Privacy Policy

We take your privacy seriously. This Privacy Policy explains the steps We take to ensure information about you is kept secure and confidential. We are owned and operated by Ekobridge Limited, company number SC762627, of registered address 31, 4 Lochend Butterfly Way, Edinburgh, who is the data controller in respect of this Mobile app.

Please read this Privacy Policy carefully as once you use the Mobile app We will assume you have read this Privacy Policy and accept the Terms and Conditions of use.

You must not use the Mobile app if you do not want your data dealt with in accordance with this Privacy Policy and the Terms and Conditions. This Privacy Policy takes effect from 1st July 2023.

In this Privacy Policy, certain words have specific meanings, such as:
. "We" means Hallowed Ones, which is owned and operated by Ekobridge Limited. . "Mobile app" refers to this mobile app, the official Hallowed Ones app. . "Member(s)" is a person or persons who have registered an account on Hallowed Ones. . "Profile" refers to a personal profile, which is publicly visible to any registered Member of the Mobile app. . "Personal Information" is data that We collect on registration, examples of which are listed in section 2. . "The Service" refers to the Mobile app, events and any other services that We operate.
1. Data Protection
We are registered with the Information Commissioner’s Office who regulates how We store and use information about you. To view our registration information, please visit the Information Commissioner’s Office mobile app. If you feel that We are in any way not conforming with the provisions of our registration, please contact us email: admin@hallowedones.com. In addition, you have rights under the Data Protection Legislation. For an overview of your rights under these laws, please see the data protection section on the GOV.UK mobile app.
2. The Information We Collect
On Registration
2.1 We will collect Personal Information about you that is voluntarily given by you when you register with Hallowed Ones. This will include your name, gender, date of birth, postcode, city, country, mobile number and email address. We do not store credit card details. None of the contact information above will be given to another Member except your first name, location and gender as added to your Profile. Other information you provide us with
2.2 When you create a Profile we will collect Personal Information about you that you put in your Profile. This might include photos, your interests and the type of person you would like to meet, and anything else you say about yourself on your Profile. 2.3 You may change or delete Personal Information provided by you at any time by logging into your account on the Mobile app.
2.4 If you send us a success story about yourself and a partner you have met through Hallowed Ones, or other testimonial comments, we will collect Personal Information about you that is included in any such submission. By your use of The Service
2.5 Through our use of cookies, log files and other technologies, we may collect Personal Information regarding your mobile device or the computer hardware and software used to access The Service and your use of The Service. This may include the following: IP address of device(s) used; browser type; operating system and device type; approximate location (e.g. Edinburgh); access times and dates; and referring mobile app addresses. navigation around the mobile app links followed time spent on pages
2.6 We collect this information regarding your use of and activity on The Service to help us develop and improve The Service and deliver more helpful information, services and tools.
2.7 We use a number of different cookies on our Mobile app which collect technical data about you. Please read our Terms and Conditions for more information.
3. Data use within the Mobile app
3.1 None of the information in clause 2.1 will be given to other people via the Mobile app, except your first name, location and gender which will appear on your Profile. We will assign you a username which you can use on the Mobile app. Other Members will only know your username and other information should you choose to tell them.
3.2 When you fill in your Profile, the information provided will be available to other users of this Mobile app. The information you provide to us as part of your Profile should exclude anything that could allow you to be specifically identified or contacted outside the Mobile app. Your Profile is a page on Hallowed Ones which shows your photos and the answers you provide On Registration. You can edit your Profile at any time, and it’s up to you to keep it up to date. Your Profile can be seen only by other Members of Hallowed Ones, however, we can’t control who registers on Hallowed Ones and therefore you should be careful about what you choose to share. Your Profile will be promoted alongside your photo to other users through recommendations and search results on the Mobile app, and in email communications, push notifications and SMS recommendations.
3.3 When completing your Profile there are several questions, and some of these are mandatory for you to be able to use the Mobile app, the remainder are discretionary. We do not allow you to add your private email address, surname, address or other contact details into your Profile, so other users will not have access to this information unless you choose to send it to them via the messaging system. We moderate and remove any such private information from your Profile that we become aware of, but please note that if you include such information in your Profile, we may not always be able to recognise and remove it. You can update your Profile at any time.
3.4 Any person can visit parts of the Mobile app without being a member. They will be able to see extracts from media articles, success stories and testimonials from others. They will not be able to access the majority of the Mobile app nor see full Profiles. What is our legal basis? It is also in our legitimate interest to use your Personal Information in such a way to ensure that we provide and promote the very best service we can to you and others. And voluntarily submitting stories or comments we rely on your consent to use the Personal Information in this way.
4. How we use the Personal Information we collect about you (in addition to section 3 above)
4.1 Contact information is used by us to communicate with you. This includes notifying you about messages from other Members, providing information about The Service, responding to any questions or requests you may make, confirming receipt of communications from you, or if we need to contact you for any reason.
What is our legal basis? It is necessary for us to use your Personal Information to provide The Service to you and perform our obligations in accordance with the contract that we have with you. It is also in our legitimate interest to use your Personal Information in such a way to ensure that we provide the very best service we can to you.
4.2 Profile information is posted on the Hallowed Ones Mobile app and is used to promote you to our other Members. As such, it may be viewed by any other Member on the Mobile app.
What is our legal basis? It is necessary for us to use your Personal Information to provide The Service to you and perform our obligations in accordance with the contract that we have with you. It is also in our legitimate interest to use your Personal Information in such a way to ensure that we provide the very best service we can to you.
4.3 If you send emails to other Members they are also stored on our own systems and are visible to us. Your Personal Information provided voluntarily by you and collected by your use of the Mobile app is used to better understand our Members and to help us improve and promote our services.
What is our legal basis? It is in our legitimate interest to use your Personal Information in such a way to ensure that we improve The Service and provide the very best service we can to you.
4.4 Success stories may be posted on our Mobile app and social media pages, and/or included in emails to Members to help promote our services. If you submit a success story or testimonial to us, Hallowed Ones will assume that all people mentioned in a success story are happy for the success story to be used in this way, unless you request otherwise.
What is our legal basis? By voluntarily submitting stories or comments we rely on your consent to use the Personal Information in this way.
4.5 Internal record keeping and legal compliance. Complaints are investigated as appropriate. The fact of the complaint may be recorded and details stored in case of future complaints against the same Member. See section 6 below for more information.
What is our legal basis? It is in our legitimate interest to store your Personal Information in this way to comply with and/or enforce our legal rights and obligations, and to protect the rights of third parties.
4.7 We may send you information about our events or products, including newsletters and other marketing materials electronically or by post.
What is our legal basis? By voluntarily agreeing to receive electronic marketing we rely on your consent. Otherwise, it is in our legitimate interest to use your Personal Information for postal marketing.
4.8 Profiling. We may use your information for customer profiling to ensure that we create and market the most suitable products and services to you. This may include: To promote your Profile to other Members who may be most interested in meeting you To identify individuals who would benefit from additional promotion to other Members To identify fraudulent or misleading behaviour To identify users who may be receptive to a particular promotion or offer; and To recommend users to other users based on their attributes and behaviour. What is our legal basis? It is in our legitimate interest to use your Personal Information in such a way to ensure that we provide the very best service we can to you.
4.9 Data Analytics. We use data about your behaviour and use of the mobile app for the following reasons: to identify potential fraud by comparing genuine behaviour with known fraudulent behaviour; to help us plan targeted marketing and advertising campaigns, by looking at how particular groups of users are using The Service; to help us understand what behaviours are more likely to result in a successful experience (typically finding a partner), so that we can pass on advice to Members, and we can improve the design of The Service to achieve a higher success rate by encouraging the kind of behaviour that is more likely to yield a success; What is our legal basis? Where your Personal Information is completely anonymised, we do not require a legal basis as the information will no longer constitute Personal Information. However, where your Personal Information is not in an anonymous form, it is in our legitimate interest to continually evaluate that Personal Information to ensure that the products and services we provide are relevant to the market and provide the very best service we can to you.
5. Passing on Information about you
5.1 Hallowed Ones uses various third party providers to help provide The Service to you. These third parties process your Personal Information on our behalf for the purposes of mobile app administration, payments, development and back-up.
What is our legal basis? It is in our legitimate interest to share your Personal Information in such a way to ensure that we provide the very best service we can to you. Where we share your sensitive Personal Information (eg religious or political views, or health or sexuality information), we shall be relying on your consent to do so which you provide if you choose to submit such information.
5.2 We do not pass your information to third parties for marketing purposes.
5.3 In certain circumstances we may need to disclose information about you to legal advisors or to law enforcement authorities if you breach this privacy policy and/or the Terms and Conditions of this Mobile app. We may also disclose or access your account if required to do so by law or any other Governmental body.
What is our legal basis? It is in our legitimate interest to share your Personal Information with such third parties to enable them to process your information on our behalf, to comply with and/or enforce our legal rights and obligations, and to protect the rights of third parties.
5.4 In the event that we sell any of our business or assets, we will disclose your personal data to the prospective buyer of such business or assets. If Ekobridge Limited or substantially all of its assets are acquired by a third party, any personal data held by it in relation to its customers (including you) will be one of the transferred assets.
What is our legal basis? It is in our legitimate interest to share your Personal Information with such third parties to facilitate business transactions and to enable continuity of service for the benefit of our Members.
5.5 We may disclose aggregate but not individual statistics to potential advisors, for example, number of users, typical ages, locations.
What is our legal basis? It is in our legitimate interest to share your Personal Information in such a way to ensure that we improve The Service and provide the very best service we can to you. 5.6 We are considering becoming a member of the Online Dating Association (ODA). The ODA helps to ensure the safety, and protect the vital interests, of those who use dating mobile apps in the UK. In helping to ensure the safety of users, if a user's actions or behaviour on Hallowed Ones cause us to become aware of or reasonably suspect that the user may be guilty of, or may commit, a serious offence then we may (at our sole discretion) share information about such user (which may include sensitive personal data) and the serious offence with the ODA who may in turn share this information with other members of the ODA. Where we do share such user's information we will only disclose such information as is strictly necessary for the purpose of the ODA and its members reviewing the serious offence and whether or not it would be appropriate to block such users them from any mobile apps. In certain circumstances we may disclose information about a user in relation to a serious offence to the police or users at risk where we believe it is in the vital interests of those users. In this section the term "serious offence" includes, but is not limited to: racist, sexist or discriminatory, physically or sexually threatening actions or comments; actually or attempting to defraud other users; actions such as stalking or harassment which could cause a user serious distress; and repeated offences which in isolation are not considered serious but collectively display a pattern of behaviour which may cause other users harm or serious distress.
What is our legal basis? It is in our legitimate interest, or may be a legal obligation, or may be in the vital interests of a member of the public to share your Personal Information with third parties to enable them to process your information on our behalf, to comply with and/or enforce our legal rights and obligations, or to protect the rights of third parties.
6. Fraud and inappropriate behaviour
We share details about your web browser, IP address, email address, address, name and the pages you view on Hallowed Ones mobile app with specialist security services who help us identify fraudulent users. The Services provide us with a report that indicates the likelihood that the user has been involved in fraudulent activity online in the past. We do this to make Hallowed Ones as safe as possible to use. What is our legal basis? It is in our legitimate interest, or may be a legal obligation, or may be in the vital interests of a member of the public to use your information in this way and to share your Personal Information with third parties, to comply with and/or enforce our legal rights and obligations, or to protect the rights of third parties.
7. Hallowed Ones staff and contractors’ use of and access to information
7.1 Hallowed Ones employees and contractors may also be a Member of the Mobile app, and their employment may give them access to information not generally available to other Members of Hallowed Ones or the general public. They will not use personal contact information or other Personal Information held by Hallowed Ones for any purpose other than the performance of their jobs. If in contact with another Member, they shall disclose the fact that they are working for Hallowed Ones in one of the first two emails.
8. Where your data is stored
8.1 The data that we collect from you may be transferred to and stored at, a destination outside the European Economic Area ("EEA"). By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy. Our current hosting provider has signed up to Privacy Shield.
9. Security
9.1 Keeping information about you secure is very important to Hallowed Ones. We exercise great care in providing secure transmission of all your information from our computer servers. However, no data transmission over the Internet can be guaranteed to be totally secure. As a result, whilst we strive to protect your Personal Information, we cannot ensure or warrant the security of any information which you send to us, and you do so at your own risk.
9.2 Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Mobile app, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
9.3 If a visitor or other Member of the Mobile app copies or distributes information on your Profile, they are in breach of copyright and acting illegally. If the media uses information from any part of the Mobile app without permission, they are in breach of copyright, but Hallowed Ones cannot be held responsible where this has occurred.
10. How long do we keep your Personal Information for?
We keep your Personal Information on the Hallowed Ones database for up to 36 months since you last logged in. Where your information is stored in a third party service (such as our helpdesk, analytics or customer support email software), we will keep your data for up to 36 months or the closest option available to us. If your account has been banned for breaking terms and conditions or has been involved in fraud, then we may keep your data for longer, in order to protect other users of The Service. In considering how long to keep it, we will take into account its relevance to our business and our legal and regulatory obligations.
11. How to access your information and your other rights
You have the following rights in relation to the Personal Information we hold about you: 11.1 Your right of access. If you ask us, we’ll confirm whether we’re processing your Personal Information and, if so, provide you with a copy of that Personal Information (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.
11.2 Your right to rectification. If the Personal Information we hold about you is inaccurate or incomplete, you’re entitled to have it rectified. If we’ve shared your Personal Information with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your Personal Information with so that you can contact them directly.
11.3 Your right to erasure. You can ask us to delete or remove your Personal Information in some circumstances such as where we no longer need it or you withdraw your consent (where applicable). If we’ve shared your Personal Information with others, we’ll let them know about the erasure where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your Personal Information with so that you can contact them directly.
11.4 Your right to restrict processing. You can ask us to ‘block’ or suppress the processing of your Personal Information in certain circumstances such as where you contest the accuracy of that Personal Information or object to us processing it. It won’t stop us from storing your Personal Information though. We’ll tell you before we lift any restriction. If we’ve shared your Personal Information with others, we’ll let them know about the restriction where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your Personal Information with so that you can contact them directly.
11.5 Your right to data portability. With effect from 25 May 2018, you have the right, in certain circumstances, to obtain Personal Information you’ve provided us with (in a structured, commonly used and machine-readable format) and to reuse it elsewhere or ask us to transfer this to a third party of your choice.
11.6 Your right to object. You can ask us to stop processing your Personal Information, and we will do so if we are: relying on our own or someone else’s legitimate interests to process your Personal Information except if we can demonstrate compelling legal grounds for the processing; processing your Personal Information for direct marketing; or processing your Personal Information for research unless such processing is necessary for the performance of a task carried out in the public interest.
11.7 Your rights in relation to automated decision-making and profiling. You have the right not to be subject to a decision when it’s based on automatic processing, including profiling, and it produces a legal effect or similarly significantly affects you unless such profiling is necessary for entering into, or the performance of, a contract between you and us.
11.8 Your right to withdraw consent. If we rely on your consent (or explicit consent) as our legal basis for processing your Personal Information, you have the right to withdraw that consent at any time.
11.9 Your right to lodge a complaint with the supervisory authority. If you have a concern about any aspect of our privacy practices, including the way we’ve handled your Personal Information, you can report it to the UK Information Commissioner’s Office (ICO). You can find details about how to do this on the ICO mobile app at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113.
12. Cookies
12.1 We use a number of different cookies to make this mobile app as useful as possible. Cookies are small text files that are stored on your computer to track usage of our mobile app and remember some basic settings. For example, we use them to keep you logged in to the Mobile app, to help analyze mobile app traffic and trends and to provide you with services and offers tailored to your interests. To learn more about cookies and how to manage them, read The Ultimate Guide to Cookies. 12.2 Currently we operate an implied consent policy which means that we assume you are happy with this usage. If you are not happy then you should either discontinue use of this mobile app, delete the cookies, or where possible, browse this mobile app using your browser's anonymous usage mode (called Incognito in Chrome, InPrivate for Internet Explorer, Private Browsing in Firefox and Safari etc.). Any changes to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by email or when you log in to your mobile app account. Please check back frequently to see any updates or changes to our privacy policy. If you have any questions relating to this Privacy Policy or how we use the Personal Information we have about you, please contact us. Email: privacy@hallowedones.com