Hello Iris Privacy Policy

Last updated: July 15, 2019

OUR COMMITMENT TO YOU

We built Hello Iris with an emphasis on protecting your privacy. Our goal is to give you as much control as possible over what information you share with us and with other people on the platform. 

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

We strive to be as transparent as possible with the way we collect, store, and use your data. We’ve also written this privacy policy so that you can actually read it and understand what happens to the data you share with us. 

PRIVACY POLICY

Welcome to Hello Iris’ Privacy Policy. Thank you for taking the time to read it.

We appreciate that you trust us with your information and we intend to always 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.

For reference - 

“Hello Iris” is the short name for our company, Hello Iris Technologies. 

“Iris” is the human-assisted AI service that works over SMS - what you interact with over text!

A “Match” is the person Iris suggests to someone else. 

A “Mutual Match” is when both people who match want to be introduced to each other.

A “Date” is an in-person meeting between two people who are a Mutual Match.

  1. WHO WE ARE

  2. WHERE THIS PRIVACY POLICY APPLIES

  3. INFORMATION WE COLLECT

    1. REQUESTING WAITLIST ACCESS

    2. DURING WAITLIST

    3. TO CREATE A HELLO IRIS ACCOUNT

    4. TO CREATE A HELLO IRIS PROFILE

    5. AFTER A MATCH OR DATE

    6. OTHER INFORMATION

  4. WHEN WE SHARE YOUR INFORMATION

    1. RECEIVING A MATCH

    2. MUTUAL MATCH

    3. OPTING OUT OF A MATCH

  5. WHO GETS THE FIRST MATCH

    1. HETEROSEXUAL MATCHES

    2. SAME-SEX MATCHES

    3. NON-BINARY MATCHES

  6. INFORMATION WE RECEIVE FROM OTHERS

  7. INFORMATION COLLECTED WHEN YOU USE OUR SERVICES

    1. USAGE INFORMATION

    2. DEVICE INFORMATION

  8. COOKIES AND OTHER SIMILAR DATA COLLECTION TECHNOLOGIES

  9. HOW WE USE INFORMATION

  10. WHO WE SHARE YOUR INFORMATION WITH

  11. CROSS-BORDER DATA TRANSFERS

  12. YOUR RIGHTS

  13. HOW WE PROTECT YOUR INFORMATION

  14. HOW LONG WE RETAIN YOUR INFORMATION

  15. CHILDREN’S PRIVACY

  16. PRIVACY POLICY CHANGES

  17. HOW TO CONTACT US

1. WHO WE ARE

The company responsible for your information is:

Hello Iris Technologies Ltd.

124 Spadina Rd. Unit 3

Toronto, ON, Canada

M5R 2T8

2. WHERE THIS PRIVACY POLICY APPLIES

This Privacy Policy applies to websites, apps, events and other services operated by Hello Iris. For simplicity, we refer to all of these as our “services” in this Privacy Policy. 

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

3. INFORMATION WE COLLECT

It goes without saying, we can’t help you develop meaningful connections without some 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: answering questions during the waitlist, giving feedback on matches, etc. If you want additional info, we go into more detail below.

3.1 REQUESTING WAITLIST ACCESS

When you request access to the Hello Iris waitlist, we ask you for the following information:

  • First name

  • Last name

  • Email

  • Age (optional)

  • Gender (optional)

We collect this information through Squarespace. You can view their Privacy Policy here.

Your information is then stored in a Google Sheet. You can view their Privacy Policy here. Access to this Sheet is restricted to only the Hello Iris leadership team. 

Your information is also stored in a Mailchimp list. You can view their Privacy Policy here.

3.2 DURING WAITLIST

While you’re on the waitlist, we send 4 questionnaires that help us better understand you, what you’re looking for, and who might be a good Match for you (“Matches” are the people Iris suggests to you!). All of the information we ask for is optional, but answering the questionnaires helps us make better Matches for you. Some of the information you choose to provide us may be considered “special” or “sensitive” in certain jurisdictions, for example your sexual orientation. By choosing to provide this information, you consent to our processing of that information. 

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.

Some of the information we ask for includes:

  • What neighbourhood in Toronto you live in (because we’re a location-based service, and so we can recommend cafes that are close to you and your Match)

  • Gender (so we can make accurate suggestions to other people based on their sexual orientation)

  • Preferred pronoun (so we can be respectful of how you identify, and give your matches the information to do the same!)

  • Who are you interested in dating? (so we know which people to match you with)

  • What type of relationship are you looking for? (so we can match people with similar relationship goals)

  • A link to a social media account (we use it to verify you’re a real person)

We use Google Forms to collect this information. You can view their Privacy Policy here

3.3 TO CREATE A HELLO IRIS ACCOUNT

When you successfully get through the waitlist, we’ll ask you to verify your ID, pick a monthly or annual subscription, and submit your credit card payment. 

We use Berbix (a San Francisco-based, Y Combinator-backed company) to verify your ID. You can find their Privacy Policy here.

We use Stripe to process your payment. You can find their Privacy Policy here.

3.4 TO CREATE A HELLO IRIS PROFILE

When Iris first messages you, she’ll ask for some personal information. Some of it is required to use our services, some is optional, and is used to improve the quality of matches Iris provides. See the list below for the information we ask for:

  • First name

  • Last name

  • Age

  • 1 close up photo

  • 1 full body photo

  • 1 short video to give your Matches an idea of your vibe and energy

  • Your preferred pronouns (optional)

3.5 AFTER A MATCH OR DATE

After every match and mutual Match that results in a date, Iris will ask you for feedback on the Match and/or date. That feedback will not be shared directly with your Match but is used to improve the quality of your future Matches. An anonymized summary of feedback from Matches may be shared with a person at our discretion where appropriate and constructive. 

3.6 OTHER INFORMATION

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

  • When you participate in surveys, focus groups or market studies, you give us your 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 to ensure a high quality of service.

  • Of course, we also process your chats with Iris, as part of the operation of the services.

4 WHEN WE SHARE YOUR INFORMATION

Iris will share certain information about you with the people she submits your profile to. You will see the same information about the Matches you receive. If it’s a mutual Match where both sides want to meet each other, Iris will share additional information. Read on below to see what information is shared when.

4.1 RECEIVING A MATCH

When you are sent as a Match, we share the following information about you with your Match:

  • Your first name

  • Your last name

  • Your age

  • Your close up photo

  • Your full body photo

  • Your short video

  • Your pronouns (if you chose to share them)

The same information will be shared with you about the people Iris sends you as a Match.

We also let you know whether you are the first one to see your Match or whether your Match has already opted in to you. 

4.2 MUTUAL MATCH

When both people opt in to a Match, Iris will share the following information with both of you:

  • The other person’s phone number

  • A café to meet at that is close to both your neighbourhoods

4.3 OPTING OUT OF A MUTUAL MATCH

After a Mutual Match has been made, Iris will let your Match know if you choose to ask for an introduction to someone else. If your Mutual Match asks for an introduction to someone else, Iris will also let you know. We know that things don’t always work out, but are working hard to minimize ghosting on our platform. 

5. HOW WE MAKE MATCHES

Iris will send a Match to one person first, and only if that person agrees to the Match will Iris share their info with the other party. This works slightly differently based on the genders and ages of the Matches you are receiving.

5.1 HETEROSEXUAL MATCHES

Women and female-identifying people: You get the first match! If you opt in, we’ll send your information over to the man. If you opt out, he won’t be notified and will not receive your information. If you both opt in, Iris will give you a cafe to meet at, then share your phone numbers with each other. It will be up to both of you to pick a date and time to meet. 

Men and male-identifying people: You will receive matches from women who have opted in to meeting you. If you also opt in, Iris will give you a cafe to meet at, then share your phone numbers with each other. It will be up to both of you to pick a date and time to meet.

5.2 SAME-SEX MATCHES

Matches for same-sex couples work the same way as for heterosexual couples, but are based on age rather than gender. Whoever is younger will get the first match. In other words:

The younger person: You get the first match! If you opt in, we’ll send your information over to the older person. If you opt out, they won’t be notified and will not receive your information. If you both opt in, Iris will give you a cafe to meet at, then share your phone numbers with each other. It will be up to both of you to pick a date and time to meet. 

The older person: You will receive matches from people who have opted in to meeting you. If you also opt in, Iris will give you a cafe to meet at, then share your phone numbers with each other. It will be up to both of you to pick a date and time to meet. 

5.3 NON-BINARY MATCHES

Regardless of your sexual orientation, non-binary and gender non-conforming people get the first match. If both people are non-binary or gender non-conforming, whoever is younger will get the first match (see the section on SAME SEX MATCHES above!). 

6. 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, or leave feedback about a Match or Date with you.

Other Partners: We may receive info about you from our partners, for instance where Hello Iris ads are published on a partner’s websites and platforms (in which case they may pass along details on a campaign’s success).

7. INFORMATION 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:

7.1 USAGE INFORMATION

We collect information about your activity on our services, for instance how you use them (e.g., features you’ve been using, searches or search parameters, clicks and pages which have been shown to you, referring webpage address, advertising that you click on) and how you interact with Iris (e.g., people you are interested in Matching with, time and date of your exchanges with Iris, number of messages you send and receive).

7.2 DEVICE INFORMATION

We collect information from and about the device(s) you use to access our services, including:

  • hardware and software information such as IP address, device ID and type, device-specific and apps settings and characteristics, app crashes, 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 device’ 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); and

  • information on your wireless and mobile network connection, like your service provider and signal strength.

8. 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). We use cookies for reasons like: authenticating you, remembering your preferences and settings, analyzing site traffic and trends, and delivering and measuring the effectiveness of advertising campaigns. To learn more about how you can better control their use through your browser settings and other tools, visit www.allaboutcookies.org

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 his or her 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. Not all browsers offer a DNT option and DNT signals are not yet uniform.  For this reason, many businesses, including Hello Iris, do not currently respond to DNT signals.

9. 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 to 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

  • Communicate with you about our services

To help you connect with other users

  • Analyze your profile, your feedback, and the way you text to recommend meaningful connections. 

  • Show users’ profiles to one another

To serve you relevant offers and ads

  • Administer sweepstakes, contests, discounts or other offers

  • Develop, display and track content and advertising tailored to your interests on our services and other sites

  • 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

  • Conduct research and analysis of users’ behavior 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’ behavior)

  • Develop new features and services 

To prevent, detect and fight fraud or other illegal or unauthorized activities

  • Address ongoing or alleged misbehavior on and off-platform

  • Perform data analysis to better understand and design countermeasures against these activities

  • Retain data related to fraudulent activities to prevent against recurrences

To ensure legal compliance

  • Comply with legal requirements

  • Assist law enforcement

  • Enforce or exercise our rights, for example our Terms of Service

To process your information as described above, we rely on the following legal bases:

  • Provide our service to you: Most of the time, the reason we process your information is to perform the contract that 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, to make it viewable to other users and recommend other users to you.

  • 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, we suggest offers we think might interest you, and we process information for administrative, fraud detection and other legal purposes.

  • 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 email address provided at the end of this Privacy Policy, or by telling Iris.

10. WHO WE SHARE YOUR INFORMATION WITH

Since our goal is to help you make meaningful connections, the main sharing of users’ information is, of course, with other people, as per your privacy settings. We also share some users’ information with service providers and partners who assist us in operating the services, with other Match Group companies and, in some cases, legal authorities. Read on for more details about how your information is shared with others.

With other people: 

We share your information with other people as per your privacy settings (and in the case of any sharing features available on Hinge, the individuals or apps with whom you may choose to share your information with) 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.

If you choose to limit certain content or information about you, then 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 information on you in hashed, non-human readable form to advertising partners.

We follow a strict vetting process prior to engaging any service provider or working with any partner. All of our service providers and partners must agree to strict confidentiality obligations.

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.

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.

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 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.

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.

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 behavioral 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 third parties (notably advertisers) to develop and deliver targeted advertising on our services and on websites or applications of third parties, and to 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. 

11. CROSS-BORDER DATA TRANSFERS

Sharing of information laid out in Section 6 sometimes involves cross-border data transfers, for instance to the United States of America and other jurisdictions. 

12. YOUR RIGHTS

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

  • Deletion. You can delete your account by emailing info@helloiris.io with the subject DELETE MY ACCOUNT or telling Iris you want to delete your account.

  • 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 emailing us at info@helloiris.io with the subject REVIEW MY INFO.

  • 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 email us at info@helloiris.io with the subject REVIEW MY INFO.

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

Also, we may not be able to accommodate certain 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.

  • Accountability. In certain countries, including in the European Union, you have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how we process your personal information. The data protection authority you can lodge a complaint with notably may be that of your habitual residence, where you work or where we are established.

13. HOW WE PROTECT YOUR INFORMATION

We work hard to protect you from unauthorized access to or alteration, disclosure or destruction of your personal information. 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 at info@helloiris.io with the subject SECURITY BREACH.

14. HOW LONG WE RETAIN YOUR INFORMATION
We keep your personal information only as long as we need it for legitimate business purposes as permitted by applicable law.

In practice, we delete or anonymize your information upon deletion of your account, unless:

  • we must keep it to comply with applicable law;

  • we must keep it to evidence our compliance with applicable law;

  • there is an outstanding or potential issue, claim or dispute requiring us to keep the relevant information until it is resolved; or

  • the information is 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 timeframe due to technical constraints.


15. 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 the age of 18, please email us at info@helloiris.io with the subject CHILDREN’S PRIVACY.


16. PRIVACY POLICY CHANGES
Because we’re always looking for new and innovative ways to help you build meaningful connections, this policy may change over time. We will notify you before any material changes take effect so that you have time to review the changes.


17. HOW TO CONTACT US
If you have questions about this Privacy Policy, email us at info@helloiris.io with the subject PRIVACY QUESTION.