Last updated date: Sep 16th, 2021

OUR COMMITMENT TO YOU

At HEHE Match, your privacy is a top priority. Your privacy is at the core of the way we design and build the services and products you know and love so that you can fully trust them and focus on building meaningful connections. 

We appreciate that you put your trust in us when you provide us with your information, and we do not take this lightly.

We do not compromise your privacy. On the contrary, we design all of our products and services with your privacy in mind. In addition, we involve experts from various fields, including legal, security, engineering, product design and others, to make sure that no decision is taken without respect for your privacy.

We strive to be transparent in the way we process your data. However, because we use many of the same online services you do, we know that insufficient information and overly complicated language are common issues in privacy policies. Therefore, we take the exact opposite approach: we have written our Privacy Policy and related documents in plain language. We want you to read our policies and understand our privacy practices!

We work hard to keep your information secure. We have teams dedicated to keeping your data safe and secure. In addition, we constantly update our security practices and invest in our security efforts to enhance the safety of your information.

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PRIVACY POLICY

Welcome to HEHE Match’s Privacy Policy. Thank you for taking the time to read it. Using our website, you acknowledge that you are 18 years of age or older and have read, understood, and agreed to be bound by this Privacy Policy.

We appreciate that you trust us with your information and we intend always to keep that trust. This starts with making sure you understand the information we collect, why we collect it, how it is used and your choices regarding your information. This Policy describes our privacy practices in plain language, keeping legal and technical jargon to a minimum.

This Privacy Policy was applied on June 26, 2016. EFFECTIVE DATE: June 26, 2016

1. The company responsible for your information is:

Privacy Officer

HEHE Match Inc.

18 King St E, Suite 1400

Toronto, ON, Canada, M5C 1C4

2. WHERE THIS PRIVACY POLICY APPLIES

This Privacy Policy applies to websites, apps, events and other services operated by HEHE Match. For simplicity, we refer to all of these as our “services” in this Privacy Policy. To make it extra clear, we’ve added links to this Privacy Policy on all applicable services.

Some services may require a unique privacy policy. If a particular service has its privacy policy, then that policy – not this Privacy Policy – applies.

3. INFORMATION WE COLLECT

We can’t help you develop meaningful connections without information about you, such as basic profile details and the types of people you’d like to meet. We also collect information generated as you use our services, for example, access logs and data from third parties, like when you access our services through a social media account. If you want additional info, we go into more detail below.

Information you give us.

You choose to give us certain information when using our services. This includes:

•         When you create an account, you provide us with at least your login credentials and some basic details necessary for the service to work, such as your gender and date of birth.
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•         When you complete your profile, you can share with us additional information, such as details on your personality, lifestyle, interests and other details about you, as well as content such as photos and videos. To add certain content, like pictures or videos, you may allow us to access your camera or photo album. Some of the information you choose to provide us may be considered “special” or “sensitive” in certain jurisdictions, for example, your racial or ethnic origins, sexual orientation and religious beliefs. By choosing to provide this information, you consent to our processing of that information.
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•         When you subscribe to a paid service or purchase directly from us (rather than through a platform such as iOS or Android), you provide us or our payment service provider with information, such as your debit or credit card number other financial information.
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•         When you participate in surveys or focus groups, you give us insights into our products and services, responses to our questions and testimonials.
•         When you choose to participate in our promotions, events or contests, we collect the information that you use to register or enter.
•         If you contact our customer care team, we collect the information you give us during the interaction. Sometimes, we monitor or record these interactions for training purposes and ensure high service quality.
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•         If you ask us to communicate with or otherwise process other people’s information (for example, if you ask us to send an email on your behalf to one of your friends), we collect the information about others you give us to complete your request.
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•         Of course, we also process your chats with other users and the content you publish as part of the operation of the services.

Information we receive from others.

In addition to the information you provide us directly, we receive information about you from others, including:

•         Other Users. Other users may provide information about you as they use our services. For instance, we may collect information about you from other users if they contact us about you.
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•         Social Media. You may be able to use your social media login (such as Facebook Login) to create and log into your HEHE Match account. This saves you from remembering yet another user name and password and allows you to share some information from your social media account with us.
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•         Other Partners. We may receive info about you from our partners, for instance, where HEHE Match ads are published on a partner’s websites and platforms (in which case they may pass along details on a campaign’s success).
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Information is collected when you use our services.

When you use our services, we collect information about which features you’ve used, how you’ve used them and the devices you use to access our services. See below for more details:

•         Usage Information. We collect information about your activity on our services, for instance, how you use them (e.g., date and time you logged in, features you’ve been using, searches, clicks and pages which have been shown to you, referring webpage address, advertising that you click on) and how you interact with other users (e.g., users you connect and interact with, time and date of your exchanges, number of messages you send and receive).
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•         Device information. We collect information from and about the device(s) you use to access our services, including:
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•         hardware and software information such as IP address, device ID and type, device-specific and apps settings and characteristics, app crashes, and advertising IDs (such as Google’s AAID and Apple’s IDFA, both of which are randomly generated numbers that you can reset by going into your devices’ settings), browser type, version and language, operating system, time zones, identifiers associated with cookies or other technologies that may uniquely identify your device or browser (e.g., IMEI/UDID and MAC address);
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•         information on your wireless and mobile network connection, like your service provider and signal strength;
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•         information on device sensors such as accelerometers, gyroscopes and compasses.
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•         Other information with your consent. If you permit us, we can collect your precise geolocation (latitude and longitude) through various means, depending on the service and device you’re using, including GPS, Bluetooth or Wi-Fi connections. The collection of your geolocation may occur in the background even when you aren’t using the services if the permission you gave us expressly permits such collection. If you decline permission for us to collect your geolocation, we will not collect it.
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Similarly, we may collect your photos and videos (for instance, if you want to publish a photo, video or streaming on the services).

4. COOKIES AND OTHER SIMILAR DATA COLLECTION TECHNOLOGIES

We use and may allow others to use cookies and similar technologies (e.g., web beacons, pixels) to recognize you and/or your device(s), such as authenticating you, remembering your preferences and settings, analyzing site traffic and trends, delivering and measuring the effectiveness of advertising campaigns, allowing you to use social features.

Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) have a “Do Not Track” (” DNT”) feature that tells a website that a user does not want to have their online activity tracked. If a website that responds to a DNT signal receives a DNT signal, the browser can block that website from collecting certain information about the browser’s user. However, not all browsers offer a DNT option, and DNT signals are not yet uniform. For this reason, many businesses, including HEHE Match, do not currently respond to DNT signals.

5. 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 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
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To help you connect with other users

•         Analyze your profile and that of other users to recommend meaningful connections
•         Show users’ profiles to one another
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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 complete IP address, browser version and similar data about your devices to help identify and link them.
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To serve you relevant offers and ads

•         Administer sweepstakes, contests, discounts or other offers
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•         Develop, display and track content and advertising tailored to your interests on our services and other sites
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•         Communicate with you by email, phone, social media or mobile device about products or services that we think may interest you

To improve our services and develop new ones

•         Administer focus groups and surveys
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•         Conduct research and analysis of users’ behaviour 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’ behaviour)
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•         Develop new features and services (for example, we may decide to build a new interests-based feature further to requests received from users).
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To prevent, detect and fight fraud or other illegal or unauthorized activities

•         Address ongoing or alleged misbehaviour on and off-platform
•         Perform data analysis to better understand and design countermeasures against these activities
•         Retain data related to fraudulent activities to prevent recurrences
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To ensure legal compliance

•         Comply with legal requirements
•         Assist law enforcement
•         Enforce or exercise our rights, for example, our Terms
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We  process your information as described above, relying on the following legal bases:

•         Provide our service to you: Most of the time, we process your information to perform the contract 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 users, and recommend other users to you.
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•         Legitimate interests: We may use your information where we have legitimate interests to do so. For instance, we analyze users’ behaviour on our services to continuously improve our offerings, and we suggest offers we think might interest you. We process information for administrative, fraud detection and other legal purposes.
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•         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.
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6. HOW WE SHARE YOUR PROFILE AND YOUR INFORMATION

Since our goal is to help you make meaningful connections, and maximize your benefits, the main sharing of users’ information and profile is done for the purpose of making other users aware of your desire to be matched, with other users. We do this by sharing your uploaded content and profile with other users. Therefore, i) By submitting your pictures, bio and any other content to us, you authorize us to make whatever you submit to us available to other users of HEHE Match ii) In addition, if you have chosen to have your profile featured on the Featured Profiles section of our site, you authorize us to make whatever you submit to us, including your pictures and bio, viewable by the general public at our discretion for the period of time which you have requested and usually have to pay for. iii) You also authorize HEHE Match to promote your profile on our social media accounts (including but not limited to Facebook, Instagram, Linkedin, YouTube, Pinterest, WeChat, Podcast, and TikTok) for purpose of helping you find your ideal match by making meaningful connections, and maximize your member’s benefit for the period of time which you have requested and usually have to pay for. 

 We also share some users’ information with service providers and partners who assist us in operating the services, in some cases, legal authorities. Read on for more details about how your information is shared with others.

•         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 publicly viewable since neither you nor we can control what others do with your information once you share it.
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If you choose to limit the audience for all or part of your profile or certain content or information about you, 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, payment processing 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 anonymized information on you in hashed, non-human readable form to advertising partners.

We follow a strict vetting process before engaging any service provider or working with any partner. In addition, all of our service providers and partners must agree to strict confidentiality obligations.

We may also share information with other partners and service providers for legitimate business purposes such as corporate audit, analysis and consolidated reporting, and compliance with applicable laws. We may also share user information with other service providers and partners to remove users who violate our terms of service or reported criminal activity and bad behaviour. 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.
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•         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.
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•         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 the 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.
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•         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.
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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 behavioural 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 matchmaking companies and third parties (notably advertisers) to develop and deliver targeted advertising on our services and websites or applications of third parties and 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.

7. RIGHTS YOU GRANT US

You own all the content you provide us when creating an account on our site. However, you grant us the right to use your content (including any photos) you put on the site as agreed in these terms. Also, we may take photos or videos of you during the events that you register for. You also grant us the right to use those photos and videos with your images in them. You also grant us the right to post your images on our media social account(s). When you create an account or use our services, you grant us the following rights to your content:

• Hosting
• Storing
• Using
• Copying
• Displaying
• Reproducing
• Adapting
• Editing
• Publishing
• Translating
• Modifying
• Distributing

8. CROSS-BORDER DATA TRANSFERS

Sharing of information laid out in Section 6 sometimes involves cross-border data transfers to the United States of America and other jurisdictions. For example, where the service allows users in the European Economic Area (“EEA”), their personal information is transferred to countries outside of the EEA. We use standard contract clauses approved by the European Commission or other suitable safeguards to permit data transfers from the EEA to other countries. Standard contractual clauses are commitments between companies transferring personal data, binding them to protect the privacy and security of your data.

9. YOUR RIGHTS
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We want you to be in control of your information, so we have provided you with the following tools:

•         Access / Update tools in the service. Tools and account settings help you access, rectify, and delete the information you provided to us and associated with your account directly within the service. If you have any questions about those tools and settings, please contact us.
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•         Device permissions. Mobile platforms have permission systems for specific types of device data and notifications, such as phone book and location services and push notifications. You can change your settings on your device to either consent to or oppose the collection of the corresponding information or the display of the corresponding notifications. Of course, if you do that, certain services may lose full functionality.
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•         Deletion. You can delete your account by using the corresponding functionality directly on the service.

We want you to be aware of your privacy rights. Here are a few key points to remember:

•         Reviewing your information. Applicable privacy laws may give you the right to review the personal information we keep about you (depending on the jurisdiction, this may be called right of access, right of portability or variations of those terms). You can request a copy of your personal information by contacting us.
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•         Updating your information. If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion or object to its processing, please contact us.

For your protection and the protection of all of our users, we may ask you to provide proof of identity before answering the above requests.

Keep in mind that we may reject requests for specific reasons, including if the request is unlawful or if it may infringe on trade secrets or intellectual property or the privacy of another user. For example, suppose you wish to receive information relating to another user, such as a copy of any messages you received from him or her through our service. In that case, the other user will have to contact our Privacy Officer to provide their written consent before the information is released.

Also, we may not be able to accommodate specific requests to object to the processing of personal information, notably where such requests would not allow us to provide our service to you anymore. For instance, we cannot provide our service if we do not have your date of birth.

•         Uninstall. You can stop all information collection by an app by uninstalling it using the standard uninstall process for your device. If you uninstall the app from your mobile device, the unique identifier associated with your device will continue to be stored. However, if you reinstall the application on the same mobile device, we will re-associate this identifier from your previous transactions and activities.
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•         Accountability. In certain countries, including the European Union, you have a right to complain about the appropriate data protection authority if you have concerns about how we process your personal information. The data protection authority you can complain about may be that of your habitual residence, where you work or where we are established.
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If you want, 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 contacting us. 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 answering such a request.

10. HOW WE PROTECT YOUR INFORMATION

We work hard to protect you from unauthorized access to or alteration, disclosure or destruction of your personal information. However, as with all technology companies, although we take steps to secure your information, we do not promise, and you should not expect, that your personal information will always remain secure.

We regularly monitor our systems for possible vulnerabilities and attacks and regularly review our information collection, storage and processing practices to update our physical, technical and organizational security measures.

We may suspend your use of all or part of the services without notice if we suspect or detect any breach of security. If you believe that your account or information is no longer secure, please notify us immediately.

SSL SECURE technology is implemented to ensure that our systems and your information are protected against unauthorized access, theft, and loss. Your information is protected by 256-bit SSL encryption.

11. HOW LONG DO WE RETAIN YOUR INFORMATION

We keep your personal information only as long as we need it for legitimate business purposes (as laid out in Section 5 and permitted by applicable law. To protect the safety and security of our users on and off our services, we implement a one-year safety retention window 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:

1.   we must keep it to evidence of our compliance with applicable law (for instance, records of consents to our Terms, Privacy Policy and other similar consents are kept for five years);
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3.   there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or
4.   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 behaviour 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 time frame due to technical constraints.

12. CHILDREN’S PRIVACY

Our services are restricted to users who are 18 years of age or older. We do not permit users under the age of 18 on our platform, and we do not knowingly collect personal information from anyone under the age of 18. If you suspect that a user is under 18, please use the reporting mechanism available through the service.

13. PRIVACY POLICY CHANGES

This policy may change over time because we’re always looking for new and innovative ways to help you build meaningful connections. We may notify you before any material changes take effect. However, you understand that we are not obligated to do so. 

14. HOW TO CONTACT US

If you have questions about this Privacy Policy, here’s how you can reach us:

Online: E-mail us at hehematch@gmail.com or admin@HEHEMatch.com

By post:

Privacy Officer

HEHE Match Inc.

18 King St E, Suite 1400

Toronto, ON, Canada, M5C 1C4

Special Information For EU Users

Beginning May 25, 2018, the processing of users’ personal data in the European Union is subject to the EU General Data Protection Regulation (“GDPR”).

This section summarizes HEHE Match’s grounds for processing personal information under the GDPR and the rights of EU users as they relate to HEHE Match’s handling of personal information.

1. EU User Rights

If you are a HEHE Match user in the EU, you have the following rights regarding HEHE Match’s handling of your personal data:

1. a) Explanation and Copies of Your Information

You have the right to request an explanation of the information that HEHE Match has about you and how HEHE Match uses that information.

You also have the right to receive a copy of the information that HEHE Match collects about you based on consent or because HEHE Match requires the information to provide the services you request.

1. b) Correction

If HEHE Match has information about you that you believe is inaccurate, you have the right to request the correction of your data. Please see the section titled “Explanation, Copies, and Correction” above for more information on correcting or requesting correction of your data.

1. c) Objections and Complaints

Users in the EU have the right to object to HEHE Match’s processing of their personal data, including for marketing purposes. However, HEHE Match may continue to process your information, notwithstanding the objection to the extent permitted under GDPR.

Users in the EU also have the right to file a complaint relating to HEHE Match’s handling of their personal information by writing to HEHE Match at the following address:

HEHE Match Inc.

Att: Privacy Offer

18 King St E, Suite 1400

Toronto, ON, Canada, M5C 1C4

You may also submit questions, comments, or complaints to HEHE Match’s Data Protection Officer by emailing <office@HEHE Match.com>.

To exercise these rights, please submit your request by emailing <office@HEHE Match.com>. Users outside the EU may also request an explanation, correction, deletion, or copies of their personal data.

2. Processing Grounds 

The GDPR requires that companies processing the personal data of EU users do so based on specific legal grounds. Accordingly, as described below, HEHE Match processes the information of EU users based on one or more of the grounds specified under the GDPR:

1. a) The processing is necessary to provide the services and features you request.

HEHE Match must collect and use certain information to provide its services, including:

1. i) Transaction information necessary to generate and maintain in connection with your use of HEHE Match’s services.
2. ii) User profile information necessary to establish and maintain your account, including verifying your identity; to enable communications with you about your account/profile/event registration or subscription, orders, and accounts; and to enable you to make payments.
3. b) The processing is necessary to fulfill HEHE Match’s legal obligations.

HEHE Match is subject to legal requirements in the jurisdictions it operates that require us to collect, process, disclose and retain your personal data.

1. c) The processing is necessary for HEHE Match’s legitimate interests.

HEHE Match collects and uses personal information to the extent necessary for its legitimate interests, which includes collecting and using information:

1. i) To enforce HEHE Match’s Terms of Service. 
2. ii) To provide customer support;

iii)  To optimize our service and develop new services;

1. iv) for direct marketing purposes. (This includes, for example, analyzing data to identify trends and tailor marketing messages to user needs.)
2. The processing is necessary to protect the vital interests of our users or of others.

HEHE Match may process personal information, including disclosing data with law enforcement authorities in case of threats to the safety of users or of others.

1. Consent
2.  

HEHE Match may collect and use your information based on your consent. You may revoke your consent at any time. If you revoke your consent, you will no longer be able to use any service or feature that requires collecting or using the information we collected or used based on consent.

HEHE Match relies on consent in connection with data collection or uses necessary to enhance the user experience, enable optional services or features, or communicate with you. If you are an EU user, the following types of data collections or uses are done based on your consent.

Marketing emails

Newsletter emails

Promotion emails for events

HEHE Match may also collect personal information about you through voluntary surveys. Your responses to such surveys are collected based on consent and will be deleted once no longer necessary for the purposes collected.