enforcement. We also keep data evidencing consents members give us and decisions they may have taken to opt-out of a given feature or processing.

   Consent: If you choose to provide us with information that may be considered “special” or “sensitive” in certain jurisdictions, such as your sexual orientation, you’re consenting to our processing of that information in accordance with this Privacy Policy. In some cases, you may withdraw your consent by adapting your settings (for instance in relation to the collection of our precise geolocation) or by deleting your content (for instance where you entered information in your profile that may be considered “special” or “sensitive”). In any case, you may withdraw your consent at any time by contacting us at the address provided at the end of this Privacy Policy.

5. How We Share Information

   In addition to the description of how we may disclose your personal data for each user type, we may also disclose personal data as follows:

   • Within the family of companies controlled by RusWife for internal reasons, primarily for business and operational purposes;
   • If we go through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of our assets, your personal data will likely be among the assets transferred;
   • When legally required to do so (e.g., to cooperate with law enforcement investigations or other legal proceedings); and/or
   • To respond to a genuine emergency.

   In addition, we combine your personal data with those of other users in order to share trend information and aggregate user statistics with third parties, always in aggregated and anonymized form.

6. Data Transfer

   When we transfer personal data from the European Economic Area (EEA) we will ensure such transfers are in compliance with relevant data protection laws, including, if applicable, EU Standard Contractual Clauses, or a European Commission positive adequacy decision under Article 25(6) of Directive 95/46/EC or Article 45 of the GDPR. In other words, your rights and protections remain with your data and we used approved contractual clauses and other measures designed to ensure that the recipients of your personal data protect it. RusWife has in place the Standard Contractual Clauses between RusWife entities to govern the transfer of data outside of the EEA.

7. Rights

   In compliance with certain privacy laws, in particular the European General Data Protection Regulation (GDPR), RusWife provides specific additional rights for individuals who interact with RusWife such as the right to access, rectification, right to object, to complaint, erasure and blockage. More specifically and under certain circumstances:

   • the right to request information about whether and which personal data is processed by us, and the right to demand that personal data is rectified or amended.
   • the right to request that personal data should be deleted.
   • the right to demand that the processing of personal data should be restricted.
   • withdraw your consent to the processing and use of your data completely or partially at any time with future application.
   • have the right to obtain your personal data in a common, structured and mechanically readable format.
   • contact our data protection officer if there are any questions, comments, complaints or requests in connection with our statement on data protection and the processing of your personal data.
   • the right to complain to the responsible supervisory authority if believed that the processing of your personal data is in violation of the legislation.

   In addition to the above, we reference certain rights for European Territory citizens throughout this Privacy Policy. Pursuant to the GDPR, citizens from “European Territories” mean the European Economic Area (EEA), the European Free Trade Area (EFTA) and Switzerland.

8. 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. If you decide to stop using our services, you can close your account and your profile will stop being visible to other members. After your account is closed, we will delete your personal information, as laid out below:

   To protect the safety and security of our members, we implement a safety retention window of three months following account closure, or one year following an account ban. During this period, we keep your information in the event that it might be necessary to investigate unlawful or harmful conducts. The retention of information during this safety retention window is based on our legitimate interest as well as that of potential third-party victims.

   Once the safety retention window elapses, we delete your data and only keep limited information for specified purposes, as laid out below:

   a) We maintain limited data to comply with legal data retention obligations: in particular, we keep transaction data for 10 years to comply with tax and accounting legal requirements, credit card information for the duration the user may challenge the transaction and “traffic data” / logs for one year to comply with legal data retention obligations. We also keep records of consents members give us for five years to evidence our compliance with applicable law.

   b) We maintain limited information on the basis of our legitimate interest: we keep customer care records and supporting data as well as imprecise location of download/purchase for five years to support our customer care decisions, enforce our rights and enable us to defend ourselves in the event of a claim, information on the existence of past accounts and subscriptions, which we delete three years after the closure of your last account to ensure proper and accurate financial forecasting and reporting, profile data for one year in anticipation of potential litigation, for the establishment, exercise or defense of legal claims, and data necessary to prevent members who were banned from opening a new account, for as long as necessary to ensure the safety and vital interests of our members.

   c) Finally, we maintain information on the basis of our legitimate interest where there is an outstanding or potential issue, claim or dispute requiring us to keep information (in particular if we receive a valid legal subpoena or request asking us to preserve data (in which case we would need to keep the data to comply with our legal obligations) or if data would otherwise be necessary as part of legal proceedings).

9. Privacy Policy Changes

   We may change this Privacy Policy from time to time. We will place a prominent notice that will be visible to you as a Site Visitor or Business Partner, but we do not have a means of advising Users of an update by way of notice. You should check back here periodically to see if the Privacy Policy has been updated as we will always show the date of the latest modification of the Privacy Policy at the top of the page so you can tell when it was last revised.