Plankton Privacy Policy

This document explains how we collect, store, protect, and share your information, and with whom we share it. We suggest you read this in conjunction with our Terms and Conditions of Use.

Whilst you’re using the Plankton App (“App”), our websites and microsites (such as plankton-labs.com) (referred to in this Privacy Policy as our “Sites”), we collect some information about you. In addition, you may choose to use the App or Sites to share information with other users, including your friends and contacts (“Users”). We may also need to share your information sometimes.

The App and Sites are global, and your information will be sent to and used in the United States and the UK regardless of the country you reside in. This Policy explains how we protect your personal data when we transfer it overseas, so please read very carefully!

Who we are

The App and Sites are operated by the “Plankton Labs” (also referred to in this policy as “we” or “us”) which are controllers of personal information collected and processed through the App and Sites.

1. COLLECTION OF INFORMATION

Registration Information

When you download the App and create an account (“Account”), we may collect certain information (“Registration Information”) about you, such as:

Once you register, you will be able to review and change this information at any time just by logging in to Plankton. It is your responsibility to ensure that your account details are kept up to date.

The information we collect helps to enhance the App and verify our Users. Registration Information such as your sexual preference, name may be visible to other Users who view your profile page.

For Users who are California residents, the data we may collect falls within the following categories of “personal information”, as defined by the California Consumer Privacy Act (CCPA):

  1. Identifiers, such as name and location;
  2. Personal information, as defined in the California customer records law, such as contact (including email and telephone number) and financial information;
  3. Characteristics of protected classifications under California or federal law (if you choose to provide them), such as age, gender identity, marital status, sexual orientation, race, ancestry, national origin, religion, and medical conditions;
  4. Commercial information, such as transaction information and purchase history;
  5. Biometric information (not relevant here);
  6. Internet or network activity information, such as browsing history and interactions with our Sites and App;
  7. Geolocation data, such as mobile device location;
  8. Audio, electronic, visual and similar information, such as photos and videos;
  9. Professional or employment-related information, such as work history and prior employer;
  10. Non-public education information; and
  11. Inferences drawn from any of the personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.

Device Information

We may collect information about your device when you use the App including the unique device identifier, device model, operating system, and MAC address, for a number of purposes, as set out in this policy.

Links

We may keep track of how you interact with links available on Plankton including third party services by redirecting clicks or through other means. We may share aggregate click statistics such as how many times a particular link was clicked on.

When you Contact Customer Support or Give Feedback

We will receive your email address, and may track your IP address, as well as the information you send to us to help resolve your query. We will keep records of our communications with you, including any complaints that we receive from you about other Users (and from other Users about you) for 6 years after deletion of your account.

Cookies and similar technologies

When you visit our Sites or when you use our App, we may collect personal data from you automatically by using cookies or similar technologies. A cookie is a small file that can be placed on your device or browser that allows us to recognise and remember you.

2. USE OF YOUR INFORMATION

Data Purpose Source
Name, email address To provide you with the Plankton social networking service, sending updates, promotion via email. You provide this information to us through a third-party social networking service such as Facebook
Optional information that you choose to provide in your profile which may include: Sexual preferences, non-binary gender, occupation, location preferences, photos To facilitate networking opportunities on the Plankton App You provide this information to us
Log and usage data, including IP address, browser type, referring domain, pages accessed, mobile carrier and search terms (CCPA Categories F and H) To carry out research and analysis to help us improve the App We obtain the log and usage information from the device that you use to access the service
Email address and IP address, social media name (CCPA Categories B and F) To respond to correspondence and queries that you submit to us, including social media queries You provide your email address, social media name to us when you contact us and we obtain your IP address from the device that you use to contact us
Name and user registration details, profile information, content of messages and photographs + usage and device data such as IP address and IP session information (CCPA Categories A, B, C, F, and H) To investigate and block Users for reported infringements of our Terms and Conditions of Use You provide your registration details, profile information, messages and photographs to us. We obtain the other information from the device that you use to access the service.
Data from Facebook and other third-party accounts (see section 7 of this Privacy Policy for more details) (CCPA Categories A, B, C, and H) To enable Users to create and enhance their Plankton profile and log into the App via third party accounts We obtain this information from Facebook, or the providers of any other accounts you use to log in or connect with your Plankton account
Email address (CCPA Category B) To contact you in order to run surveys for research purposes and to obtain feedback, and to find out if you want to take part in marketing campaigns You provide this information to us
This could include any information that is relevant to the issue To defend legal claims, protect legal rights and to protect people from harm This information may be obtained directly from you, from your device or from third parties, depending on the information involved

3. DISCLOSURE OF INFORMATION

Our policy is to not disclose your Registration Information or personal data, except in the limited circumstances described here:

Circumstances where data may be disclosed Disclosed data
Moderators – To monitor activity on the App and approve content. Name and user registration details, profile information, content of messages and photographs (CCPA Categories A, B, C, and H)
Law and Harm – As we mentioned in the Terms & Conditions, we think it is very important that all Users behave whilst using the App. We will cooperate with all third parties to enforce their intellectual property or other rights. We will also cooperate with law enforcement enquiries from within or outside your country of residence where we are required to by law, where there is an investigation into alleged criminal behaviour or to protect the vital interests of a person. This may include preserving or disclosing any of your information, including your Registration Information, if we believe in good faith that it is necessary to comply with a law or regulation, or when we believe that disclosure is necessary to comply with a judicial proceeding, court order, or legal request; to protect the safety of any person; to address fraud, security or technical issues e.g. through anti-spam providers to protect the service from criminal activity or to protect our rights or property or those of third parties. In such cases we may raise or waive any legal objection or right available to us. This could include any personal data that Plankton holds about you, depending on the nature of the request or the issue that we are dealing with, including all CCPA Categories listed above
Business transfer - In the event that a Plankton Labs entity or any of its affiliates undergoes a business transition or change of ownership, such as a merger, acquisition by another company, re-organisation, or sale of all or a portion of its assets, or in the event of insolvency or administration, we may be required to disclose your personal data. This could include all personal data that Plankton holds about you, including all CCPA Categories listed above
Anti-Spam and Anti-Fraud – Your data may be shared with Plankton Labs, for example, to block accounts and suspected fraudulent payment transactions as part of our anti-spam and anti-fraud procedures. Email address, phone number, IP address and IP session information, social network ID, username, user agent string, and transaction and payment data (CCPA Categories B, F and D).

Aggregated Information – We may share aggregated information with third parties that includes your personal data (but which doesn’t identify you directly) together with other information including log data for industry analysis and demographic profiling.

Plankton does not sell your data and has not sold your personal data in the previous 12 months.

MORE INFORMATION ABOUT DISCLOSURES

Sharing your personal data with Service Providers

We engage certain trusted third parties to perform functions and provide services to us (“Service Providers”). The suppliers with which Plankton shares User personal data vary depending on a variety of factors, such as which of our App, Sites and services a User engages with. For example, to provide our services to Users, we typically use the following suppliers:

We carry out due diligence on all Service Providers we engage to ensure they have adequate data protection and information security measures in place and only provide them with the personal data necessary to the service they are providing. Measures are taken to ensure that the data shared is non-attributable to the greatest extent possible and our suppliers are also subject to extensive obligations under our contractual arrangements, including strict data retention limits.

4. WHAT OTHERS MAY SEE ABOUT YOU

When using the Plankton App, you should assume that anything you post or submit on the App may be publicly-viewable and accessible, both by Users and non-users of the App. We want our Users to be careful about posting information that may eventually be made public.

Please be careful about posting sensitive details about yourself on your profile such as your religious denomination and health details. While you may voluntarily provide this information to us when you create your profile, including your sexual preferences, there is no requirement to do so. Please remember that photographs that you post on Plankton may reveal information about yourself as well. Where you do upload and choose to tell us sensitive information about yourself, you are explicitly consenting to our processing of this information and making it public to other Users.

Your Plankton profile and other information you make available via the App, including certain information added to your profile through third party accounts (such as Facebook, Instagram or Spotify – see section 7 of this Privacy Policy for more information about this) may be viewed and shared by Users with individuals who may or may not be users of the App. For example, a User may recommend you as a match to his or her Facebook friend(s) by taking a screenshot of your profile picture and sharing it, regardless of whether such friend(s) is also a User of the App.

If you log in to or access the App through your Facebook account or another third-party account on a device which you share with others, remember to log out of the App and the relevant third-party account when you leave the device in order to prevent other users from accessing your Plankton account.

5. OUR POLICY TOWARDS AGE

Plankton does not knowingly collect any information about or market to children, minors or anyone under the age of 18. If you are less than 18 years old, we request that you do not submit information to us. If we become aware that a child, minor or anyone under the age of 18 has registered with us and provided us with personal information, we will take steps to terminate that person’s registration.

6. SECURITY

We pride ourselves on taking all appropriate security measures to help protect your information against loss, misuse and unauthorised access, or disclosure. We use reasonable security measures to safeguard the confidentiality of your personal information such as secured servers using firewalls.

Unfortunately, no website or Internet transmission is ever completely 100% secure and even we cannot guarantee that unauthorised access, hacking, data loss or other breaches will never occur, but here are some handy tips to help keep your data secure:

  1. Please make sure you log out of your Account after use as you never know who may stumble onto your Account!
  2. Please don’t share the password you use to access your Plankton Account with anyone else!
  3. Change your password periodically.

We cannot guarantee the security of your personal data while it is being transmitted to our site and any transmission is at your own risk.

7. Using your social media details to sign in to Plankton

When you sign in to our App using your Facebook account, you give permission to Facebook to share with us your name, email and profile picture.

We will then use this personal data to form your Plankton account. If you remove the Plankton app from your Facebook settings we will no longer have access to this data. However, we will still have the personal data that we received when ou first set up your Plankton account using your Facebook (you must delete your lankton account entirely for us to no longer have access to this data).

8. YOUR CALIFORNIA PRIVACY RIGHTS

For Users who are California residents, you have the following rights (in addition to those listed at section 10 below) under the California Consumer Privacy Act, and you have the right to be free from unlawful discrimination for exercising your rights under the Act:

  1. You have the right to request that we disclose certain information to you and explain how we have collected, used and shared your personal information over the past 12 months.
  2. You have the right to request that we delete your personal information that we collected from you, subject to certain exceptions.

California’s “Shine the Light” law, Civil Code section 1798.83, requires certain businesses to respond to requests from California customers asking about the businesses’ practices related to disclosing personal information to third parties for the third parties’ direct marketing purposes. If you wish to find out about any rights you may have under California Civil Code section 1798.83, you can write to us at feedback@plankton-labs.com.

From time to time, as part of a joint promotion with a third party, we may, if you participate in such promotion, disclose your contact information to the third party to allow them to market their products or services to you. Where this is a condition for participation in a promotion, we will always let you know before when you enter the promotion. Please follow the instructions provided to you by third parties to unsubscribe from their messages.

In addition, under California law, operators of online services are required to disclose how they respond to “do not track” signals or other similar mechanisms that provide consumers the ability to exercise choice regarding the collection of personal information of a consumer over time and across third party online services, to the extent the operator engages in that collection. At this time, we do not track our Users’ personal information over time and across third-party online services. This law also requires operators of online services to disclose whether third parties may collect personal information about their users’ online ctivities over time and across different online services when the users use the operator’s service. We do not knowingly permit third parties to collect personal information about an individual User’s online activities over time and across different online services when using the App.

9. YOUR RIGHTS

Privacy laws applicable in your country may give you the following rights:

  1. Right to be informed: what personal data an organisation is processing and why (we provide this information to you in this Privacy Policy).
  2. Right of access: you can request a copy of your data.
  3. Right of rectification: if the data held is inaccurate, you have the right to have it corrected.
  4. Right to erasure: you have the right to have your data deleted in certain circumstances.
  5. Right to restrict processing: in limited circumstances, you have the right to request that processing is stopped but the data retained.
  6. Right to data portability: you can request a copy of certain data in a machine-readable form that can be transferred to another provider.
  7. Right to object: in certain circumstances (including where data is processed on the basis of legitimate interests or for the purposes of marketing) you may object to that processing.
  8. Rights related to automated decision-making including profiling: there are several rights in this area where processing carried out on a solely automated basis results in a decision which has legal or significant effects for the individual. In these circumstances your rights include the right to ensure that there is human intervention in the decision-making process.

The particular rights which are applicable to you (which might include other rights not listed above) may vary depending on your country. You should make yourself aware of the rights you have under applicable privacy laws in your country.

If you feel we have not resolved your concern, you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). If you live in a country or territory located in the European Union (EU) or European Economic Area (EEA), you may also get in touch with your local Data Protection Regulator. If you live in a country outside the EU, you may have the right to lodge a complaint with your local privacy or data protection regulator.

10. DATA RETENTION AND DELETION

We keep your personal information only as long as we need it for the legal basis relied upon (as set out in Section 2 above) and as permitted by applicable law.

When you delete your Account, or it is deactivated by us, we make sure it is no longer viewable in the App, this may take times to propagate to all the users of the app that have visibility to "Your Contents". We will delete your personal information from our systems, unless:

  1. we must keep it to comply with applicable law (for instance, if you make purchases within the App, some personal data may be kept for tax and accounting purposes);
  2. we must keep it to evidence our compliance with applicable law (for example, if an account is blocked, we keep some account information and a record of the behaviour that led to the block - this information is retained for evidential purposes in case of queries or legal claims concerning the block);
  3. there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or
  4. the information must be kept for our legitimate business interests, such as fraud prevention and enhancing Users’ safety and security (for example, information may need to be kept to prevent a user who was banned for unsafe behaviour or security incidents from opening a new account).

Warning: Even after you remove information from your profile or delete your Account, copies of that information may still be viewable and/or accessed to the extent such information has been previously shared with others, or copied or stored by others. We cannot control this, nor do we accept any liability for this. If you have given third party applications or websites access to your personal information, they may retain such information to the extent permitted under their terms of service or privacy policies.

11. CHANGES TO THIS POLICY

As Plankton evolves, we may revise this Privacy Policy from time to time. The most current version of the policy will govern our use of your information and will always be at plankton-labs.com/privacy-policy. If we make a change to this policy that, in our sole discretion, is material, we will notify you, for example, via an email to the email associated with your Account or by posting a notice within Plankton.

Effective date

This Privacy Policy was last updated 20 December 2021.