Privacy policy

Updated: 01/12/2022

 

The purpose of this Privacy Policy is to inform you about how PAKPAIR uses your personal data. We recommend you should read it carefully.

 

1. Definitions

 

Application: The PAKPAIR application, available on the Apple App Store and the Google Play Store.

Account: The Member’s dedicated personal area within the Application, which he or she accesses when he or she registers and connects to the Application. It enables the Member to access the Services. A Member may only have one Account.

Boost: a function enabling Members to increase the visibility of their profile during the time that this option is activated.

Crossing point: your Geographical position, as recorded when you crossed paths with another Member, if the geolocation feature is enabled.

Match: An event that is created between two profiles, triggered by a Like or Super like on both profiles. It represents mutual interest and sends out a “You have a match” notification, allowing Members to start a conversation.

Facebook Connect: A feature enabling Members to use their Facebook account to log in to the Application, in order to simplify the registration process.

Google Connect: A feature enabling Members to use their Gmail account to log in to the Application, in order to simplify the registration process.

Apple Connect: A feature enabling Members to use their Apple account to log in to the Application, in order to simplify the registration process.

Geographical position: your location, recorded by PAKPAIR and updated regularly when this option is enabled.

Like: An action represented by a heart, expressing interest.

Map (Mapping): A map that allows you to find Members with whom you’ve crossed paths.

Member: A person registered with the Application. 

Member characteristics: Information provided by the Member describing his or her lifestyle and personal characteristics on the profile. The Member can choose the information he or she wishes to appear on the profile and filter other Members on the Application based on this information.

Messages and/or voice messages: Only Members who have a Match can use the Application’s “Chat” function to send each other Messages.

Profile Verification: PAKPAIR only allows verified profile. During registration the app ask the user to take a picture with a paper on a code provided by the app must be written. The someone from the PAKPAIR team will approve or deny the profile

Profile Photos: photos on your profile enabling the easy identification of the Member. The Member accepts to, at the very least, provide a photo of his or her face in which he or she is clearly recognizable, and place it in first position. These two criteria combined are an essential condition for using the Services.

Services: All services, are free of charge, offered by PAKPAIR to encourage virtual or real-life meet-ups between Members who have crossed paths and who have a mutual interest in one another, according to the selected search criteria.

Video Call: feature offered only to Members who have a Match, enabling them to call and talk to each of their Matches spontaneously, for a limited duration. This feature can be accessed from the “Messages” page, by clicking the icon in the top right corner to start the Video Call. During the Video Call, Members have access to the following options:

  • Pick up

  • Mute

  • Disable video

  • Switch to frontcam

  • Hang up

 

2. Data controller

 

PAKPAIR is extremely concerned about the protection of your personal data and respect for your privacy. The purpose of this privacy policy (along with our document on the use of cookies and our terms of service and any other document it refers to) is to inform you on the way we process the personal data you share with us and that we collect when you use the Application and Services. Please read this document carefully to better understand how we process your personal data, and to know your rights. 

 

This Privacy Policy applies to all Services published by PAKPAIR that you use (with the exception of services supplied and operated by third parties, in which case, their privacy policy will apply). 

 

3. Information we collect

 

PAKPAIR collects and processes personal data on you when you use the PAKPAIR application or when you communicate with PAKPAIR. It may be information you share with us directly, or data we collect automatically. 

 

To make sure our privacy policy is clear, we are providing below an overview of the personal data PAKPAIR collects and processes. Information is given below for each type of data collected. 

 

  • Mandatory data
    • Identification data
    • Depending on how you signed up, Social media login or via PakPair registration process
    • Data relating to your activity on the application
    • Technical data of the cell phone or device
    • Your city

 

  • Data required for certain purposes
    • Data relating to taking part in games and competitions, to your experience and your satisfaction
    • Geographical position or at least your city
    • Crossing points with other Members
    • Search preferences - people whom you would like to cross paths with (age and gender)
    • In-app messages and in-app voice messages sent and received
    • Data on Video Calls (the contents of such Calls are not collected)
    • Data relating to reports made and requests sent to the PAKPAIR customer service 

 

  • Optional data
    • Professional career and education
    • Interests and hobbies
    • Description

 

3.1 Data you share directly 

 

When you use our Services, you share information with us, some of which may be used to identify you. When you communicate this information, you accept that some of the data will be visible to the other Members of the Application, and therefore made public on the Application. In an effort to help you identify this information easily, it is signaled as ‘public’ below. PAKPAIR cannot be held liable for data published on its platform and disclosed by a Member. However, information not marked as Public will not be visible or accessible by other Members; such information is signaled as ‘private’ below. 

 

PAKPAIR collects and processes data relating to your registration and data relating to your interactions with PAKPAIR. 

 

3.1.1. Registration data 

 

Information required for registering

 

This is the basic data required for you to register and access our Services. 

This data is collected by PAKPAIR using different methods depending on the type of registration you choose. 

 

If you choose to register using your Facebook, Apple or Google account, your data will be collected from the relevant platform in an effort to reduce formalism. By selecting “Log in with Facebook/Apple/Google,” you agree to having these platforms provide us with such data.

 

In addition, you can register using any other mail account and, if this is the case, your data will be sent to PAKPAIR directly by you

This data relates to your identity. 

 

Depending on how you registered, some data must be collected in order to provide our Services. If such data is not obtained, PAKPAIR will not be able to provide you with its Services via the Application, and you will not be able to create an Account. In all cases, your first name (public), age (public), gender(public), and all Profile Photos (public) are required to register with the Application. Subsequently, you may add or remove Profile Photos at any time, providing you have added at least one Profile Photo containing a person’s face. As stated in paragraph 1, “Definitions,” the first Profile Photo should be a photo of a person’s face.

 

When you register via Facebook, we must collect your first name and your age. You may also allow Facebook to provide PAKPAIR with your last name, birthdate, gender, email address, and to transfer your Profile Photos from Facebook.

When you register via Apple or Google, we must collect your first name and email address. Said platforms may also provide PAKPAIR with your last name.

 

In addition, if you refuse the geolocation feature when registering, and thereby the possibility for PAKPAIR to collect your location data to suggest Member profiles with whom you have crossed paths, you must provide the name of your city. This information will enable PAKPAIR to suggest Member profiles near you.

 

Optional information to complete your profile 

 

You may add additional information to improve your profile. This information is optional, shared at your own discretion, and is your sole responsibility. You can add this information directly to your profile on the Application and/or via Facebook Connect by syncing your Account with Facebook. This data is as follows: 

 

  • professional career and education (public): profession or studies;

 

  • interests and habits (public): personal preferences, leisure activities, musical preferences, lifestyle, Member Characteristics;

 

  • height (public);

 

  • profile description (public): if you would like to, you can share additional information about you in the space provided for this purpose. This information will be visible to PAKPAIR Members. Moreover, if you so wish, you can also answer the questions on your lifestyle (personality traits, sports, travel, type of meeting expected, etc.).

 

 

Your description is a free text area, PAKPAIR does not encourage Members to share data that can be perceived as sensitive with other Members, or with PAKPAIR through the Application. Sensitive data refers to data that is legally qualified as “sensitive” by the General Data Protection Regulation (“GDPR”). More specifically, it includes information on race or ethnicity, political opinions, religious or philosophical beliefs or affiliation with a union, along with information on health, sexual life or sexual preferences (“Sensitive Data”). If a Member decides to share such information on his/her profile regardless, it is deemed to have been “clearly made public” by the Member who shared it, according to the GDPR. 

 

3.1.2. Data relating to interactions with PAKPAIR

 

When you contact our customer or support services, report an issue with our services, ask for help, exercise your personal data rights, or participate in promotional activities, games, competitions or surveys, when you share your experience of our services, give testimonies, or answer one of our questionnaires, PAKPAIR will collect, depending on the case, the following personal data: 

 

  • Data relating to reports and requests sent to the PAKPAIR customer service (private): Date and time of the report, nature and reason for the report, data relating to the reported user. Furthermore, proof of identity may be requested as part of the exercise of your rights over your personal data, and for safety/confidentiality reasons.

 

3.2 Data we collect automatically

 

When you use our services and features, we collect information on your activities on the Application: 

 

  • Activity data (private) (registration date, login dates, on or offline status, interactions with Members and third-party accounts, number of transactions, notifications received, notification preferences, etc.) 

 

When you access our Services and use the Application and its features, information on the way you use them is collected and processed. Most of the information collected by PAKPAIR is necessary to the provision of its Services. Without this data PAKPAIR cannot supply the Services linked to the PAKPAIR application. 

More specifically, this includes your registration date, login dates, on or offline status, the type and number of interactions with other Members (such as Likes, Likes, Dislikes, crossings, asking questions before matching, and Matches), notifications received and notification preferences. 

 

  • Geographical positions and Crossing points with other Members (public)

 

The Application’s main value and purpose is to allow Members to find other Members they have or may have crossed paths. Your Geographical position is collected with your express consent only. In fact, you will be asked to authorize the collection and processing of your location data to allow PAKPAIR to identify your crossing points with other Members who have agreed to be geolocated.

Unless you have chosen stricter settings on your device, PAKPAIR will collect your Geographical position regularly.

When the Geographical positions of two Members are within a certain radius, PAKPAIR pinpoints a Crossing point.

Your Crossing points will be displayed on your profile, but Members with whom you cross paths can never see your exact location. Each Member sees his/her location when the Crossing point was registered in a radius defined by PAKPAIR. They cannot see the other Member’s location.

During your registration, if you do not provide your consent for geolocation the you will not be able to use the cross paths feature.

 

These Crossing points can be displayed as a news feed or on a Map (Mapping).


You may, at any time, withdraw your consent by disabling geolocation on your smartphone. If you choose to do so, your news feed will no longer be updated, and you will not be able to see who you have crossed paths with after disabling the geolocation option. When you have no more profiles in your newsfeed.

 

You can also ask that your profile, and therefore your crossing points, are no longer displayed on the Map (Mapping). In this case, you will only appear in the news feed of other Members. Equally, you will no longer be able to see the profiles of Members you have crossed paths with on the Map (Mapping); you will only see these profiles on your news feed.

 

  • Text messages and voice messages sent and received (private)

 

Messages are sent and stored on PAKPAIR’s servers, to provide the Service to allow Members with a Match to have a conversation. Messages and voice messages are strictly private and only implicate the Members involved. PAKPAIR’s authorized managers do not exercise any rights to view these conversations. These Messages are not transmitted or communicated to third parties except in cases of judicial requests, and/or in compliance with the applicable legislative or regulatory provisions. Moreover, Messages are strictly private and are not accessible to other Members who are not involved in the conversation, nor to any third party. 

 

  • Information relating to Video Calls (start and end time/date of calls, etc.) (private)

 

If you wish to make a Video Call using PAKPAIR, your telephone’s technical data is required in order to establish communication between the two Members. PAKPAIR will collect the start and end time/date of Video Calls, but not their content. Such Video Calls are instant.

 

  • Match preferences - people whom you would like to cross paths with (age and gender) (private)

 

The Application lets you set preferences by age, gender, and the Member Characteristics they have provided. You can change these settings in the Application and specify the age range and Member Characteristics, and, after agreeing to PAKPAIR collecting and processing your data, the gender of people you are looking for, so you can be matched exclusively with profiles you crossed paths with and who meet your search criteria. You will then only see the Members you have crossed paths with and who share your search preferences on your news feed. 

 

  • Technical data of the cell phone or device (IP, mobile ID, application version, telephone version and model advertisement ID, etc.) (private)

 

We collect information from the devices and equipment you use to access our Services, including server logs, which may contain information such as IP addresses, version of the application, device version and model, language used, operating system, application crashes, and advertisement ID. Data may be collected with cookies or other tracking tools: to learn more about this, please refer to our document on the Use of Cookies

 

 

4. How do we use your data?

 

4.1. Supply of services and features according to our terms of service

 

  • Creation and management of your Account as a Member:
    • Creation of your profile.
    • Registration, deregistration, deactivation of your Member profile.
    • Management of parameters and preferences.
    • Management of access to the Services proposed by PAKPAIR.

 

  • Managing and storing messages exchanged between Members (Messages, Likes, Superlikes, Matches).

 

  • Managing Video Calls between Members

 

  • Sending information messages relating to the Services or your interactions with other Members (notifications).

 

4.2. Suggesting profiles you have crossed paths or may cross paths with

 

  • Geolocation to suggest profiles of Members you have crossed paths or may cross paths with. 

 

Legal basis: Consent 

When you have given your consent, you are free to withdraw it any time by disabling the geolocation option on your smartphone. Withdrawal of consent does not affect any processing carried out before the withdrawal.

 

Additional information 

The aim of the Application is to help you find other Members whose paths you have crossed or may cross. In fact, it allows you to identify your crossing points with other Members who have agreed to be geolocated. These crossing points allow PAKPAIR to show you profiles of Members you have crossed paths or may cross paths with and who meet your search criteria. 

 

  • Based on your activity in the Application, your position and the information on your profile, your profile may be suggested to other Members. Your profile is also suggested when you use the Boost feature as defined in paragraph 1.

 

Legal basis: Execution of the contract

Processing this data enables us to provide our Services, and thus, to increase your likelihood of meeting Members with whom you are a good match.
 

  • Recommend your Profile via email to other Members with whom you have crossed paths or with whom you could cross paths.
     

Legal basis: Legitimate interest

This processing is based on the legitimate interest of PAKPAIR to offer Members relevant Profiles as part of its Services. You can contest this data use at any time by contacting us (see section 9. Contact).
 

4.3. Suggesting relevant offers and contents (marketing and advertisements)

 

  • Sending marketing or advertisement messages or contents:

     

    • Send the PAKPAIR editorial newsletter by email. We will stop sending the newsletter to Members who have not opened it in over a year.
    • Send a newsletter suggesting Profile recommendation that can be viewed on the Application (your Shortlist).

    • Distribute marketing contents and advertisements related to PAKPAIR offers and services on the application and by emails.
    • Provide Members with offers and/or promotions on PAKPAIR’s services.

 

Legal basis: Legitimate interest

This processing is based on the legitimate interest of PAKPAIR to share its offers. As relates to the newsletter, you can object to receiving emails from PAKPAIR at any time by clicking on the “Click here to unsubscribe” link provided for this purpose in the emails you receive.

 

4.4. Improving and optimizing our services and our knowledge of how you use them

 

  • Improvement and optimization of the services of PAKPAIR, of the knowledge of its Members and the manner of using the Services:
    • Statistical studies.
    • Satisfaction survey.
    • Analyses of the use of the Application and Services by Members.
    • Understanding how our Application and its features are used
    • Improving our Application, offers and features
    • Understanding your needs

 

Legal basis: legitimate interest

This processing activity is based on PAKPAIR’s legitimate interest in improving and optimizing its services, knowing its users and how its services are used.

 

  • Provide Members with advice on which Profile Photos to publish by analyzing all Members’ profiles, so Members can, if they wish to do so, optimize the way their profile is presented.

 

Legal basis: legitimate interest

This processing activity is based on PAKPAIR’s legitimate interest in improving the way profiles are presented in the Application. You may oppose this use at any time by contacting us (see Section 9, Contact).

 

4.5. Guaranteeing the security of your personal data

 

  • Detecting or preventing breaches of the security of the Services by identifying and analyzing fraudulent behavior.

 

Legal basis: Legitimate interest 

This processing is based on PAKPAIR’s legitimate interest in guaranteeing the security of its application and the data it processes. You can object to this use at any time by contacting us (see section 9. Contact). However, PAKPAIR may continue to implement the processing if it justifies legitimate and compelling reasons.

 

4.6. Preventing and combating illegal or unauthorized activities (breaches of the terms of service), ensuring the trust of Members and complying with legal requirements

 

  • Analysing and processing reports of fraudulent/undesirable behavior.

 

  • Managing undesirable behavior and warning, suspending, blocking or deleting the Member’s Account.

 

  • Managing requests to exercise Members’ rights over their data.

 

  • Detecting or preventing fraudulent activities or activities which breach our Terms of Service:

     

    • Automated analysis of profile data, application activity to detect fake profiles, fraudulent behavior or behavior that breaches the Terms of Service.

 

  • Guarantee the quality of profiles:

     

    • Automated analysis of Members’ Profile Photos in order to detect faces, and, as much as possible, exclude fake profiles from the Application, combat fraudulent behavior and guarantee Member identification. You will not be able to create an account if your face cannot be detected in one of your Profile Photos upon registering. If you are prevented from registering even though your Profile Photo does show your face, you may contact us at any time.

 

Legal basis: Legitimate interest

This processing is based on PAKPAIR’s legitimate interest in preventing and stopping fraudulent activities that may be carried out on its Services or breach its Terms of Service, and in protecting users’ safety though profile identification. You can object to this use at any time by contacting us (see section 9. Contact). However, PAKPAIR may continue to implement the processing if it justifies legitimate and compelling reasons.

 

  • Profile certification (as defined in paragraph 1): in order to certify the profile of a member, PAKPAIR must, having obtained the Member’s consent, collect his or her biometric data using the image provided during profile verification , and compare this data with the Member’s Profile Photos

 

Legal basis: Consent

Your consent for the use of your biometric data for Profile verification is requested when you start the verification process. You can withdraw this consent at any time by clicking on “Account” then “Delete my account.” If you withdraw your consent, your video will be deleted and your biometric data will no longer be able to be collected.

 

4.7. Providing Members with help and technical support

 

  • Responding to the requests for support submitting by Members using the Application

 

Legal basis: legitimate interest

This processing activity is based on PAKPAIR’s legitimate interest in ensuring that its Members can use the Application in proper technical and operational conditions.

 

5. Cookies and tracking tools 

 

Cookies may be used on our showcase website for technical, advertising reasons or for measuring audiences. In the Application, cookies and tracking tools may be used for technical reasons and for measuring audiences.

To learn more, read our document on the Use of Cookies on our website. 

 

6. How data is shared

 

Only certain PAKPAIR employees from customer services and authorized managers process Members’ personal data for the purposes described above. These employees and authorized managers only have access to the data necessary to perform their duties.

 

Authenticated and reliable service providers and partners, who may access and/or process Members’ personal data, in compliance with the Privacy Policy, and ensuring the security and privacy of the Members’ personal data. These service providers help us operate and improve our Services, including

  • our sub-contractors in charge of data infrastructure and hosting

  • suppliers of the analysis software we use

  • technical sub-contractors for using the Application and/or ensuring that the Application functions properly

  • our customer service to provide Members with the support they need and manage reports;

  • our Marketing partners to provide PAKPAIR Members and non-Members with relevant messages, offers and content.

 

As part of marketing and advertising operations outside the Application intended for non-Members, your data may be provided to partner social networks in order to exclude you from our campaigns, unless you oppose that.

 

 

In addition, at the request of state bodies, in particular the judicial authorities, and in order to comply with any judicial or legal request, PAKPAIR may transmit the personal data of its Members. 

 

Lastly, we may be required to share your data for the purposes of corporate operations, which include, but are not limited to, a restructuring, a change in control of the company, a merger, an acquisition, a transfer, or a termination of the company.

 

 

 

7. Exercising your rights over your Data

 

Your rights

Pakistan does not currently have a general data protection law. However, the government is currently considering the Personal Data Protection Bill 2020 (PDPB) (see Question 1), which requires data controllers to provide a written privacy notice to data subjects (Section 6, PDPB).. In an effort to address its Members’ concerns, PAKPAIR commits to respecting the protection of personal data and to process requests as soon as possible. 

 

Exercising your rights

Members may exercise their rights, subject to proving their identity, by sending an email to support@pakpair.com

 

For any other claim, the Member may lodge a request with the national authority responsible for data protection.

 

Description of rights

 

These rights may only be exercised within the limits of PAKPAIR’s resources as it relates to its use of Facebook, Google and Apple to log into the Application. Some data sent to PAKPAIR by Facebook, Google or Apple cannot be corrected without Facebook, Google or Apple’s cooperation.

 

8. How long will we keep your data?

 

PAKPAIR has introduced a process for automatically deleting your account and your personal data with regard to the storage time limits defined below. When certain data must be stored for statistical uses beyond these storage time limits, this data is anonymized irreversibly to ensure you can no longer be identified.


PAKPAIR will store the Member’s data for as long as required in order for the Member to use his/her Account, namely: 

 

  • When a Member is banned, his/her Account becomes inactive. Information from this Account is retained in an active database for one year, in order cross check it with information provided with new registrations to the Application, in order to prevent, to the extent possible, banned users from registering again. Subsequently, the personal data is archived for one more year, after which it is deleted permanently or irreversibly anonymized.
  • When the Member deletes his/her Account or requests its deletion from Customer Service, it will be deleted from the Application. However, the Member’s data will be kept in a separate archive for one year before being permanently destroyed or irreversibly anonymized, in order to enable PAKPAIR to comply with its obligation to keep it as host.
  • Some of the Member’s data, such as email address, will be retained for prospecting or Marketing purposes for one year after an Account has been inactive for one year. If a Member deletes his/her Account, this data will not be used for prospecting or marketing purposes.

 

With regard to your Geographical Positions and Crossing Points, shorter storage times apply:

-  Your Geographical Positions are stored for one days from their collection in order to determine your Crossing Points with other Members;

- Your Crossing Points are stored for six months from their collection in order to display the Profiles of Members you have crossed on the Application.

 

PAKPAIR undertakes to make every effort and to invest all means at its disposal to guarantee that the stored data is kept as secure as possible. However, it is the Member’s responsibility to take appropriate measures to protect his/her data.

 

 

9. Contact 

 

If you have any questions regarding this privacy policy, or any other request concerning your personal data, you can contact us: