Privacy Policy

Hello! Welcome to only-fwb's privacy policy.

We know reading a privacy policy might not be the highlight of your day, but please take a moment. We've put a lot of effort into making this policy as clear and engaging as possible, because we want you to actually read it! Think of us as your digital copilot, ready to guide you through the details of the data we collect and why and how we use it. So settle in, grab your favorite beverage, and let's explore the world of personal data together.

1. Who we are

The company responsible for your data (the “controller”) is:

Kooijman Incorporate Holding B.V.
Krijtlaan 2, 7764 AC Zandpol

2. Where this privacy policy applies

This Privacy Policy applies to the websites, apps, events, and other services we offer under the only-fwb brand. Whether you're looking for your soulmate, participating in one of our events, or using one of our other great services, this policy ensures you're well-protected. For simplicity, we'll refer to all of these services as our "services" in this Privacy Policy.

If any of our services for any reason require its own separate privacy policy, that policy will be made available to you, and that policy – ​​and not this Privacy Policy – ​​will govern.

3. What data we collect

Of course, we can only help you develop meaningful relationships if you provide some information about yourself, such as basic profile information and the types of people you'd like to meet. Using our service also generates certain data, such as when you're logged in and how you've used the service. We may also collect data from third parties, for example, when you access the service through an account you have on another platform (e.g., Google or Apple) or when you upload information from your account on another platform to complete your profile. For full details, please see the table below.

Data you provide to us
Categories	Description
Account details	When you create an account, you provide us with basic information to set up your account, such as your email address, date of birth, and password.
Profile data	When you complete your profile, you share additional information about yourself, such as your gender, interests, preferences, approximate location, and so on. Some of this information may be considered sensitive or special categories of data in certain countries, such as details about sexual orientation, health, or race or ethnicity. By choosing to provide this information, you agree to our use of it as set out in this privacy policy.
Contents	When you use our Service, you may post photos, videos, audio, text, and other types of content, such as your chats with other members.
Purchase details	When you make a purchase, we store details of the transaction (e.g., what you bought, the date of the transaction, and the price). The exact details depend on the payment method you choose. When you pay directly with us (rather than through a platform like iOS or Android), you provide your debit or credit card number or other financial information.
Marketing, survey and research data	We sometimes conduct (i) surveys, focus groups, or market research for research purposes, and (ii) organize promotions, events, or contests for marketing purposes. When you choose to participate, you provide us with information to process your submission and participation, as well as your responses to our questions and your comments.
Third party data	When you choose to provide us with information about other people (for example, if you use a friend's contact information for a particular role, or if you submit a question or report regarding a member), we process that information on your behalf to complete your request.
Customer service data	When you contact us, you provide us with information that may be necessary to respond to your inquiry. Other people may also submit questions or reports about you. Finally, our tools and moderation teams may collect additional data as part of their investigations. Where legally permitted, we may also receive information about suspected or convicted malicious actors from third parties as part of our efforts to ensure the safety and security of our members.
Social media data	You may choose to provide us with data through your accounts on other platforms (e.g. Google or Apple), for example if you choose to create and log in to your account through these platforms, or if you choose to upload data such as photos or friends lists from these platforms to our service.

Generated or automatically collected data
Categories	Description
Usage data	When you use the Service, we generate data about your activities, including how you interact with the Service (e.g., when you log in, what features you use, actions you take, information shown to you, referring web pages, ads you click), and how you interact with others (e.g., searching, matching, communicating). We may also receive data about your interactions with our ads on third-party websites or apps.
Technical data	When you use the Service, we collect data from and about the devices you use to access our Service. This includes device and software information such as your IP address, device ID, and device type; app settings and features; app crashes; advertising IDs; and identifiers associated with cookies or other technologies that uniquely identify a device or browser. For more information about cookies, please see our Cookie Policy.

Other data we collect with your consent
Categories	Description
Facial geometry data	You may choose to participate in certain features of ours, such as photo verification, which collects facial geometry data, which may be considered biometric data in some jurisdictions. Learn more about our verification tool and how we process your facial geometry data.
Identity data	You can provide us with a copy of your government-issued ID to help us verify that you are who you say you are.

4. Why and how we use your data

The main reason we process your data is to provide you with our service and improve it over time. This means connecting you with members who truly delight you, personalizing your experience, and generally helping you get the most out of our service. We also process your data to ensure that you and all our members remain secure while using our service. We take this responsibility very seriously and are always working to improve our systems and processes to protect you. And yes, we also process your data to show you relevant ads; you can manage this in your settings. Read on for more information.

Purposes for processing your data	Legal bases for processing your data	Categories of data processed (These are described in Chapter 3 of this policy)
To enable you to use our Service, including: creating and maintaining your account and profile on our service performing and maintaining the various functions of our service recommend other members to you and recommend you to them organizing raffles and competitions respond to your requests and questions monitoring the proper functioning of our service and resolving problems where necessary	performance of our contract with you your consent (when processing sensitive data or other types of data requiring consent)	account details profile data content purchase details marketing, survey and research data third-party data customer service data social media data usage data technical data
To facilitate your purchases through our Service, including: Process payments offer discounts and promotions, adjust prices	performance of our contract with you	account details profile data technical data purchase details usage data
To conduct advertising and marketing campaigns, including: conducting and measuring the effectiveness of advertising campaigns run on our service conducting and measuring the effectiveness of marketing campaigns that promote our own service on third-party platforms communicate with you about products and services that we think may interest you	Consent (where required by applicable law) and otherwise our legitimate interest. It is in our legitimate interest to promote our service and show our members ads tailored to their interests, as a way to improve their experience and help fund the parts of our service that are free.	account details profile data usage data marketing, survey and research data technical data
To improve our Service and create new features and services, including: working with focus groups, market research and surveys analyze how our service is used assess interactions with customer service teams to improve service quality Developing and improving new features and services, including through machine learning and other technologies, and testing them Conduct research and publish research papers	performance of our contract with you Our legitimate interest: It is in our legitimate interest to improve our service over time consent where required by applicable law (for example, we may process data that is considered sensitive or special purpose data in certain countries, to ensure fair and equitable treatment of the different communities that use our service and to ensure the diversity and inclusivity of our service)	account details profile data content purchase details marketing, survey and research data third-party data customer service data social media data usage data technical data
To ensure that you and other members remain secure on our service and within the Kooijman Inc Group, including: preventing, detecting and combating violations of our Terms, fraud and other illegal or unauthorized activities developing and improving tools to prevent, detect, and combat violations of our terms, fraud, and other illegal or unauthorized activities preventing recurrence, in particular by preventing people who violate our terms from creating a new account people who report let us know what we have done about it verify your identity securing payments and combating financial fraud	performance of our contract with you our legitimate interest: It is in our legitimate interests and those of our members to keep them safe protection of your vital interests and those of other members compliance with legal obligations we have, such as removing illegal content your consent (when processing sensitive data or other types of data requiring consent)	account details profile data content purchase details third-party data customer service data usage data technical data facial geometry data identity data
To ensure compliance with applicable law and to establish, exercise and defend legal claims and rights, including: retaining data to comply with applicable law and to demonstrate our compliance with it supporting investigations and defending potential or ongoing legal proceedings, regulatory actions or disputes responding to lawful requests from law enforcement agencies, courts, regulators and other third parties reporting illegal or infringing content to law enforcement, government agencies, or other authorities the institution, exercise or defense of pending or threatened legal claims disclosing data to law enforcement agencies or partners to combat abuse or illegal behavior	our legitimate interest: It is in our legitimate interest to comply with applicable law and to protect ourselves, our members and others, including as part of investigations, legal proceedings and other disputes protection of your vital interests and those of other members compliance with legal obligations we have, such as responding to requests for information from law enforcement agencies	The categories of data transferred vary depending on the specific circumstances surrounding each obligation, compelling interest or dispute.

5. How we share data

Because our goal is to help you make meaningful connections, some of your information will, of course, be visible to other members of the service. We also share information with service providers and partners who help us provide the services, with other Kooijman Inc Group companies for the reasons explained below, and, in some cases, for legal and related reasons. Read on for more information.

Recipients	Reasons to pass on	Categories of personal data
Other members	You disclose information to other users when you voluntarily disclose information on the Service for others to see (e.g., your public profile). If someone files a report involving you (for example, an allegation that you have violated our Terms of Use), we may notify the reporter of any action we have taken as a result of their report. The same applies if you file a report involving another member.	profile data content social media data third-party data customer service data
Service providers / partners	We share data with vendors and partners who help us operate, promote, and improve our service. They provide us with services such as data facilitation and maintenance, analytics, customer service, marketing, advertising, payment processing, legal support, and security operations.	Depending on the service provided by the supplier or partner, this may involve: account details profile data content purchase details marketing, survey and research data third-party data customer service data social media data usage data technical data facial geometry data identity data
Affiliated companies	We may transfer data to affiliated companies or receive data from them for the purposes set out in Section 6 of this policy.	The categories of data vary depending on the reason for disclosure, but may include: account details profile data content purchase details marketing, survey and research data third-party data customer service data social media data usage data technical data facial geometry data identity data
Law enforcement agencies	We may disclose your information to: (i) comply with legal process, such as a court order, subpoena or search warrant, government/law enforcement investigation, or other legal requirements; (ii) assist in the prevention or detection of crime; (iii) protect the safety of any person; and (iv) establish, exercise or defend legal claims.	The categories of data transferred vary depending on the specific circumstances surrounding the request, but can often include: account details profile data content purchase details third-party data customer service data social media data usage data technical data identity data

6. How the Kooijman Inc Group companies work together

only-fwb is part of the Kooijman Inc Group of companies

We may share information about you with our affiliated companies, and they may share information about you with us, for the reasons set out below:

• To make all Kooijman Inc Group platforms more secure, for example by ensuring that if a malicious actor is found on one Kooijman Inc Group platform (for example on our platform), that person can be banned from all platforms.
• To assist each other as service providers with data processing activities. This assistance may include processing activities such as data facilitation and maintenance, customer service, marketing and targeted advertising, analytics, finance and accounting, legal support, payment processing, service improvement, data security, and combating spam, abuse, fraud, and other violations.
• To improve your chances of building meaningful connections with others, we may make you visible on other Kooijman Inc Group services or allow you to benefit from features across all platforms. We will, of course, comply with applicable law and, where applicable, notify you of such an opportunity and give you the option to accept or decline.
• Where and to the extent permitted under applicable law, to better understand how people use the Kooijman Inc Group services generally, to personalize your experience within the Kooijman Inc Group services, and to improve marketing and advertising campaigns.
• For other legitimate business purposes, including corporate audit/consolidated audit, analysis and reporting.

7. Cross-border data transfers

Because we offer a global service, the transfer of your information as outlined in Section 6 involves international data transfers to the United States and other jurisdictions that may have different data processing laws. When we transfer personal data outside the EEA, the United Kingdom, Switzerland, or other countries whose data protection laws are deemed adequate by the European Commission or other competent authorities, we typically rely on what are known as standard contractual clauses. These standard contractual clauses are commitments between companies transferring personal data, obligating them to protect the privacy and security of your data. Please contact us for a copy.

8. Your rights

We want you to be in control of your data. Therefore, we want to remind you of the following options and tools available to you. Depending on where you live, you may not have these same rights, or they may be named differently. If you have any questions about your rights and how to exercise them, please contact us here.

Your rights	How to exercise this
Access, portability, or knowledge The right to be informed about what personal data we process about you and/or to request a copy.	You can access and view some of your data directly by logging into your account. You can also retrieve a copy of your data by following the process explained here.
Rectification or correction The right to change or update your personal data if it is inaccurate or incomplete.	You can update your information directly within the service by simply updating your profile. If you need to correct other information, please contact us here.
Deletion or Erasure The right to delete personal data	You can delete some of the information you've provided us directly within the service. You can also close your account as explained here, and we will then delete your information as outlined in this privacy policy. In any case, you can always contact us here.
Objection (opt-out) or restriction The right to object to our processing of your personal data or to request that we temporarily or permanently stop processing your personal data.	You can opt out of certain processing of your personal data directly through your account settings. Alternatively, you can contact us here if you wish to object to or restrict the data processing described in this privacy policy.
Withdrawal of consent The right to withdraw consent you have given us to process your personal data for a specific purpose.	You can withdraw the consent you've given us directly by updating your account settings or removing device permissions you've agreed to in your device settings (e.g., access to specific types of device data like phone contacts, photos, advertising identifiers, and location services, or permission to receive push notifications). When you withdraw your consent, some services may no longer work. You can always contact us here for more information.

Before we can respond to the above requests, we may, for your protection and that of all our members, ask for information to verify your identity or authority to act on a member's behalf. We wouldn't want anyone else to gain control of your data!

Please note that we may refuse requests for certain reasons, such as if we cannot verify your identity, if the request is unlawful or invalid, or if it may infringe on trade secrets, intellectual property, or another person's privacy. If you wish to receive information about another member, such as a copy of messages you've received from them, the other member must submit a request.

In certain countries, including the European Economic Area and the United Kingdom, you have the right to lodge a complaint with the competent data protection authority if you have concerns about how we process your personal data. You can find information about your data protection supervisory authority in the European Economic Area here and for the United Kingdom here. The data protection authority with whom you may lodge a complaint may be that of your habitual residence, your place of work, or the place where an alleged infringement occurred.

9. How long we keep your data

We want the connections you make through our Service to last forever, but we only retain your personal data for as long as necessary for legitimate business reasons (as set out in Section 4) and as permitted by applicable law.

If you decide to stop using our services, you can close your account, and your profile will no longer be visible to other members. Please note that we will automatically close your account if you have been inactive for two years.

After you close your account, we will delete your data as explained below:

1. For the safety and security of our members, we maintain a three-month retention period after account closure. During this period, we retain your data to investigate unlawful or harmful behavior. Retaining data during this retention period is based on our legitimate interests and those of potential external victims.
2. We retain limited data to comply with legal data retention obligations; specifically, we retain transaction information and imprecise purchase locations for 10 years to meet tax and accounting requirements, credit card information for the period during which the user can dispute the transaction, and "traffic data"/logs for one year to comply with legal data retention obligations. We also retain member consent records for five years to comply with and demonstrate our compliance with applicable laws.
3. We retain limited data based on our legitimate interest: we retain customer care records and supporting data for 6 years from the date of notification to support our security efforts, to support our customer care decisions, to enforce our rights and to enable us to defend ourselves in the event of a claim, profile data and imprecise download location for one year pending potential litigation, for the establishment, exercise or defense of legal claims, and data necessary to prevent members who have been banned from opening a new account for as long as necessary to protect the security and vital interests of our members.
4. c) Finally, we retain information based on our legitimate interest when there is an open or potential issue, claim or dispute that requires us to preserve information (in particular, if we receive a valid legal subpoena or request asking us to preserve data (in which case we must retain the data to comply with our legal obligations) or if data is otherwise necessary as part of legal proceedings.

Where and to the extent permitted by law, we may retain and use information that, on its own, cannot be specifically attributed to you for the purposes described in this Privacy Policy, including improving our services, creating new features, technologies and services, and keeping Kooijman Inc Group's services secure.

10. Children's Privacy

Our services are restricted to individuals 18 years of age or older. We do not permit individuals under 18 to use our platform. If you suspect a member is under 18, please use the reporting mechanism available through the service.

11. Changes to the Privacy Policy

This policy may change over time. We're always looking for new and innovative ways to help you build meaningful connections, and we strive to keep our information practices up-to-date. We'll notify you before significant changes take effect so you have time to review them.