AARP Dating Privacy Policy

Last Updated: October 24, 2013

dating.aarp.org and its affiliated websites, including but not limited to its Couples website and its dating blogs (the "Site"), operated solely by HowAboutWe, LLC ("we" or "us"), respects the privacy of our users and has developed this privacy policy (the "Privacy Policy") to articulate our commitment to protecting your privacy. AARP ("Partner") does not operate dating.aarp.org, the Site or the Services (as defined below) and takes no responsibility for same, including but not limited to their content and operation. However, as described herein, some information you share with Partner may be shared with us, and some information you share with us may be shared with Partner.

The Privacy Policy is intended to describe for you, as an individual who is a user of the Site or of the services offered on the Site (collectively with the Site, the "Services"), 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 the Services. By accessing the Services, you acknowledge and agree that you have read, fully accept, and will abide by this Privacy Policy.

Information we collect about you

In general, we don't collect personally identifiable information about you. We may collect personal information that can identify you in combination with other information, such as your name and e-mail address, and generally collect other information that does not identify you, like interesting places you've visited.

Information you provide. We may collect and store any information that you enter on the Site or provide to us in some other manner, such as through using some of our Services.

Private personally identifiable information. While we don't, at this time, ask for very many items that alone would be considered personally identifiable information, the information we collect may include items like your name, address, e-mail address and telephone number.

Public preference information and content. When you create an account and join the Site (becoming a "Member") you create a profile containing non-identifiable information, such as your "first date no-nos" and descriptive information about you including, for example, your height. You can also upload photographs of yourself to your profile. The Services also allow you to propose dates and share other information publicly. To the extent you provide any information in those sections of the Services, that information is entirely public, could be indexed by Internet search engines and may be used by us for any purpose. As such, you should exercise caution when revealing information in public aspects of the Services.

Financial information. We do not currently collect financial information, such as your payment method (valid credit card number, type, expiration date or other financial information); that information is collected and stored by our third party payment processing company (the "Payment Processor"), and use and storage of that information is governed by the Payment Processor's applicable terms of service and privacy policy.

Demographic and usage information. We may collect and store demographic information, such as your gender, age, information about your interests and activities and information related to your use of the Services, such as dates you have responded to and profiles you have viewed. This information is not personally identifiable by itself, but may become so in combination with other information.

Location information. To the extent you voluntarily opt to use any of our Services that that are based on the location of Members and which may report on those Members' current locations (the "Location-Based Services"), we may collect and store information about your location at the time you use those Location-Based Services. This information can come from a variety of sources depending on the client you use to access the Services; for example, a mobile phone may report its GPS location at the time the Location-Based Services are used.

Information from other sources. We may also periodically obtain both personal and non-personal information about you from business partners, contractors and other third parties, including third-party platforms (“Third Party Platforms”), and add it to our account information or other information we have collected (for example, we may collect information about you from our Payment Processor in order to continue your account subscription). Examples of information that we may receive include: updated address information, purchase history and additional demographic information.

Information about others. We may also collect and store personal information about other people that you provide to us, such as their name, address and e-mail address. If you use the Services to send others (friends, relatives, colleagues, etc.) a gift, we may store your personal information, and the personal information of each such recipient in order to process those requests or facilitate future activities.

Information collected using cookies and other technologies. We use various technologies to collect information from your computer and about your activities on the Services.

Information collected automatically. We automatically collect information from your browser when you access the Services. This information includes your IP address, your browser type and language, access times, the content of any undeleted cookies that your browser previously accepted from us (see "Cookies" below), and the referring website address.

Cookies. When you access the Services, we may assign your computer one or more cookies, to facilitate access to the Services and to personalize your experience. Through the use of cookies, we also may automatically collect information about your activity related to the Services, such as the web pages you visit, the links you click, and the searches you conduct. Most browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies. If you choose to decline cookies, please note that you may not be able to sign in or use some of the interactive features offered by the Services.

Other Technologies. We may use standard Internet technology, such as web beacons and other similar technologies, to track your use of the Services. We also may include web beacons in advertisements or promotional or other e-mail messages or to determine whether messages have been opened and acted upon. The information we obtain in this manner enables us to customize the Services. It also may enable us to deliver targeted advertisements and to measure the overall effectiveness of our online advertising, content, programming or other activities.

Information collected by third parties

We may allow third parties, including but not limited to our authorized service providers, advertising companies, corporate partners, and ad networks, to display advertisements through the Services. These companies may use tracking technologies, such as cookies, to collect information about users who view or interact with their advertisements. This information may allow them to deliver targeted advertisements and gauge their effectiveness. Some of these third-party advertising companies may be advertising networks that are members of the Network Advertising Initiative, which offers a single location to opt out of ad targeting from member companies (http://www.networkadvertising.org). Additionally, please see http://www.youradchoices.com to further understand targeted advertising and your choices about it.

When you use or connect to the Site or download a Site mobile app by or through a Third Party Platform, such as Facebook or other social networking site, you allow us to access and/or collect certain information from your Third Party Platform profile/account (such as your Facebook account) or via any cookies placed on your device by such Third Party Platform as permitted by the terms of the agreement and your privacy settings with the Third Party Platform. We will share such information with the Third Party Platform for their use as permitted by the terms of the agreement and your privacy setting with the Third Party Platform.

We will share some of the information we collect from you upon install of the mobile app with vendors and other service providers who are engaged by or working with us in connection with the operation of the services we provide to you and/or for analytics purposes which may require the reproduction and display of such information in an aggregated and anonymized manner such that will not in any way identify you.

Where information we collect goes

When you provide us with personal information, that information may be sent to servers located in the United States and other countries around the world.

How we use the information we collect

Generally, we may use information that we collect about you to:

facilitate and enhance your use of the Services;

manage your account and provide you with customer support;

perform research and analysis about your use of, or interest in, the Site, Services, and content provided by us, or products, services and content offered by others;

communicate with you by e-mail, postal mail, telephone and/or mobile devices about products or services that may be of interest to you either from us or other third parties;

develop and display content and advertising tailored to your interests as reflected by your use of the Services;

verify your eligibility and deliver prizes in connection with contests and sweepstakes;

enforce our Terms of Use;

manage our business; and

perform functions as otherwise described to you at the time of collection.

Financial information. As stated above, we do not currently collect financial information, as that information is collected and stored by our Payment Processor. However, we may from time to time request and receive some of your financial information from our Payment Processor for the purposes of completing transactions you have initiated through the Services, enrolling you in discount, rebate, and other programs in which you elect to participate, protecting against or identify possible fraudulent transactions, and otherwise as needed to manage our business.

With whom we share your information

We want you to understand when and with whom we may share personal or other information we have collected about you or your activities while using our Services. Public information. Any information (i) you place in your Member profile, such as your username, any photographs you upload, and information under the "Basics" and "About Me" sections; (ii) about dates you propose; or (iii) otherwise posted by you to a public portion of the Services, is completely public and could be indexed by Internet search engines. As such, by providing us with that information, you acknowledge that you have no reasonable expectation of privacy in it and that it may be used for any purpose. As noted above, you should exercise due care in revealing information through these public portions of the Services.

Other personal information. We do not share your personal information with others except as indicated below or when we inform you and give you an opportunity to opt out of having your personal information shared. We may share personal information with:

Authorized agents and service providers: We may share your personal information, which may include your name and contact information (including e-mail address) with our authorized agents and service providers that perform certain services on our behalf. These services may include maintaining our servers, fulfilling subscription requests, providing customer service and marketing assistance, performing business and sales analysis, supporting the functionality of the Services, providing payment fulfillment and reconciliation services, and supporting rewards programs, surveys and other features. These agents and service providers may have access to personal information needed to perform their functions but are not permitted to share or use such information for any other purposes.

Business partners: When you make purchases or engage in promotions offered through the Services, we may share personal information with the businesses, such as Third Party Platforms, with which we partner to offer you those products, services, promotions, or rewards (collectively, “Affiliates”). When you engage in a particular offer or program, you authorize us to provide your e-mail address and other information to the associated Affiliate. We will provide you with the opportunity not to share information with these Affiliates

Other Situations: We also 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 law enforcement or other government agencies; 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 the Terms of Use or other agreements or policies.

Any third parties to whom we may disclose personal information may have their own privacy policies that describe how they use and disclose personal information. Those policies will govern use, handling and disclosure of your personal information once we have shared it with those third parties as described in this Privacy Policy. If you want to learn more about their privacy practices, we encourage you to visit the websites of those third parties. These entities or their servers may be located either inside or outside the United States.

Aggregated and non-personal information. We may share aggregated and non-personal information we collect under any of the above circumstances. We may also share it with third parties to develop and deliver targeted advertising through the Services and on websites of third parties. We may combine non-personal information we collect with additional non-personal information collected from other sources. We also may share aggregated information with third parties, including advisors, advertisers and investors, for the purpose of conducting general business analysis. For example, we may tell advertisers the number of visitors to the Site and the most popular features people have accessed. This information does not contain any personal information and may be used to develop website content and services that we hope you and other users will find of interest and to target content and advertising.

In the event of a merger, sale, or bankruptcy

In the event that we or any portion of the business represented by the Services, are acquired by or merged with a third party entity, we reserve the right, in any of these or similar circumstances, to transfer or assign any or all of the information we have collected as part of such merger, acquisition, sale, or other change of control.

In the event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors' rights generally, we may not be able to control how your personal information is treated, transferred, or used.

Third-party websites

Through the Services, you may be able to click on a link to access other websites that do not operate under this Privacy Policy. For example, if you click on a link to an external article, 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 policies of all third-party websites you visit by clicking on the "privacy" link typically located at the bottom of the webpage you are visiting.

How you can access your information

If you are a Member, you have the ability to review and update the information you have provided us by logging into your account and clicking on "Settings". You can also review and update information in your public profile by clicking on the "Profile" link. You also can review and update that information by contacting us at the e-mail address provided below in the "How to contact us" section of this Privacy Policy.

How you can remove your information

Closing your account. If you are a Member, you may choose to resign and close your account at any time by visiting the "Settings" page for your account. After you close your account, you will not be able to sign in to the Services or access any of the information you have provided us. Upon closing your account, your public profile information will no longer be accessible from the Services, but may still be cached by Internet search engines.

Retention of information. If you close your account, we may still retain certain information associated with your account for analytical purposes and recordkeeping integrity, as well as to prevent fraud, collect any fees owed, enforce our terms and conditions, take actions we deem necessary to protect the integrity of our web site or our users, or take other actions otherwise permitted by law. Further, because of the complexities of the technology involved, we cannot guarantee total or irrevocable deletion of your account information, and we cannot provide you with any specific timelines for deletion. In addition, if certain information has already been provided to third parties as described in this Privacy Policy, retention of that information will be subject to those third parties' policies.

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 some features of the Services. For example, such information may be required for you to: register as a Member; participate in things like proposing dates and responding to date proposals; participate in our Rewards Program and other contests or promotions we may offer from time to time; ask questions; send messages to Members; or initiate other transactions on through the Services.

If you are a Member, you can elect not to share any of your profile information publicly by visiting your Settings page and selecting to have your profile available only to users signed into the Services. This does not prevent us from sharing your information with third parties as specified above.

Further, to the extent we send commercial or promotional e-mails to Members, you will be able to opt-out of receiving those e-mails, either in your Settings or within the body of any such e-mail.

You may "opt out" of the collection of your information for third party analytics purposes by following the directions provided by our third party analytics vendor located at http://www.mobileapptracking.com/privacy-policy/ If you “opt out” with our third party analytics provider, that action is specific to the information we collect specifically for that provider, and does not limit our ability to collect information from you, under the terms of this privacy policy, for other vendors.

In addition, if we have already provided your information to a third party (such as a service provider) before you have changed your preferences or updated your information, you may have to change your preferences directly with that third party.

We may send you, as a Member, other types of transactional and relationship e-mail communications, such as service announcements, administrative notices, and surveys, without offering you the opportunity to opt-out of receiving them, as our ability to communicate with you in some instances is necessary for your use of the Services as a Member.

Please note that changing information in your account, or otherwise opting-out of receipt of certain e-mail communications, will only affect future activities or communications from us.

How we protect your personal information

We take appropriate security measures (including physical, electronic and procedural measures) to help safeguard your personal information from unauthorized access and disclosure. For example, only authorized employees and third parties who have agreed to be bound by confidentiality restrictions, such as consultants, may be permitted to access personal information, and they may do so only for permitted business functions. In addition, we use SSL encryption in the transmission of your sensitive personal information between your system and ours, and we use firewalls to help prevent unauthorized persons from gaining access to your personal information.

We want you to feel confident using the Services. However, no system can be completely secure. Therefore, although we take steps to secure your information, we do not promise, and you should not expect, that your personal information, searches, 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 e-mail. Please refer to the Federal Trade Commission's website at http://www.ftc.gov/bcp/menus/consumer/data.shtm for information about how to protect yourself against identity theft.

Children's privacy

Although the Services are meant for a general audience, we restrict their use to individuals age 18 and above. We do not knowingly seek or collect personal information from children under the age of 13.

Visiting the Site from outside the United States

This Privacy Policy is intended to cover collection of information from residents of the United States. If you are accessing the Services from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States where our servers are located and our central database is operated. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. Please be assured that we seek to take reasonable steps to ensure that your privacy is protected. By using the Services, you understand that your information may be transferred to our facilities and those third parties with whom we share it as described in this Privacy Policy.

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 Services.

Changes to this Privacy Policy

We will occasionally update this Privacy Policy to reflect changes in our practices and in the Services. When we post changes to this Privacy Policy, we will revise the "last updated" date at the top of this Privacy Policy. If we make any material changes in the way we collect, use, and/or share your personal information, we will notify you by sending an e-mail to the e-mail address you most recently provided us in your account, profile or registration (unless we do not have such an e-mail address), and/or by prominently posting notice of the changes through the Services. We recommend that you check the Services from time to time to inform yourself of any changes in this Privacy Policy or any of our other policies.

How to contact us

If you have any questions about this Privacy Policy or our information-handling practices, or if you would like to request information about our disclosure of personal information to third parties for their direct marketing purposes, please contact us by e-mail at theteam@howaboutwe.com or postal mail as follows:

Privacy Officer

HowAboutWe, LLC
555 W 18th St
New York, NY 10011

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