Data protection is an important concern of be2 S.à.r.l., 13 rue du Commerce L-1351 Luxembourg Luxembourg ("be2 S.à.r.l."). For this reason, we process our customers' data solely in compliance with valid regulations relevant to data protection (GDPR).
We collect and process personal data if you make this data available to us in the framework of registering on our website for using be2 services ("be2"), and we are entitled to collect, use and process the data on the basis of consent that you issued.
Personal data is all information that refers to an identified or identifiable natural person ("data subject"). We differentiate between personal data in the framework of a free profile and a Premium membership.
In the case of free registration we collect and process the personal data:
Master data: first name, email address, password, gender, gender wanted, date of birth
Personal characteristics: characteristics, height, colour of eyes and hair, length of hair, figure, ethnicity, occupation, education, annual income, drinking and smoking habits, information on the existence of children
Search profile and other information: state, region, county/town, postcode, personal welcoming message, profile images, supplementary profile information in the categories "opinions" and "lifestyle"
Your transaction data: customer ID, messages, date of first registration, activity on our website, access type (mobile/desktop), internal tracking code, date and time of access, browser type and version, operating system, IP address, device ID, mobile service provider
In the framework of a Premium membership we collect in addition:
Home address, first and family name, telephone number and payment data. We forward credit card data via a secure connection to our contractual Payment Service Providers and store them on an anonymised form only.
Purpose of data processing
We use the above-mentioned personal data for the following purposes:
- Providing the services you request as well as the customer service that you request;
- Carrying out and managing the business relationship between us and you; e.g. in order to handle the provision of services, collect payments, settlements and debt collection, for accounting purposes;
- Reviewing customer communication between customers and customer support staff;
- Information on new or supplementary products in the field of dating from be2 S.à.r.l., and from cooperation partners of be2 S.à.r.l. (Interdate S.A., 13 rue du Commerce, L-1351 Luxembourg), as well as for preparing a newsletter;
- Carrying out customer surveys, marketing campaigns, market analyses;
- Compliance with statutory requirements (e.g. obligations under tax and commercial law to preserve records);
- Maintaining and protecting the security of our products and services and of our websites by preventing and detecting security risks, fraudulent behaviour or other criminal activities or activities carried out with the intent to cause damage, as well as by analysis of the contents;
- Settling disputes, enforcing existing contracts and for claiming, exercising and defending legal rights.
Processing personal data is necessary to achieve the above-mentioned purposes, including the implementation of the (contractual) business relationship with you. Unless otherwise expressly stated, the legal basis for the data processing is Article 6 (1) (b) and (f) of the General Data Protection Regulation, or your expressly issued consent in accordance with Article 6 (1) (a) of the General Data Protection Regulation.
If the above-mentioned data are further processed for a purpose other than the original collection purpose, we are obliged to inform you of this before further processing and of the new purpose. In this way, you have an opportunity to object to the processing of your data for the other purpose.
Transfer of data
All data that you transmit to us will be treated in confidence. We will not sell your personal data to third parties.
You data will, in principle, not be made available for use to third parties, unless you have declared your agreement or we are entitled and/or obliged by law to transfer this data.
We transfer personal data to courts, tax authorities, supervisory authorities if this is legally permissible and necessary to comply with current law, or to enforce, exercise or defend legal rights. We take all steps to ensure suitable and reasonable guarantees to safeguard your personal data.
Insofar as this is necessary for the provision of the service, we forward personal data for the above-mentioned purposes to the following companies or categories of companies:
- insparx GmbH, Erika-Mann-Straße 63, 80636 Munich, Germany. Our service provider is responsible for operating our platform, software further development, for customer support, and for marketing and sending newsletters.
- Payment service providers, acquirer/executing banks for the purpose of payment processing: e.g. https://www.wirecard-cardsolutions.co.uk/privacy-policy/.
- On non-payment, to collection agencies to safeguard our business interests.
- To cooperation partners / marketing and email newsletter partners.
- Data may be transferred to specialised service providers to prevent or combat cases of abuse by customers and/or third parties.
- IT service provider for storing data within the EU.
Transmission to addressees outside the EU takes place only if the predefined purpose requires this and only on the basis of EU standard contract provisions, or if a company in the USA is certified in accordance with the EU/US Privacy Shield (https://www.privacyshield.gov). This guarantees that your data is processed in conformity with data protection provisions in the USA as well (adequacy decision of the EU Commission of 12.07.2016, ref. C(2016) 4176 final, Official Gazette L 207/1 of 01.8.2016).
If an explicit storage period is not indicated on collection (e.g. in the framework of a declaration of consent), personal data will be deleted if they are no longer required to fulfil the purpose of storage, unless statutory obligations to keep records prevent deletion (e.g. obligations under tax and commercial law to preserve records).
We take technical and organisational security measures to protect your data that we store and process in our company against manipulation, loss of confidentiality, destruction and against access by unauthorised persons. Our company's security measures are constantly improved in accordance with technological developments.
Rights of data subjects: right to information, correction, deletion or restriction of processing of their personal data, right to object and right to data portability
We will inform you in writing on request in accordance with current law whether and which personal data we store in our company. If you, yourself, are registered as a user, we provide you with an opportunity to inspect these data yourself and, where applicable, to amend and delete them. If false information has been stored in spite of our company's efforts with regard to data security and data correctness, and you as user are unable to correct your data, we will correct them at your request.
You also have the right to demand restriction of the processing of personal data by our company. In addition, you may demand that you are given data that you provided to our company in a structured, standard and machine-readable form. You may also object to the processing of personal data by our company.
In addition, you have the right to demand that your personal data be deleted, unless statutory obligations to keep records prevent this. We delete data when we no longer require it for the purpose for which it was collected and processed, or if you revoke your consent and there is no other legal basis for the further processing of your data. In addition to this, we delete data if processing was illegal for reasons that are unknown to us, or if you have filed an objection to the processing and there are no prior legitimate interests for processing. Your data will also be deleted if we are obliged by law to do this. Our company has also implemented technical measures to make all recipients of your data aware of your demand for deletion or correction. This applies only for cases in which we disclosed or made these data public. All links, copies and replications of your personal data will be deleted.
If you consented to the processing of your personal data, you have the right to revoke the consent at any time, with effect for the future. Revocation of consent does not make data processing in the past unlawful.
Data transmission to our company is done voluntarily. However, these data are necessary for the further conclusion of the contract or to reply to your queries. If you do not wish to make your data known, the contract may in certain circumstances not take effect, or your queries may not be answered. Providing data is necessary for concluding the contract.
The contact data of our company's data protection officer are:
[email protected] or by post to
be2 Data Protection Officer
13 rue du Commerce
You also have the right to complain to the competent data protection supervisory authority about data processing by our company.
The data protection supervisory authority responsible for our company is:
Commission nationale pour la protection des données
1, avenue du Rock’n’Roll
Tel.: (+352) 26 10 60 -1 www.cnpd.lu
As a data subject, you have the possibility to approach the data protection supervisory authority in your country: (https://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080).
If you register for a subscription to our newsletter, the data you provide will be used solely for this purpose.
Your name and a valid email address are required for effective registration. For this purpose, your opt-in to the newsletter subscription is logged. The data is used solely for sending the newsletter.
You may revoke your consent to storage of your data and their use for sending the newsletter at any time. Each newsletter contains a link for this purpose. Apart from this, you may unsubscribe the newsletter at any time directly by email to [email protected] or by post to the following address:
be2 Customer Support
13 rue du Commerce
When you access our company's homepage, for technical reasons your Internet browser automatically transmits the following data ("log data") to our company's web server, which our company records in log files:
- date and time of access, URL of the referring website, file requested, transmitted data volume, browser type and version, operating system, IP address, domain name of your Internet access provider
This is solely information that does not permit any conclusions with regard to the natural person. This information is technically necessary in order to display the website content that you requested correctly and is mandatory for use of Internet offers. Log data is evaluated purely for statistical purposes, in order to optimise our company's web presence and the underlying technology, and are then deleted.
Log data is stored separately from other data that our company collects in the framework of use.
Pseudonymised or anonymised usage profiles
be2 has analyses carried out of customer behaviour in the framework of use of be2 services and prepares anonymised or pseudonymised usage profiles for this. Usage profiles are evaluated anonymised or pseudonymised and not in relation to persons. The analyses are intended to improve our services.
Tracking-based analyses, remarketing tools and Scoring
We use so-called tracking technologies in order to continuously improve and optimise our offer.
be2 also uses Google Analytics, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses “cookies”, which are text files placed on customers' computers, to help the website analyse how they use the site. The information generated by the cookie about use of this website (including the IP address) will be transmitted to a Google server in the United States and stored there. Google will use this information to evaluate customers' use of the website, to compile analyses of website activities for website operators and to provide other services associated with website and Internet use. Where applicable, Google will also transmit this information to third parties, insofar as this is prescribed by law, or if third parties process these data on its behalf. Google will not associate the IP address with any other data that it holds. Customers may prevent the installation of cookies by selecting the appropriate settings on their browsers; however, please note that if this is done, it may not be possible to use all the functions of this website in their full capacity. By using this website, customers declare their agreement with the processing of collected data by Google in the manner described above and for the above-mentioned purpose. For detailed information on Google Analytics and data protection go to https://tools.google.com/dlpage/gaoptout?hl=en.
Our user analysis uses Universal Analytics. This allows us to obtain information about the use of our offers on different devices ("Cross Device"). We use a pseudonym user ID using cookie technology, which contains no personal data and does not transmit data to Google. Data collection and storage can be opted-out of at any time through a Google browser plugin (https://tools.google.com/dlpage/gaoptout?hl=en). This opt-out must be performed on all systems that you use, for example, in another browser or on your mobile device. More information about Universal Analytics can be found here: https://support.google.com/analytics/answer/2838718?hl=en&ref_topic=6010376
The following Google Analytics Advertising Features are enabled:
- Remarketing with Google Analytics
- Google Display Network Impression Reporting
- Google Analytics Demographics and Interest Reporting
- Integrated services that require Google Analytics to collect data via advertising cookies and identifiers
These Advertising Features enable Google Analytics to collect additional user data via Google advertising cookies (more information at https://www.google.com/policies/technologies/types/) and identifiers, to data collected through a standard Google Analytics implementation.
Google AdWords (remarketing)
be2 also makes use of the remarketing function within the Google AdWords service. Google AdWords is an online advertising program provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google”). With the remarketing function we can present advertising based on their interests to users of our website on other websites in the Google display network (on Google itself, so-called "Google ads" or on other websites). For this purpose, the interaction of users on our website is analysed, e.g. what offers are users interested in, in order to be able to display targeted advertising on other websites after they visit our website as well. To do this, Google saves a number in the browsers of users who visit specific Google services or websites in the Google display network. This number, referred to as a cookie, is used to record the users' visits. The number serves the unambiguous identification of a web browser on a specific computer and not for identifying a person. Information on use of our website collected through the cookie (including your IP address) is usually transmitted to a Google server in the United States and stored there. Please note that on this website Google AdWords (Remarketing) was extended by the code "gat._anonymizeIp()", in order to guarantee anonymised collecting of IP addresses (so-called IP masking). For this reason, at our instance Google collects your IP address in an abbreviated form only, which guarantees anonymisation and does not permit any conclusions regarding your identity. In the event that IP anonymisation is activated on this website, Google will abbreviate your IP address beforehand within a member state of the European Union or in other signatory states of the Treaty on the European Economic Area. The full IP address will only be transmitted to a Google server in the USA and abbreviated there in exceptional cases.
You have the right to prevent installation of cookies by selecting the appropriate settings in your browser software; however, please note that if you do this, you may not be able to use all the functions of this website in their full capacity. In addition to this, you can deactivate interest-based ads on Google and interest-based Google ads in the web (within the Google display network) in your browser by following the link "Deactivate" at www.google.com/settings/ads in the submenu "Deactivation settings". Furthermore, you can deactivate interest-based ads at https://www.networkadvertising.org/choices/?partnerId=1/ cookies by means of opt-out; an opt-out cookie is set on your computer for this purpose.
be2 uses Google Firebase, which is a service provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94034, USA (Google). Google Firebase makes use of tracking technology, which allows us to analyse how our app is used. To this end, information on app usage is collected for and sent to Google, where it is stored locally. Google uses your device's Advertiser ID for this. Further information on Google Firebase and data protection can be found at https://www.google.com/policies/privacy/ and https://firebase.google.com/ . Google is Privacy Shield certified. You can manage the Advertiser ID in your device settings (iOS: Privacy > Advertising > Limit Ad Tracking; Android: Account > Google > Ads).
Firebase is also used for conveying Push Notifications (also known as In App Messages), which are messages that are only shown within the app. For this, your mobile device is assigned a pseudonymised Push Reference, which serves as the destination for the Push Notification or In App Message. You can activate or deactivate the content of Push Notifications at any time by doing the following: (1) Once installed, you can find the app on your device under Settings > Apps. There under App Settings > Notifications you can manage the content of the push notifications at any time. (2) You can also manage the content of push notifications on your device under Settings > Notifications.
The smartphone apps from be2 use the Crashlytics tool, which is part of Google Firebase. No personal data are transmitted. Only real-time crash reports with exact information on register codes and appliance information are transmitted that are intended to simplify maintenance and improve the resulting stability of the app. The Crashlytics privacy statement can be inspected here: https://www.google.com/policies/privacy/
be2 also uses the "adjust" analytics technology provided by adjust GmbH, Saarbrücker Str. 37A, 10405 Berlin ("adjust”). adjust uses IP and Mac addresses for the analysis, whereby these addresses are only used in an anonymised form. In this way, conclusions regarding a natural person are not possible.
For the purposes of tracking and advertising, the be2 app uses the Advertiser ID, also known as the "Advertiser Identifier" (IDFA) for Apple devices and the "Android Advertiser ID" (Advertiser ID) for devices running Google products and services. These are hereinafter referred to as the "Advertiser ID(s)". The user can deactivate the Advertiser ID. For iOS devices this is done in the Settings under Privacy > Advertising by selecting the option "No Ad Tracking". For devices running an Android system this is done under the "Google Settings" (or under "Settings" and then in "Google"), by tapping on "Ads" and then selecting the option "Opt Out of Ads Personalisation". The Advertiser ID is pseudonymous.
be2 uses the Smartly.io tool to prepare and manage Facebook and Instagram ads. Smartly.io is a service provided by Solutions Inc., whose registered office is Elielinaukio 2 G, 00100 Helsinki, Finland. As soon as a user clicks an ad from be2 on Facebook or Instagram and is directed to the be2 page, the following data may be collected and transmitted to Facebook: 1) Facebook ad ID, 2) time the Facebook ad was clicked. Smartly can now retrieve these data, which are not personal and aggregated. Please note that when the tool is used we have made the appropriate settings in such a way that no personal data at all of users are transmitted to Smartly. You can also find additional information on data protection by Smartly.io at https://cdn2.hubspot.net/hubfs/1570479/Privacy%20Policy/Smartly.io%20Privacy%20Policy.pdf?t=1541065391182
Facebook Custom Audience – Facebook Pixel
Within our services, for the purposes of our legitimate interests in analysis, optimisation and the economic operation of our business, we use the so-called “Facebook-Pixel” of Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA (“Facebook”). This can track the behaviour of users, e.g. after clicking on a Facebook-ad. This method is used to evaluate the effectiveness of Facebook advertisements for statistical and market research purposes, and may additionally help to optimise future advertising efforts. In the scope of Facebook Custom Audience, we do not transmit any data records, in particular no email addresses of our users - neither encrypted nor unencrypted - to Facebook.
The data collected in the context of the Pixel usage is anonymous to us; the data does not give us any information about the identity of the users. However, the data is stored and processed by Facebook, so that a connection to the respective user profile is possible and Facebook can use the data for its own advertising purposes, according to the Facebook data usage directive (https://www.facebook.com/about/privacy/). You can enable Facebook and its affiliates to display ads on and off Facebook. For these purposes a cookie may be stored on your computer. Current information on the General Data Protection Regulation (GDPR) can be found here: https://www.facebook.com/business/gdpr.
If you want to disable the use of Facebook Website Custom Audience, you can do so here: https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen. To do this, you must be logged in to Facebook.
In addition, you have the possibility to opt-out of tracking by the Facebook Pixel in this browser. To do so - please click here: Deactivate Facebook Pixel for this Browser. An opt-out cookie will be added to your browser to stop your data being collected, whenever you visit this website, in the future.
We offer the facility to register for our service with Facebook Connect. Facebook Inc., 1 Hacker Way, 94025 Menlo Park, CA, USA, Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland. This means that an additional registration is not possible. To register, you are directed to the Facebook page on which you can register with your usage data. In this way your Facebook profile and our service are linked. Through the link we receive the following information automatically from Facebook Inc.: age range, date of birth, email, first name, family name, gender, Facebook ID, link to the Facebook profile, language, photo, time zone, confirmed Facebook profile, access token, signed application.
We use only your data of birth, email, first name, gender, photo, time zone, access token and signed application. This information is essential for the conclusion of the contract so that we are able to identify you.
We also use the development tool SDK provided by Facebook Inc., 1 Hacker Way, 94025 Menlo Park, CA, USA, Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland ("Facebook SDK") with regard to the app. Facebook SDK enables evaluation of user behaviour in an anonymised form and measuring of active users and their behaviour (e.g. posts, replies, votes). This does not provide us with any access at all to Facebook data or to users' Facebook accounts. For more information on Facebook SDK go to https://developers.facebook.com/docs/ios and https://developers.facebook.com/docs/android.
Automated Decision Making
In order to protect our customers and us, we conduct fraud checks. We have to ensure that the services we provide are duly paid for which enables us to perform our contracted services to our customers and we aim to protect individuals from the misuse of their cards. Checks are conducted on all customers. Due to the amount of customers we deal with, we have to use automated fraud checks including a third party fraud detection provider called Ravelin. Customer data is analysed to make automated decisions whether we can accept an order or not. Automated checks enable us to conduct fraud checks in proper timeframes and in a more accurate and efficient way. The checks and their results are based on various components including known industry fraud indicators provided by our expert fraud detection provider and on fraud patterns we found ourselves. These components are subject to continuous further knowledge of new types of fraud emerging in the future The components generate an automated score indicating the likelihood of a fraudulent transaction. In case the score for you is high, we may reject an order for our services. For disputing a rejection, please contact us. Concerning your rights - please see “Rights of data subjects” section for more information.
Cookies are text snippets that are stored either for a limited time (so-called "session cookies") in a computer's temporary memory, or on a computer's hard disk (so-called "persistent cookies"). Cookies contain, for example, information on users' previous access to the appropriate server, information on which offers were requested or which methods of payment were agreed during previous transactions. The main purposes of cookies is, by storing personal settings on websites, to prepare offers customised to customers on the one hand and, on the other, to design the use of services to be as comfortable as possible, because customers can visit these websites in this way without having to make all the settings every time. In contrast, cookies are not used to carry out programs independently or even to load viruses onto customers' computers.
be2 uses sessions cookies, partner and affiliate cookies and persistent cookies.
be2 uses so-called "sessions cookies". These are not stored on the computer's hard disk and are deleted when the browser is closed. Sessions cookies are used in particular for login authentication during the registration procedure.
Partner and affiliate cookies:
In addition to the above, be2 uses so-called "partner cookies" or "affiliate cookies". These are understood as cookies that are set if a customer accesses the service of be2 through the advertising space of a cooperation partner. These cookies are used for settlements with cooperation partners and do not contain any personal data of customers. They are deleted either when the customer registers on the be2 website or automatically on expiry of the relevant cookie lifetime.
be2 uses so-called "persistent cookies" in order to store the personal usage settings that a customer enters when using be2 services. On the one hand, this ensures that customers find their personal settings again when they return to be2 websites and, on the other, it serves the automatic differentiation of the customer's membership status, whether they have already seen specific information and advertising campaigns, or have taken part in a survey. Use of persistent cookies is intended to personalise and improve be2 services.
Most Internet browsers are set to accept cookies by default. However, customers have the right and the possibility to set their computers to reject cookies, or at least for the customer to be asked to confirm beforehand. If the customer decides to reject or switch cookies off, the consequence may be a reduction in the scope of the be2 service and that not all offers will function without fault.
Declaration of consent
With the conclusion of the contract I consent to the collection and processing of my personal data for the above-mentioned purposes by be2 S.à.r.l., 13 rue du Commerce L-1351 Luxembourg Luxembourg or by third parties that work in the name of and on behalf of be2 S.à.r.l..
I have been informed that be2 S.à.r.l. will log my consent.
In addition, I have been informed that personal data regarding my person that are collected in the framework of the above-mentioned purposes will be processed in compliance with the General Data Protection Regulation (GDPR).
I have been informed that processing of my data takes place on a voluntary basis, and that I may refuse my consent to the processing of my data or revoke it at any time with effect for the future without any disadvantage to myself.
To revoke consent, it is sufficient to send an email stating the email address registered with be2 S.à.r.l., the country whose be2 service the customer uses, and the user name (alternatively: the assigned contact ID) to:
I have been informed that I can send my revocation by fax to: (+61) 280 887 326 or by post to be2 S.à.r.l., be2 Customer Service / Revocation of Consent or Data Correction, 13 rue du Commerce L-1351 Luxembourg Luxembourg.
Consent to the processing of data for advertising purposes
I consent to be2 S.à.r.l. sending/showing me information on new or supplementary products in the field of dating customised for me personally. This also includes advertising from partner companies of be2 S.à.r.l..
I have been informed that I may revoke my consent to the storage of my data and their use for transmitting advertising with effect for the future at any time without any disadvantage to myself and at no charge. To do this, it is sufficient to send an email to [email protected], stating the email address registered with be2 S.à.r.l., the country whose be2 service the customer uses, and the user name (alternatively: the assigned contact ID)