Last Updated: 01 September 2020

1. Introduction

Sikhing, operated by Twyford Hill Limited, (“Sikhing,” “we,” and “us”) respects the privacy of its users (“you”) and has developed this Privacy Policy to demonstrate its commitment to protecting your privacy. This Privacy Policy describes the information we collect, how that information may be used, with whom it may be shared, and your choices about such uses and disclosures. We encourage you to read this Privacy Policy carefully when using our application or services or transacting business with us. By using our website, application or other online services (our “Service”), you are accepting the practices described in this Privacy Policy.

If you have any questions about our privacy practices, please refer to the end of this Privacy Policy for information on how to contact us. Please read this Privacy Policy in conjunction with our Terms of Service. If you do not agree with any of the provisions of this Privacy Policy, you should not use our Service.

2. Information we collect about you

In General. We may collect Personal Information, including Sensitive Data, and other information. “Personal Information” means individually identifiable information that would allow us to determine the actual identity of, and contact, a specific living person. Sensitive Data includes information, comments or content (e.g. photographs, video, profile, lifestyle) that you optionally provide that may reveal your ethnic origin, nationality, religion and/or sexual orientation.

By providing Sensitive Data to us, you consent to the collection, use and disclosure of Sensitive Data as permitted by applicable privacy laws. We may also collect your geolocation information with your consent. We may collect this information through a website, mobile application, or other online services. By using the Service, you are authorising us to gather, parse and retain data related to the provision of the Service. When you provide personal information through our Service, the information may be sent to servers located in the United Kingdom, United States and countries around the world where data protection laws may differ.

Information you provide. In order to register as a user with Sikhing, you will be asked to sign in using your email address.

You will also be asked to allow Sikhing to collect your location information from your device when you download or use the Service. In addition, we may collect and store any personal information you provide while using our Service or in some other manner. This may include identifying information, such as your name, address, email address and telephone number, and, if you transact business with us, financial information. You may also provide us photos, a personal description and information about your gender and preferences for recommendations, such as search distance, age range and gender. If you chat with other Sikhing users, you provide us the content of your chats, and if you contact us with a customer service or other inquiry, you provide us with the content of that communication.

3. Fair collection of personal data

  • Data related to your identity: The registration form must be completed in order to access the Services. You are required to provide some personal data when registering. When completing your profile you will share with us additional information for example, your marital status, height, qualifications, physical status, and other details about you. Some of the information you choose to provide us may be considered sensitive in certain jurisdictions, for example, your racial or ethnic origins and religious beliefs. By choosing to provide this information you consent to our processing of that information.
  • You may also provide us with a mobile phone number in order to receive text alerts as well as a step within our profile verification. In all cases, your e-mail address, and phone number shall not be visible on your public profile
  • Location Data (geolocation): The primary function and goal of our service is to enable users to find the people nearby, in order to facilitate virtual or real life meet ups. You will be asked for permission to collect and process your geolocation in order to allow us to identify other users who agreed to geolocation.
  • Transaction Data: We do not collect or process any bank data. The Apple App Store and Google Play Store have opted to refrain from sending certain data to mobile applications, which includes any banking and financial information. Such data is collected and processed solely by the above platforms, and The Company does not have the option of changing this payment method.
  • Mobile Data: When you use the Application, The Company collects server logs which may include information such as IP addresses, operating systems or application crashes.

Use of technologies to collect information. We use various technologies to collect information from your device and about your activities on our Service.

Information collected automatically. We automatically collect information from your browser or device when you visit our Service. This information could include your IP address, device ID and type, your browser type and language, the operating system used by your device, access times, your mobile device’s geographic location while our application is actively running, and the referring website address.

Cookies and use of cookie and similar data. When you visit our Service, we may assign your device one or more cookies or other technologies that facilitate personalisation to facilitate access to our Service and to personalise your experience. Through the use of a cookie, we also may automatically collect information about your activity on our Service, such as the pages you visit, the time and date of your visits and the links you click. If we advertise, we (or third parties) may use certain data collected on our Service to show you Sikhing advertisements on other sites or applications.

Pixel tags. We may embed pixel tags (also called web beacons or clear GIFs) on web pages, ads, and emails. These tiny, invisible graphics are used to access cookies and track user activities (such as how many times a page is viewed). We may use pixel tags to measure the popularity of our features and services. Ad companies also use pixel tags to measure the number of ads displayed and their performance (such as how many people clicked on an ad).

Information collected by third-parties for advertising purposes. We may allow service providers, advertising companies and ad networks, and other third parties to display advertisements on our Service and elsewhere. These companies may use tracking technologies, such as cookies or web beacons, to collect information about users who view or interact with their advertisements. We do not provide any non-masked or non-obscured personal information to third parties.

4. How we use the information we collect

In General. We may use the information that we collect about you to:

  • deliver and improve our products and services, and manage our business;
  • manage your account and provide you with customer support; perform research and analysis about your use of, or interest in, our or others’ products, services, or content;
  • communicate with you by email, telephone and/or mobile devices about products or services that may be of interest to you either from us or other third parties;
  • develop, display, and track content and advertising tailored to your interests on our Service and other sites, including providing our advertisements to you when you visit other sites;
  • website or mobile application analytics;
  • enforce or exercise any rights in our Terms of Use;
  • perform functions or services as otherwise described to you at the time of collection.

In all circumstances, we may perform these functions directly or use a third party vendor to perform these functions on our behalf who will be obligated to use your personal information only to perform services for us.

5. With whom we share your information

  • Other Users. When you register as a user of Sikhing, your Sikhing profile will be viewable by other users of the Service. Other users (and in the case of any sharing features available on Sikhing, the individuals or apps with whom a Sikhing user may choose to share you with) will be able to view information you have provided to us directly including any photos you upload, your first name, your age, approximate number of miles away, your personal description, your profile attributes, and information you have in common with the person viewing your profile. If you use voting buttons to say “yes” to a person, you will be able to chat with that person if they also use voting buttons to say “yes” to you, e.g., when you have a “match.” If you chat with your match, of course your match will see the content of your chat.
  • Service Providers 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, inform marketing strategy and payment processing.
  • Business Transfer We may transfer your information if we are involved, weather in whole or part, in a merger, sale, acquisition, divesture, restructuring, reorganisation, dissolution, bankruptcy or other change of ownership control

Other Situations We may disclose your information, including personal information:

  • In response to a subpoena or similar investigative demand, a court order, or a request for cooperation from a law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases, we may raise or waive any legal objection or right available to us.
  • When we believe disclosure is appropriate in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of our company, our users, our employees, or others; to comply with applicable law or cooperate with law enforcement; or to enforce our Terms of Use or other agreements or policies.

Aggregated and/or non-personal information. We may use and share non-personal information we collect. We may also share it with third parties to develop and deliver targeted advertising on our Service and on websites or applications of third parties, and to analyse and report on advertising you see.

6. Third Party Websites

There may be a number of places on our Service where you may click on a link to access other websites that do not operate under this Privacy Policy. For example, if you click on an advertisement on our Service, you may be taken to a website that we do not control. These third- party websites may independently solicit and collect information, including personal information, from you and, in some instances, provide us with information about your activities on those websites. We recommend that you consult the privacy statements of all third-party websites you visit by clicking on the “privacy” link typically located at the bottom of the webpage you are visiting.

7. How you can access and correct your information

If you have a Sikhing account, you have the ability to review and update your personal information within the Service by opening your account and going to your profile. Applicable privacy laws may allow you the right to access and/or request the correction of errors or omissions in your personal information that is in our custody or under our control. Please contact support to assist with your access request.

For your protection and the protection of all of our users, we may ask you to provide proof of identity before we can assist with these requests.

Keep in mind, we may reject requests for certain 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 security purposes, not all personal information is accessible and amendable

If 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, the other user will have to contact our Data Protection Officer to provide their written consent before the information is released.

8. Data deletion and retention

The moment your deletion request has been processed, your account, profile, and photos are taken offline and are not shown to other Sikhing members. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal requirements.

We may retain personal information for as long as necessary after you have closed your account to comply with any legal, accounting or reporting requirements, resolve disputes and enforce our Terms and Conditions.

In some circumstances we may anonymise your personal data so that it can no longer be associated with you, in which case we may use such information without further notice to you.

9. Your choices about collection and use of your information

You can choose not to provide us with certain information, but that may result in you being unable to use certain features of our Service because such information may be required in order for you to register as user or create your profile; purchase products or services; participate in a, promotion or survey; ask a question; or initiate other transactions. Our Service may also deliver notifications to your phone or mobile device. You can disable these notifications by going into “App Settings” on the app or by changing the settings on your mobile device. You can also control information collected by cookies. You can delete or decline cookies by changing your browser settings. Click “help” in the toolbar of most browsers for instructions.

10. How we protect your personal information

We take security measures to help safeguard your personal information from unauthorised access and disclosure. However, no system can be completely secure and any information disclosed online is vulnerable to interception and misuse by unauthorized parties. Therefore, although we take steps to secure your information, we do not promise, and you should not expect, that your personal information, chats, or other communications will always remain secure. Users should also take care with how they handle and disclose their personal information and should avoid sending personal information through insecure email. No information transmitted over the Internet can be guaranteed 100% secure, we cannot ensure or warrant the security of any information transmitted to us over the Internet and hence accept no liability for any unintentional disclosure. You agree that we may communicate with you electronically regarding security, privacy, and administrative issues, such as security breaches.

11. Information you provide about yourself while using our Service

We provide areas on our Service where you can post information about yourself and others and communicate with others. Such postings are governed by our Terms of Service. Also, whenever you voluntarily disclose personal information on publicly-viewable pages, that information will be publicly available and can be collected and used by others. We cannot control who reads your posting or what other users may do with the information you voluntarily post on your profile, so we encourage you to exercise discretion and caution with respect to your personal information. The Company cannot be held liable for data published on its platform and disclosed by a Member.

12. Children’s Privacy

Although our Service is a general audience Service, we restrict the use of our service to individuals age 18 and above. We do not knowingly collect, maintain, or use personal information from children under the age of 18. If you suspect that a user is under the age of 18, please notify us immediately through the Contact Us facility on the website.

13. International Transfers

If you are visiting from the European Union or other regions with laws governing data collection and use, please note that we may need to transfer your personal data, including sensitive data, to other countries which may be outside the European Union. The data protection laws in such countries may not be as comprehensive and provide the same level of protection for your personal data as those within the European Union. In these circumstances, we will take appropriate steps to ensure that your personal data is handled as described in this Privacy Policy. These steps will include appropriate contractual mechanisms. By providing your personal information, you consent to any transfer and processing in accordance with this Policy.

14. No Rights of Third Parties

This Privacy Policy does not create rights enforceable by third parties or require disclosure of any personal information relating to users of the website.

15. Changes to this Privacy Policy

We may amend this Privacy Policy at any time and where we make material changes to it we will provide notice on our website (please check whenever you visit the website). When we make changes, we’ll update the “Last Updated Date” at the top of the Privacy Policy and post it on our website. Your continued use of the Services following the posting of changes to this policy will mean you consent to and accept those changes. If you do not consent to such changes you can delete your account by following the instructions in the Service.

16. How to Contact Us

If you have any questions about this Privacy Policy, please use the Contact Us facility on the website.