Data protection
Thank you for using the MyTrueCompanion website! Here you will find information concerning the personal data collected by MyTrueCompanion, the way we process these data and your options as a user. The organisation responsible for processing data is Parazzo AG (hereafter "MyTrueCompanion").
Contact
Our delegate in charge of protecting data and ourselves are available for any question or suggestion concerning data protection.
You can contact us at the following addresses:
Parazzo AG, Customer Service Dept, MyTrueCompanion UK, Marktgasse 5, 4051 Basel, Switzerland
Email : info@my-true-companion.com
Collecting, transmitting and using personal data
Private data are provided within the terms of the contract and the duration of the contractual relations with MyTrueCompanion on a voluntary basis. In this context, we are required in particular to communicate the specific categories of personal data. If you do not wish MyTrueCompanion to process your personal data, and especially the specific categories of data of a personal nature, MyTrueCompanion will not be able to provide you with its service. The information below provides a detailed overview of the data collected by MyTrueCompanion.
Which data does MyTrueCompanion collect from its members to fulfill the contract?
To provide the services described in detail in the General Terms and Conditions, it is necessary to collect, process and use personal data that the user (or "MyTrueCompanion" Member) provides, including in the compatibility questionnaire and when subscribing to one of the subscription plans.
Registration and subscription process for a Basic Subscription
When you complete the compatibility questionnaire, you will be asked for information about yourself and your partner.
- Your gender and the gender of your partner (the gender of your partner is an indication of sexual orientation)
- Email address
- Password
- As part of the registration process, other data may be provided, for example:
- Postcode
- Date of birth
- Users access MyTrueCompanion using the e-mail address and password they have chosen ("login data").
- As part of the personality test following registration, the following details, among others, are required:
- Postcode
- Date of birth
- Marital status
- Number of children
- Level of education
- Job
- Etc
Registration via Facebook ("Facebook Login")
You can sign up for MyTrueCompanion via your Facebook account. If you do so, Facebook provides us with the data needed to sign up. For this reason, a transfer of data takes place.
We have no influence on the amount of data collected by Facebook via Facebook Login. If you do not wish Facebook to collect information about yourself or to use data for its own purposes within the terms of reference of your use of our online service, you should not use Facebook Login.
You will find more information about the aims and quantity of data collected, data processing and later use of your data by Facebook, as well as your rights and the option to configure your devices to protect your data in the Facebook Data Policy pages: facebook.com/policy. in the Contact section.
Which data are collected by MyTrueCompanion for advertising purposes?
When you sign up, you enter your email address in the input mask. This email address will then be used to send non-encrypted email advertisements promoting free and paid products by the Web-Dragon Ltd company without having to obtain your agreement. At any time you can oppose the use of your email address for advertising purposes.
Which data are collected by MyTrueCompanion when using the MyTrueCompanion website?
On each visit to the MyTrueCompanion website, the user data of all visitors to the website - unless otherwise stated (see below), even if they are not members of MyTrueCompanion - are transmitted by the user's web browser and saved in server logfiles. These data include:
- Information about the user's type of web browser and their internet service provider, as well as their operating system (e.g. Windows 7, Apple OS, etc.)
- The Internet Protocol address of the computer, tablet or smartphone (the IP address is compared to a geographic database, identifying the user's country, state and town).
- The visitor's user name on the MyTrueCompanion platform (for MyTrueCompanion members only)
- The name of the page visited
- The date and time of the visit
- The HTTP Referer from which the user has accessed the page
- The amount of data transferred
- The status message showing whether the visit was made successfully
- Session ID
- The screen resolution used
- Each time a MyTrueCompanion member logs onto the network, the following connection data are memorised in the data connection log:
- Date and time of connection
- The visitor's user name on the MyTrueCompanion platform
- IP address (Internet Protocol Address)
- Session cookie number
- Session ID
- The session participant's user name
Processing purposes
MyTrueCompanion processes the personal data of its users for the following reasons:
- To provide the services described in the General Terms and Conditions. (Implementing the contractual relations agreed with you as a MyTrueCompanion member is the legal basis for collecting data. Please note that we also collect data relating to sexual orientation: "your gender and gender of your partner").
- In order to calculate the prices automatically. (The legal basis is to implement contractual relations.)
- To guarantee that your obligations resulting from contractual relations will be fulfilled in the event of default on payments. (As well as implementing contractual relations, the legitimate interest of MyTrueCompanion in the payment of the amounts agreed in the contract constitutes the legal basis.)
- To guarantee smooth working, optimisation and analysis of the website, as well as the security of the MyTrueCompanion I.T. systems. For this reason MyTrueCompanion uses technically required cookies and non-technically required cookies such as analytical cookies. (The legal basis is the legitimate interests of MyTrueCompanion and MyTrueCompanion members, so that the MyTrueCompanion service can be used easily and safely, and that the quality of our website and its contents are continually optimised.)
- To collect and assess information about user behaviour for purposes of advertising adapted to users' interests (Parazzo products only). To measure the success of these advertising campaigns (Conversion-Tracking), we also transmit tracking data to third parties (e.g. Google and Microsoft). More information in the Web Analysis section. (The legitimate interest of MyTrueCompanion and other advertisers to display advertisements adapted to users' interests and to provide them with advertising corresponding to their interests constitutes the legal basis)
- For the aims of integrating social plugins and features of social networking. (The legal basis is the legitimate interest of MyTrueCompanion to meet the needs of users who have activated a social plugin to share information with their respective social networks).
- For reasons of self-promotion through unencrypted advertising e-mails, text messages or WhatsApp advertisements in the form of advertising banners on other websites. (The legitimate interest of Parazzo AG in conducting direct marketing for its own products constitutes the legal basis.)
- To send out a range of newsletters (by unencrypted e-mail, text message and/or WhatsApp) providing more information about Parazzo AG products. (Implementing the contract, on the one hand, and the legitimate interests of MyTrueCompanion in direct marketing campaigns, on the other, constitutes the legal basis).
- For market studies and measuring audiences. (The legitimate interest of MyTrueCompanion to obtain an overview of the market value of the MyTrueCompanion website in direct comparison with websites of third parties constitutes the legal basis. The legitimate interest also results from economic use of the results of audience measurement. In this connection, user categories are also drawn up. User categories are a basis for helping us to adapt advertising media and/or advertising campaigns to customers' interests.
Processing purposes
- Providing we obtain the consent of the individual concerned to process personal data, article 6, paragraph 1, point (a) of the General Data Protection Regulation (GDPR) constitutes the legal basis.
- As part of processing the personal data required to carry out the MyTrueCompanion contract (Subscriptions), article 6, paragraph 1, point (b) of the GDPR constitutes the legal basis. This also applies to data processing required to carry out pre-contractual measures.
- To the extent that processing is required in order to preserve the legitimate interests of MyTrueCompanion or of a third party, for example, its members, unless the interests or freedoms and fundamental results of the individual concerned take precedence, article 6, paragraph 1, point (f) of the GDPR constitutes the legal basis for processing data.
- During processing of the personal data required for self-promotion (Subscriptions), article 6, paragraph 1, point (f) of the GDPR constitutes the legal basis.
Transfer of data to third parties; service providers
Your personal data will only be transmitted to third parties by MyTrueCompanion to the extent required to carry out the contract or if you have given your consent. To the extent that personal data are transmitted to third parties on the basis of a legitimate interest, this legitimate interest is stated in this privacy policy.
Personal data may also be transmitted by MyTrueCompanion to third parties whenever it is obligatory for legal reasons or following a decision issued by a legal or administrative authority.
Service providers
MyTrueCompanion reserves the right to work with service providers in collecting and/or processing personal data. In this case, MyTrueCompanion only transmits to service providers the personal data required to carry out their services.
MyTrueCompanion makes use of service providers, among others, to send out unencrypted e-mails and newsletters to its members. The service providers also put server capacity at the disposal of MyTrueCompanion. External payment services and debt-collection agencies help MyTrueCompanion in managing payments. Depending on the means of payment chosen during the purchasing process, MyTrueCompanion transmits data collected to process payments (for example, bank details or credit card information) to the financial establishment or the service provider collecting payments. Payment service providers also collect data under their own responsibility. In this case, the payment service provider's privacy policy is applied.
Service providers generally act as sub-contractors and are only authorised to process users' personal data linked to this online offer according to instructions provided by MyTrueCompanion.
Transfer of data towards countries not belonging to the EEA
We also transmit personal data to third parties, to sub-contractors, with headquarters located in countries outside the EEA. In this case, before transfer we guarantee that the recipient has an adequate level of data protection (for example, on the basis of a decision about suitability of use by the European Commission for the country concerned, self-certification of the recipient to the EU-US Privacy Shield or an agreement about the typical contractual clauses in use in the EU with the recipient) or whether the consent provided by our users is enough.
Storage duration; storage time limits
We keep your data as long as necessary to implement our online offer (Subscriptions) and associated services, or for as long as we have a legitimate interest in keeping them. In all other cases, we delete your personal data, excepting data that we need to keep to conform with any contractual retention period (e.g. for fiscal or commercial purposes) or for legal reasons (for example, invoices).
Please note that your data are first locked if deleting them would be an obstacle to respecting the retention period.
For individuals wishing to assert their rights, MyTrueCompanion keeps the data needed to carry out contracts or as proofs for the retention period.
Storage duration; storage time limits
You have a right of access and - under certain conditions - to rectify, delete, limit or oppose processing of personal data, as well as a right to transfer your data.
At any time, you can also oppose processing of your personal data for advertising reasons with future effect. Please bear in mind that for organisational reasons, there may be a time lapse between your request to oppose processing and the use of your data in an ongoing advertising campaign.
You have provided us with data about your sexual orientation (your gender and gender of your partner). You can withdraw this content at any time for future effect. The legitimacy of data processing until this withdrawal will not be affected. From the moment of withdrawal, advertising from partners cannot be submitted to you, and MyTrueCompanion can no longer provide you with its services.
To exercise your rights, please consult the instructions in the Contact section below. Please also make sure you can identify yourself clearly.
Otherwise, you can use the settings options in your profile to rectify the data you have provided when you signed up or to oppose advertising. You can also delete your data relating to your Basic MyTrueCompanion Subscription yourself. Only the MyTrueCompanion customer services department can delete the data provided for a Premium Subscription. Please note that your data are first locked if deleting them would be an obstacle to respecting the retention period.
Right to make a complaint to a control authority
You have the right to make a complaint to a data-protection authority. To do so, contact the data protection authority with jurisdiction over your place of residence, region or area, or the data protection authority with jurisdiction over MyTrueCompanion.
Cookies & online tracking
This online services uses cookies. Here you can find detailed information about the cookies used. Along with a description of the different cookies, this page also provides explanations about the reasons for their use and other important information.
Cookies are small text files sent to your web browser and memorised in the browser when you visit a website. When you visit the website again, the user's web browser resends the content of the received cookie to the server, thus enabling the user to be recognised. Some cookies are automatically deleted at the end of the browser session ("session cookies"), others are stored for a predetermined period or permanently in the user's web browser and are then automatically deleted (temporary or permanent cookies).
Cookies do not memorise any personal data, but only an online username.
What kinds of cookies are used by MyTrueCompanion?
Strictly necessary cookies
Some cookies are required for the security and user-friendliness of our online services. This is the case, for example, of
- cookies used to identify or authenticate our users;
- cookies temporarily saving certain user data;
- cookies saving some of the user's preferences;
Analytical cookies
We use analytical cookies to register and process the behaviour of our users in statistical form (for example, subpages visited).
Third-party advertising cookies / Third-party Pixels / Third-party monitoring
We also allow other companies to collect our users' data through advertising cookies or pixels. This allows us and third parties to provide users of our online offer with targeted advertising adapted to interests based on an analysis of their user behaviour in general and not only as part of our online offer (for example, banner adverts clicked, sub-pages visited).
Here you can find detailed information about the cookies used. Along with a description of the different cookies / pixels, this page also provides explanations about the reasons for their use and other important information.
How to prevent the use of cookies or delete cookies
At any time, you can also deactivate cookie storage in the settings of your web browser and delete the cookies already stored in your web browser (see technical notes). Please note, however, that in the absence of cookies, this online offer may not work correctly or only in a limited way.
We also recommend visiting the website http://www.youronlinechoices.com/, where you will find information and help about tracking mechanisms on the internet.
Web analysis
We need statistical information about the use made of our online offer, in order to make it more user-friendly, to measure audience, to carry out market studies and to display advertisements concerning yourself. To do so, we work with a range of authorised service providers and use web analysis tools. These tools never make use of users' IP addresses or truncate them immediately after collecting them. User profiles generated by these tools using analytical cookies or through the assessment of daily logs do not interface with personal data.
The providers of these tools process data only as sub-contractors, according to our instructions and not for their own purposes. For these service providers, their respective data protection policies apply.
Here you will find a list of the monitoring processes we use for web analysis. Along with a description of the different monitoring mechanisms, this page also provides explanations about the reasons for their use and other important information.
Google Analytics
This website uses Google Analytics, a service provided by Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland ("Google"). Google Analytics uses "cookies", text files that are stored on your computer, tablet or smartphone, and which are used to analyse your use of the website. These cookies are produced by Google (Google Analytics cookies). MyTrueCompanion uses Google Analytics with the extra feature provided by Google to make IP addresses anonymous: the IP address is truncated by Google, in theory everywhere in the EU and only in exceptional cases in the United States, and, in all cases, are only stored in truncated form. Google will use this information on behalf of MyTrueCompanion in order to assess your use of the website, to produce reports about activity on the website and to provide MyTrueCompanion with other services linked to the use of the pages on the website and on the internet, such as Google Analytics reports about demographic data and visitors' interests. Click here for more information about the way Google processes data and the amount of data processed.
Google Analytics
MyTrueCompanion uses the online advertising programme "Google Adwords" and, as part of Google Adwords, conversion-tracking. Conversion-tracking by Google is an analysis service provided by Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland ("Google"). When you click on an advertisement provided by Google, a conversion-tracking cookie is installed on your computer, tablet or smartphone. These cookies are no longer valid after 90 days. If you revisit some of the pages on our website and the cookie has not expired, Google and ourselves can recognise that you have clicked on the advertisement and that you have been redirected towards this page. Each Google Adwords client is given a different cookie.
The information collected using the conversion-tracking cookie is used to generate conversion statistics for Adwords advertisers who have opted to track conversions. MyTrueCompanion knows the total number of users who have clicked on its advertisement and who have been redirected to a page using a conversion-tracking tool. However, MyTrueCompanion receives no information that can be used to identify its users personally.
Use of the remarketing function in Google Adwords
MyTrueCompanion uses the online advertising programme "Google Adwords" and, as part of Google Adwords, conversion-tracking (analysis of the user's activity). Conversion-tracking by Google is an analysis service provided by Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland ("Google"). Through this feature MyTrueCompanion can display customised advertisements to visitors to the website. Customised advertisements of interest to visitors to MyTrueCompanion are displayed when users visit other websites on the Google Display Network or use the Google search engine or a partner's search engine. Google uses cookies to analyse the use of the website. This is the basis for displaying advertisements adapted to the user's interests. To do so, Google installs a small file with a series of figures in the web browsers of MyTrueCompanion users. The series of figures is used to record visits to MyTrueCompanion, as well as data about the use of MyTrueCompanion. If users later visit other websites on the Google Display Network or use the search function of Google or a partner, advertisements, probably taking into account the products and themes already consulted, will be displayed for visitors to MyTrueCompanion.
You can definitively deactivate the use of cookies by Google by clicking on the link below and by downloading and installing the plug-in provided for this purpose: Google Tools. You can also deactivate the use of cookies by third parties by visiting the deactivation page of the Network Advertising Initiative at the address Network Advertising and selecting the additional opt-out measures mentioned there. For more information about Google Remarketing and Google's privacy policy, please visit the website Google Policies
Facebook Custom Audiences
MyTrueCompanion seeks to display "advertisements targeted by users' interest" on Facebook and to limit the display frequency of certain advertisements. For these reasons, MyTrueCompanion uses Facebook's "Website Custom Audiences" analysis tool and "Facebook-Pixel". For Facebook-Pixel, there is a JavaScript code which sends the following information to Facebook Ireland Ltd, Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland ("Facebook"):
- Http headings data (including IP address, web browser information, page location, document, URL of the website and each page visited, user agent of the web browser, as well as the date and time of use);
- Events (visit to the MyTrueCompanion user's page, registration, completion of personality test, purchase);
- Data specific to Pixel; including the Pixel identifier and information from the Facebook cookie, including your Facebook username (it is used to associate the events with a specific Facebook advertising account and to attribute them to a Facebook user).
- Using the encrypted, user-specific Facebook username, Facebook automatically checks whether the data transmitted by Facebook Pixel can be attributed to a Facebook user. If no Facebook cookie is stored in your browser, there will be no attribution to a group of Custom Audience users.
- If the Facebook username contained in a Facebook cookie can be attributed to a Facebook user, Facebook allocates this user to a Custom Audience according to the rules we have defined, provided that the applicable criteria are met. We use the information obtained in this way to display advertisements on Facebook ("Facebook-Ads"). However, the advertisements are only displayed to a Custom Audience with at least 20 different users – so that the advertisements displayed cannot be used to draw conclusions about the characteristics of an individual user. Attribution to a Custom Audience takes effect for a maximum of 180 days. This period is renewed when you visit our website again and when the same rules for a Custom Audience apply.
- Facebook can associate your visit to our website and your associated activities with your Facebook account. We cannot do so. We only receive statistical information from Facebook about the use of our website through the "Audience Insights" Facebook tool.
Plugins sociaux
Integrating social plugins regularly leads to plugin service providers storing cookies. The different plugin providers are listed below under the term "plugin providers"
To optimise the protection of your data during the visit to our online offer, the plugins are integrated into the website using "Shariff solutions". So, when you visit a page on our online service, no connection is made with the corresponding plugin provider's servers.
It is only when you activate the plugins that your web browser makes a direct connection with the respective plugin providers' servers. The provider then receives the information that your web browser has visited the corresponding page of our online service, even if you do not have a user account with this provider or if you are not logged in. Daily logs (including the IP address) are then transmitted directly from your web browser to the provider to be registered, where required. This server may be located outside the EU or outside the EEA (e.g. in the United States).
Plugins are independent extensions provided by plugin providers. As a result, we have no influence on the scope of the data collected and registered by the plugin providers via plugins.
If you do not wish the plugin providers to receive and, where required, to register and process the data obtained via this online service, you must not use the corresponding plugins.
In theory, you can completely prevent plugins from being loaded by using add-ons in your web browser, which are called "script blockers".
You will find more information about the aims and the amount of data collection, processing and later use of these data by plugin providers, as well as your rights and the possibilities of configuring your devices to protect your data in the data policies of the respective providers.
MyTrueCompanion uses social plugins ("Plugins") from the following service-providers:
Facebook plugins
Plugins from the Facebook social network; Facebook is operated on facebook.com by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, United States, and on www.facebook.fr by Facebook Ireland Limited, Hanover Reach, 5-7 Hanover Quay, Dublin 2, Ireland ("Facebook"). You can see what the Facebook extensions look like here: Facebook Developers; Information concerning data protection on Facebook is available here: Facebook Policy
Twitter plugins
Twitter plugins; Twitter is managed by Twitter Inc., 1355 Market St, Suite 900, San Francisco, CA 94103, United States ("Twitter"). You can see some Twitter extensions and information concerning data protection on Twitter here Twitter Privacy
Appendix: Technical notes about cookies
Internet Explorer:
Instructions here Delete and manage cookies
Mozilla Firefox:
Instructions here Clear cookies and site data in Firefox
Google Chrome:
Instructions here Clear, enable, and manage cookies in Chrome
Safari:
Instructions here Manage cookies and website data
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