Privacy Policy (Canada)

Effective Date: February 25, 2017

ruby Corp. ("we" or "us") is firmly committed to your privacy. This Privacy Policy sets out our practices related to the collection, use and disclosure of information you provide us when you visit our websites, mobile websites and mobile applications (collectively, the "Platform") and use the services thereon (the "Services"). To help us meet our commitment to you, we have appointed a Privacy Officer to oversee our privacy practices and our compliance with this Privacy Policy. If you have any questions or concerns regarding our policies and practices related to your information, please see the “Contact Us / Complaints” section below.

By accessing the Platform or using any of our Services you accept this Privacy Policy and agree to the terms, conditions and notices contained or referenced herein. Your use of our Platform or Services, and any dispute over privacy, is subject to this Privacy Policy and our Terms of Service (https://www.ashleymadison.com/app/public/tandc.p).

Please note that, to the extent required by applicable law, we will obtain your express consent for the collection, use and disclosure of your Personal Information (as defined below).  

What types of information do we collect?

We collect the following types of information directly from you, from third parties or automatically through your use of our Services:

  1. personally identifiable information, which is information about an identifiable individual ("Personal Information"); and

  2. non-personally identifiable information, which is information that is unable to identify a specific individual (for example, anonymous information related to your use of the Services) ("Anonymous Data").

What information will you ask me for?

When you create a profile on our Platform you will be asked to provide basic information about you which we need to enable us to provide you the Services including contact information (e.g. your email address), demographic information (e.g. your city of residence, zip/postal code, age, gender and ethnicity), and personal characteristics (height, weight and body type). We may supplement this with information about your IP address, or your location, when you use the Services.

While creating your profile, you may choose how much Personal Information you share with us. You will be asked to create a username and offered the chance to upload a photograph and provide a personal description. You are encouraged to create a pseudonymous profile and are not required to include information in your profile that would allow you to be directly identified. Obviously do be careful if you want to remain anonymous, especially if you upload photographs or choose a username which could allow you to be easily identified.

When you make a purchase off our Platform you will be asked for certain Personal Information for billing purposes including your name, address and details of your chosen payment method.

With your permission, we will also collect your location information from your mobile device to help you identify other Platform members in your area. You may turn off this feature through the location settings on your mobile device. We also collect your general geographic location from your browser access to help you identify members in your area and to help us quickly and efficiently respond to inquiries and requests.

How will you use the information you collect?

We use the information we collect, including Personal Information, for the following purposes:

  • to provide you with the Services, including to provide you with access to a forum focused on open-minded and discreet relationships, where members can search for and connect with other like-minded individuals;

  • to allow users to find other users’ profiles based on preferences or user location;

  • to promote your profile to other users of the Services;

  • to maintain and improve our Platform including improving the content and functionality of our Platform or customize the layout of our pages for each individual member;

  • to tailor the content and information that we may send or display to you, to offer location customization, and personalized help and instructions, and to otherwise personalize your experiences while using the Platform;

  • to conduct surveys and market research in order to improve the Services;

  • to communicate with you in connection with the Services including, subject to our obligations regarding email communications in your respective jurisdiction, for the purposes of informing you of changes or additions to the Service, or of any our products and services we believe may be of interest to you;

  • to detect and combat fraud, and better understand how to protect your information;

  • to process your payments and to help resolve payment disputes;

  • to deliver targeted advertising and promotional offers to you from external companies that are of the highest relevance to your demographic profile;

  • to manage your account and provide you with customer support;

  • to protect our own rights and interests, such as to resolve any disputes, enforce our Terms of Use, or to respond to legal process;

  • to save your user account, registration and profile data and other information (so you do not have to re-enter it each time you visit or use the Services); and

  • to track your return visits to, and use of, the Services.    

If you’re a registered user of establishedmen.com, please note that your profile will also be available on, and visible to users of, arrangementfinders.com and datebrokecollegegirls.com.

If you’re a registered user of cougarlife.com, please note that your profile will also be available on, and visible to users of, datemrsrobinson.com.

We also use Anonymous Data. For example, we may collect and analyze aggregated, de-identified, statistical information to help improve operation of the Services and manage user activity across the Platform.

How will you disclose the information you collect?

We may disclose Personal Information in the following circumstances for any or more of the purposes described above:

  • Promotion of your Profile – We may disclose your nickname or username (not your actual name) and your photo to promote your profile to other users of the Services, who may be located in any country in the world where our Services are offered. By providing us your Personal Information and using the Services, you consent to the transfer of your Personal Information to countries outside of your jurisdiction of residence consistent with the terms of this Privacy Policy.

  • Other Platform Members/Users – Your username, profile information and any information that you post to the Platform, including, without limitation, reviews, comments, and text will be available to, and searchable by, other users of the Platform and Services.

  • Financial Information - In some circumstances we may require certain additional information, including but not limited to your credit card billing information. We use this financial information, including your name, address, and other information to bill you for use of our Service and products. By making a purchase, or engaging in any other kind of activity or transaction that uses financial information on the Platform, you consent to our providing of your financial information to our service providers and to such third parties as we determine necessary to support and process your activities and transactions, as well as to your credit card issuer for their purposes. These third parties may include the credit card companies, data processing companies and banking institutions used to process and support your transaction or activity.

  • Trusted Third-Parties - We may disclose your information to our service providers to perform certain functions on our behalf in connection with the provision of the Services.

  • Legal Request - We may disclose your information to respond to law enforcement requests; or where required by applicable laws, court orders, or government regulations; or to protect against misuse or unauthorized use of our Platform; or to protect the personal safety or property of our users or the public (among other things, this means that if you provide false information or attempt to pose as someone else, information about you may be disclosed as part of any investigation into your actions).

  • Sale or Merger - We may disclose your information in connection with the sale, assignment, bankruptcy proceeding or other transfer of the business or a portion of the business of our Platform, including a corporate merger, consolidation, restructuring, sale of assets or other corporate change of our direct or indirect parent companies that affects us. In connection with the due diligence review involving such a potential transaction, we also may share information (including Personal Information) with potential acquirers, merger partners or investors, and their agents (including professionals) where such individuals agree to use Personal Information under the same conditions as identified in this Privacy Policy.

  • Affiliate Entities - We may share our data, including your Personal Information, with our parent, subsidiary and other affiliated companies, including companies operating in different countries (each an "Affiliate") that are committed to serving your online needs and related services. Except where otherwise prohibited by applicable law, our Affiliates may use this data to communicate with you about their products and services. Our Affiliates will follow privacy practices no less protective of all users than our practices described in this document, to the extent allowed by applicable law. It is possible that we or one or more of our Affiliates, or any combination of such, could merge with or be acquired by another business entity.

We may disclose Anonymous Data in a number of circumstances including to third party advertisers.  

Cookies and Other Tracking

We use cookies, clear GIFs, third-party analytics and other tracking mechanisms to track your use of our Platform and the Services. Such tracking mechanisms may automatically collect information such as: your IP address, domain name, browser type and operating system; web pages you view; links you click; how you move through the Platform and the length of time you visit our Platform and use the Services; and the referring URL, or the webpage that led you to our Platform. We may combine this information with other Personal Information we collect from you.

Do-Not-Track.Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies or opting out of ad networks).

Cookies. Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. We might use cookies to uniquely identify you, in order to help us to process your transactions and requests, to track aggregate and statistical information about user activity, and to display advertising both on our Platform and on third-party sites. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. If you disable cookies some features of our Platform may not function. Further information may be found at www.allaboutcookies.org.

Clear GIFs. Clear GIFs (a.k.a. web beacons, web bugs or pixel tags) are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, though, clear GIFs are embedded invisibly on web pages, not stored on your hard drive. We might use clear GIFs to track the activities of our visitors and app users, help us manage content, and compile statistics about usage. We and our third party service providers also might use clear GIFs in HTML e-mails to our customers, to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our e-mails are forwarded. These can be blocked either by using a third party application such as Ghostery (https://www.ghostery.com), or, in the case of emails, by changing your settings to prevent images from being downloaded (where your email client supports this functionality).

Third-Party Analytics.  We also use automated devices and applications, such as Google Analytics (https://support.google.com/analytics/answer/6004245) (to opt out, go here (https://tools.google.com/dlpage/gaoptout) ), and AppsFlyer (to opt out, go here (https://www.appsflyer.com/privacy-policy/) to evaluate usage of our Platform and the Services we provide.  We use these tools to gather information about users to help us improve our services, performance and user experiences.  These analytics providers may use cookies and other technologies to perform their services, and may combine the information that they collect about you on our Platform with other information that they have collected.  This Privacy Policy does not cover such third parties’ use of the data: for further information please see the relevant party's privacy policy. For a list of additional Third Party analytics providers we may use, please go here (http://www.rubylife.com/analytics_providers).

Third-Party Ad Networks

We may use third parties such as network advertisers to serve advertisements on our Platform and on third-party websites or other media, and to evaluate the success of our advertising campaigns. This enables us and these third parties to target advertisements to you for products and services in which you might be interested. Third-party ad network providers, advertisers, sponsors and/or traffic measurement services may use cookies, JavaScript, web beacons (including clear GIFs), Flash LSOs and other tracking technologies to measure the effectiveness of their ads and to personalize advertising content to you. These third-party cookies and other technologies are governed by each third party’s specific privacy policy, not this one. We may provide these third-party advertisers with information about users (e.g., IP address and demographic information), but we do not disclose details such as your name or contact information. You may be able to avoid targeted ads by certain ad networks by blocking cookies (see your browser’s “Help” menu for information on how to do this); however, our Platform may not work if you block or disable cookies. For a list of networks advertisers we may use, please go here (http://www.rubylife.com/network_partners).

 

Third-Party Links

 

Our Platform and services may contain links to third-party websites. For example, when you leave our Platform, you may be directed to a third party website, which may collect your IP address and other Personal Information. We do not supply any Personal Information to these third parties. Any access to and use of such linked websites, and any Personal Information collected in connection therewith, is not governed by this Privacy Policy, but instead is governed by the privacy policies of those third party websites. We are not responsible for the information practices of such third party websites.

How long do you keep the Personal Information you collect?
 

We keep your Personal Information for as long as we need your Personal Information for the purposes for which it was collected or as otherwise permitted by applicable law after which we delete or anonymize your Personal Information rendering it unable to identify you.

Access and Updates

You have the opportunity to (i) opt-out of certain communications, (ii) modify/update Personal Information you have provided to us, and (iii) hide certain information visible to public users of the Platform at any time by going to the 'Manage Profile' or ‘Account Settings’ sections on your profile.

On reasonable notice, you may withdraw your consent to use your Personal Information at any time, subject to certain restrictions prescribed by applicable law.

Please be aware that it may take several hours for any custom changes you make to take effect on the public areas of the system. Please also note that changing or deleting your information through the 'Manage Profile' or ‘Account Settings' section of the system, or opting-out of email notifications from us, will only change or delete the data in our database for the purpose of future activities and communications.

Do you monitor online behavior?


Our users communicate with each other through on-site mail messaging and instant messaging. While we do not, as a rule, moderate or monitor users' private exchanges, we reserve the right to do so if we suspect users of being under the age of 18 or of using our service for the purpose of solicitation or any other violation of our Terms & Conditions or Privacy Policy. Submissions that appear on the public area of the Platform are moderated and, if necessary, we reserve the right to edit, delete, remove or not use any communication on a public area of the Platform.

Other Information Collectors


Except as otherwise expressly described in this Privacy Policy, this document only addresses the use and disclosure of the information we collect from you. To the extent that you disclose your information to other parties, whether they are on our Platform (including links to third party sites) or on other sites throughout the Internet, different rules may apply to their use or disclosure of the information you disclose to them. To the extent that we use third party advertisers or have third party e-commerce partners, they adhere to their own privacy policies. Since we do not control the privacy policies of any third parties, you should investigate their policies before you disclose your Personal Information to them.

Data Transfers outside Canada

Some of the recipients who we disclose your Personal Information to as contemplated in, and in accordance with, this Privacy Policy may be located in jurisdictions outside Canada. As a result, your Personal Information may be used, stored and/or accessed in countries outside of Canada, including without limitation the United States. However, all such Personal Information will be protected in accordance with this Privacy Policy. Please note that when your Personal Information is located outside of Canada it will be subject to the laws of the country in which it is situated and these jurisdictions may not have an equivalent level of data protection laws as those in your country.

Security

We take the protection of your Personal Information seriously. We protect Personal Information against loss and theft as well as unauthorized access, disclosure, copying, use, and modification using security safeguards, including physical, organization and technological measures, commensurate with the sensitivity of your Personal Information.  Employees who have access to your information are made aware of the importance of keeping it confidential.

Where we use service providers who might have access to your Personal Information, we require them to have privacy and security standards that are comparable to ours. We use contracts and other measures with our service providers to maintain the confidentiality and security of your Personal Information and to prevent it from being used for any other purpose.

Please be aware that no data security measures can guarantee 100% security. You should also take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.  

User Generated Content

You may post content on the Platform, including your comments, pictures, and any other information that you would like to be available to other users of our Services. We cannot prevent the content you post or share on our Platform or Services from being used in a manner that may violate this Privacy Policy, the law, or your personal privacy, or from being shared or disclosed by other users.

Changes to this Privacy Policy

This Privacy Policy is current as of the Effective Date set forth above. In the event we intend to materially change any of our practices set out in this Privacy Policy, including if we intend to use your Personal Information for any purpose not expressly contemplated herein, we will provide you a minimum of thirty (30) days prior written notice of such change and obtain your consent to the extent required under applicable law.

Contact Us / Complaints

You have the right to access Personal Information we hold about you and to have any concerns you may have over our policies and practices addressed. In addition, you have the right to obtain information regarding our policies and practices as they relate to the collection, use and disclosure of Personal Information, including those with respect to the transfer and storage of your information outside of Canada, and update your Personal Information. If you have any questions related to the foregoing or any of the terms or conditions of this Privacy Policy, or if you wish complain to us in writing about how we have handled your Personal Information, please feel free to contact us at [email protected]. All other inquiries should be sent using our Contact Us (https://www.ashleymadison.com/app/public/contactform.p) section.

We aim to resolve all complaints promptly.