Privacy Policy
Version: July 17th 2024
Thank you for using eharmony!
Please note that we offer our Service (as defined below) in different countries and as such, you understand that the information included in your profile will be visible to our members in all of these countries. You can see the list of these countries on our website. You will also be able to search for a partner in any of these countries, not just your own country. We offer our Services outside the United-Kingdom in the USA, Australia, and Canada.
This privacy policy explains what personal data eharmony collects, how we use this data and what rights you have in relation to your personal data as an eharmony user.
You can find information about data processing in connection with Cookies and other tracking technologies when using the eharmony website and app in our cookies & tracking policy.
Table of Contents:
- Contact / Data Controller
- Collection, processing and use of personal data
- Processing purposes
- Legal basis for the processing of personal data
- Transfer of data to third parties; service provider
- How do we protect your personal data?
- Duration of storage; retention obligations
- Are you obliged to provide us with personal data?
- Rights of the data subject at a glance
- Social Media
- Cookies & tracking technologies
Contact / Data Controller
Unless otherwise stated in this privacy policy or in our cookies & tracking policy, the controller of your personal data is eHarmony UK Ltd., 3rd Floor, 1 Ashley Road, Altrincham, Cheshire, WA14 2DT United Kingdom (hereafter “eharmony”, “us”, “our”, “we”).
If you have any questions or suggestions about how we use your personal data, please contact us or our data protection officer.
Our contact details are as follows:
eHarmony UK Ltd., Customer Care, 3rd Floor, 1 Ashley Road, Altrincham, Cheshire WA14 2DT, United Kingdom, privacypolicy@eharmony.co.uk (email)
You can reach our data protection officer at:
eharmony UK Privacy Team, privacy@eharmony.co.uk (email)
Collection, processing and use of personal data
Personal data is any information relating to an identified or identifiable natural person (e.g., name, address, phone number, date of birth or e-mail address). When we say that we process personal data, this means that we collect, store, use, transfer to others or delete such data.
eharmony collects and processes your personal data exclusively in the following cases:
- If you install our eharmony app.
- If you visit us on our website without being a member.
- If you contact us.
- If you subscribe to an eharmony membership (paid or free).
Once you have signed up for an eharmony account, a contract is formed and we will provide you with access to an online database over which you will be able to get know other eharmony-registered customers (also known as members). In order to provide you with the eharmony service as described in the General Terms and Conditions (the “eharmony Service” or “Service”), we need to use your personal data. If you do not want us to use your personal data or parts thereof, we will not be able to provide you with the Service. You will also need to provide us with special categories of personal data (i.e. sensitive personal data, such as information about gender or your sexual orientation). Please see below for further information about the types of personal data eharmony collects when you use our Service.
Data processing through app stores
Before you can install our app, you may have to enter into a user agreement with an app store operator (e.g. Google or Apple). Our app is available on different app platforms, depending on your particular operating system.
In order to install and use our app via these app stores, you will need to have a valid account with the app store operator as well as a compatible device (e.g. a smartphone). eharmony has no control over the collection, processing and use of personal data in this respect. The relevant app store operator will be the sole data controller of this information. If necessary, please contact the operator of the respective app store directly for information about their data processing. eharmony is the data controller with respect to your personal data only when you use the eharmony app.
What personal data does eharmony collect from its members to fulfil the contractual relationship?
In order to register for the eharmony Service and conclude a Basic Membership or a Premium Membership, you will need to provide us with the personal data described below. In addition, in order to provide you with our Services (as more fully described in the General Terms and Conditions), we need to process this personal data.
Registration process
In order to register for eharmony’s free Service (i.e., conclude a “Basic Membership”), you will need to provide us with personal data, without which the registration cannot be completed. These data are:
- Gender and sex of partner sought (as data regarding your sexual orientation and therefore sensitive personal data)
- Email address
- Password
If you have chosen to log in via a third-party provider such as Google, Facebook or Apple, you do not need to enter an email address or a password during the registration process. You can access eharmony’s Service respectively with the email address and the password you have indicated (your access data) or alternatively via the third-party provider’s login data.
Registration/Login via Google (“Google Sign in”)
We give you the option to register or log into our website using your Google account. If you do this, we will obtain the data required for registration or login (e-mail address, name, Google Account ID, and Google Account profile picture) from Google. Data is transferred in this respect.
We have no control over the scope of the data collected by Google using the Google login. If you would not like Google to collect data about you related to your use of our online offering and to use it for its own purposes, you should not use the Google login.
You may dissociate your Parship account from your Google-ID at any time in your profile on our website. In this case, you will need to establish alternative access data, as explained above.
Further information about the purpose and scope of the collection and the further processing and use of your data by Google, as well as the rights and settings options for protecting your data, is available in Google’s Privacy Policy:
During registration via Apple (“Sign in with Apple”)
You can register to join the eharmony Service using your Apple-ID. If you choose to do this, we will receive the information that we need for your registration directly from Apple. In this respect, a data transfer takes place. Apple enables you to share the email address associated with your Apple account with eharmony or hide it. If you hide your email address, we will receive a randomly generated unique email address from Apple for the creation and use of your eharmony account. Our communications will be sent to this email address and automatically forwarded by Apple to your email address, if you have not deactivated forwarding of eharmony emails.
Please be aware that we have no control over the type and amount of information that Apple collects about you when you register for our Service using the Apple login. If you do not want Apple to collect information about you in relation to your use of our Service, you should not use the Apple login.
You may dissociate your eharmony account from your Apple-ID at any time in your profile on our website. In this case, you will need to establish alternative access data, as explained above.
For more information about the types of information collected by Apple and how Apple uses your information, as well as about your rights and your ability to protect your data, please see Apple’s Privacy Policy.
Data required in connetion with a Basic Membership
Our Service works by providing your profile information (“profile”) and your compatibility scores to other eharmony users. In order to get the full benefit of our Service and to set up your eharmony profile, we will ask you to provide us with data about yourself. This may include information about your personal values and preferences, your appearance, and any other characteristics that are relevant for us to establish your personality profile and to recommend potential partners (“partner suggestions”) to you. When designing your profile, you will also need to provide us with information about yourself, including text and photos. In addition, we also collect information about you when you provide your answers to the eharmony test (“compatibility quiz”) and we will use this information to automatically create your eharmony personality evaluation (“personality profile”). Please note that, although you will be able to read your personality profile and compatibility scores in your profile, your personality profile is not generally publicly visible to other eharmony members. Instead, those members who directly access your profile information will only have access to extracts of your personality profile and your compatibility score.
When we ask you to provide us with information about you during the registration process, we make it clear when such information will be kept private and will not be made available to other users. Please note that your specific answers to eharmony’s compatibility quiz are generally kept private, however, the compatibility scores that we generate from your answers are made publicly available to other members. Additionally, the information you voluntarily provide for hobbies and interests within the quiz will be visible to your partner suggestions in your profile, but you may update or delete this information at any time. All other information you provide us with for or as part of your eharmony profile will be publicly visible to other members on our website and our app, such as information that you voluntarily choose to include in your profile, especially your first name, place of residence / first two digits of the postal code, and your interests.
We will not be able to suggest matches for you if you do not provide us with the requested information relating to your sexual preferences (i.e. both preferred sex and gender), or the other information requested as part of the eharmony compatibility quiz. If you do not want to provide us with this information, you will not be able to use our Service.
The types of data that we will collect during the registration are as follows:
- Residence/postal code
- Country of residence
- Date of birth
- Full name
- Height
- Number of children
- Marital status
- Education level
- Occupation
- Income
In addition, you may choose to provide us with sensitive information such as:
- Religion
- Ethnicity
- Political view.
By giving us this information, you agree that we can store and use this information for matching purposes. This information allows us to further refine the match preferences and search criteria available to you when searching for a partner on our platform. This information will be disclosed in your profile, and therefore, visible to partner suggestions who visit your profile. However, please note that you do not have to provide us with this information in order to use the eharmony Service, and you may change your answers to “prefer not to specify” in the religion, ethnicity and/or political view fields at any time in your profile.
You may also upload photos of yourself in your profile, whereby other members may see, next to your first name, your photos clearly (i.e. unblurred version) or in a blurred version via email. Please note that you do not have to upload any photos in order to use the eharmony Service. You may upload photos to your profile at any time, even after you completed your registration or already used the Service for a period of time.
You do not have to provide us with your mobile phone number in order to use the eharmony Service. However, if you want to, you can provide it to us for an additional security measure (known as “SMS verification”). This functionality is available to all our members but only after logging in to our eharmony Service. This will allow us to carry out a further identification check to make sure that you are the right person to be using your profile – please see more on this below (see the section “Processing purposes”).
Upon Completion of a Premium Membership
If you decide to sign up for eharmony’s Premium chargeable features (“Premium Membership”) via the website (i.e. you decide to become a Premium member), we will collect your payment data during your order. However, please note that your credit card data, PayPal- and SEPA- data is not stored by us, but is instead stored by the corresponding third party payment provider.
Ordering virtual goods
If the user decides to extend his basic membership by ordering virtual goods (e.g. Match Unlocks), the following data will be collected within the order in addition to the data collected during the basic membership:
- Payment data (credit card data, Paypal and SEPA data are stored by the payment provider and not by eharmony).
Orders via third parties
If you purchase a Premium Membership or virtual goods via an app store provider (e.g. Google or Apple), please refer to the terms of use of the relevant app platform operator to find out which personal data they process in relation to the purchase process. eharmony does not process any payment or billing data in this respect.
Communication with members, communication with our customer care
If you correspond with other eharmony members through the eharmony platform, or with eharmony customer care, we will collect and store this information. The messages sent between members via our Service are end-to-end encrypted. (You can read more about how we keep your information safe in the section “How do we protect your personal data?” below).
If you contact our customer care, please note the following: If you communicate with our customer care:
- using the online contact form: the content of your message to us will be encrypted in transit; our reply will be protected in transit, provided that your email provider supports Transport Layer Security (TLS) transfer encryption.
- via email: the content of your message to us will only be protected in transit via TLS transfer encryption if your email provider supports TLS transport encryption.
- (if available) via chat function for logged-in members in the customer service portal, the transmission of chat communication is TLS-encrypted (transport encryption). If the chat function is used with customer service, there is the possibility to provide a corresponding chat report.
Please note that communications between you and eharmony will generally only be conducted via the email address associated with your eharmony account. Members who are registered via Apple and have hidden their email address will only receive communications if the automatic forwarding function is activated through Apple. Please bear in mind that Apple does not inform us whether you have activated the forwarding function.
If you would prefer not to contact our customer care by email (for example, because you are concerned that your email provider does not support TLS encryption or the content of our email is not encrypted), please contact eharmony by post instead. You will find our contact details under Contact
Promotional emails – Messages
When you subscribe for our free membership (“Basic Membership”), you must enter your email address on the welcome page, or we receive your email address from Apple/ Facebook (if you register via a third-party login). Unless you opt out in the registration process, we will use this email address to send you promotional emails about eharmony’s free and for-purchase products.
In your profile under “Notification options,” you can also choose to receive personalised matches and guidance during your eharmony membership, to help you to get the most out of the eharmony Service.
As long as your email provider supports “Transport Layer Security” (TLS) transport encryption, these promotional emails (including our personalised guidance) are protected in transit via TLS transfer encryption.
You can object to our use of your email address for promotional purposes or personal guidance, upon registration or later at any time by: (i) clicking on the link in our emails to adjust your email notification settings, (ii) adjusting your settings in your profile under “Notification options”, or (iii) contacting us using the information in the Contact section. Members who have not yet completed the compatibility quiz may use this link for an objection. You may re-subscribe to receive such emails in your profile under “Notification options” at any time.
CRM messages channel (in chat)
Furthermore, there is the possibility that you will receive what are known as CRM messages via the electronic mailing route in the CRM message channel in the chat that has been set up for this purpose. If you no longer wish to receive the corresponding CRM messages, you may reject them at any time.
Push Messages
Our app may send you “push messages”, even when you are not currently using it. These will either contain messages that we send you as part of our Service, or they may contain advertising information.
You can stop receiving push messages or adjust your settings at any time on your mobile device or in the eharmony app.
What information does eharmony collect when using the eharmony website?
Every time you access the eharmony website, we will collect your usage data . This means that, even if you have not signed up to be an eharmony member, we will collect and use this information about you. We do this to understand how individuals interact with the website and how we might improve our services. This data is sent to us by your Internet browser and is stored in log files. Please note that each data point listed does not necessarily provide information that would identify you or any natural person. This data includes:
- Information about your browser type and your internet service provider, as well as your operating system (for example Windows 7, macOS, etc.)
- The IP address (Internet Protocol address) of the device you use to access our website or Service (for example, your computer, tablet or smartphone). We will also compare your IP address against a geo-database to collect information about your location, such as your country, state and city.In this context eharmony uses MaxMind (see explanations below, in the section “How do we protect your personal data?”)
- Information about the page that you have accessed
- The date and time that you used the website
- The referrer URL (origin URL) from which you came to the page that you have accessed
- Statistics about the amount of data transmitted during your use of the website
- Status message as to whether you were successfully able to access the website
- Session identifier
- Session participant´s pseudonym
- Screen resolution used on your device
Each time an eharmony member logs in to our network, we also collect their eharmony user identifier.
While using the website, and in addition to the data mentioned above, cookies or pseudonym IDs (such as user-ID, ad-ID) may also be stored on your device, when you visit, or after you visited, our online content. You will find specific information about this in our cookies & tracking policy.
What information does eharmony collect when using the eharmony app?
Every time you access the eharmony app with your device, eharmony automatically collects data and information from your device’s operating system. This includes, among other things, the storage of your IP address. In detail, eharmony collects:
Usage data
Every time you access the eharmony app, we will collect your usage data. This data includes:
- The operating system used to access the app and the browser type
- Your current language setting in your device
- Information about your Internet service provider
- The IP address (Internet Protocol address) of your device
- Your Device ID (e.g. IDFA, IDFV, Google Advertising ID) to identify your device for a secured authentication
- Your User identifier on the eharmony platform (only for eharmony members)
- Information about the part of the app that you have accessed and, if applicable, the webpage you accessed previously
- The date and time that you used the app
- Statistics about the amount of data transmitted during your use of the app
- Status message as to whether you were successfully able to access the app
- Session identifier
While using the app, and in addition to the data mentioned above, tracking technologies or pseudonym IDs (such as your AD-ID (e.g. the Apple IDFA (Identifier for Advertisers) or the Google Advertising ID) may also be stored on your device, when you visit, or after you visited, our online content. You will find specific information about this in our cookies & tracking policy.
Login data
We also collect the following usage data each time an eharmony member logs in to our network (“login records”):
- Date and time of login
- User identifier on the eharmony platform (your e-mail address)
- IP address (Internet Protocol Address)
- Device ID (e.g. UDID) to identify your device for a secured authentication.
While using the app, and in addition to the data mentioned above, pseudonym IDs (such as user-ID, ad-ID) may also be stored on your device, when you visit, or after you visited, our app. You will find specific information about this in our cookies & tracking policy.
GPS data when using the app
If a Premium Member turns on the “radius search” option, we also collect location data about their device (such as GPS, possibly WLAN information, and device ID) to determine their location. This information will be used to allow the Premium Member to set a suitable search radius to look for other members.
What information does eharmony process when you use the eharmony platform?
Part of our Service is providing you with potential partners (“matches”). These matches are presented to you in your profile and via notifications (e.g. emails), with the following information: first name, age, place of residence or postal code, a photo, compatibility score and a link to their profile. Please note that we may present you at any time as a match to other members, including those based outside the UK and/or using one of our other eharmony platforms. As such, your first name, age, place of residence or postal code, photo, compatibility score and a link to your profile will be provided to these members. In general, Basic Members will see only your photos blurred, but may be able, in some instances, to see your photos clearly (e.g., if they use Match Unlocks to unlock your profile or in the context of our testing of new functionalities). Premium Members will see your photos clearly.
In your profile, under “Notification options”, you may choose to receive notifications from us (e.g., emails or push messages) to alert you when there has been activity in your account (e.g. you have received a new message or we have new matches for you). Please note that whether you receive notifications or not, your matches who have requested notifications may still receive notifications related to you (e.g., when you send them a new message or we send your profile as a suggested new match). The notifications your matches received will include your first name, place of residence or postal code, photo, age, compatibility score and a link to your profile.
You may also request to be informed about: (1) which matches visited your profile (“visitors of my profile”) and/or (2) if your matches are currently online (green circle if they are online, or grey circle if they are not). Please note that if you request this information, the same information regarding your activity will be available to your matches who have also selected these notification options. As such, and subject to a match’s notification settings, (1) a match whose profile you visited may be informed of your visit, and (2) your matches may be notified when you are online or offline.
In addition, you are able to see the last time a match was online (“last time online”), and your matches are also able to see when you last logged in. This feature is set up automatically and, for technical reasons, cannot be deactivated.
Success stories
eharmony offers members who have met their partner on the eharmony platform the option of publishing their love story (success story) on the eharmony website or on other media. These success stories are available for all eharmony members and visitors to see online in the “Success stories” section of the eharmony website.
Your personal data in connection with your success story is processed on the eharmony platform or in other media processed subject to your prior written consent.
The following data is stored by eharmony in connection with success stories:
- Profile ID
- Email address
- Title, first name, surname
- Any pseudonym (if the name of a member was changed in the success story)
- Age
- Occupation
- Gender (especially for assignment in the product experience report in the sense of “experiences as a man/woman“)
- County or place of residence
- Any photos of the couple
- Information on children
- Telephone number
- The success story
- A link to where the success story and any photo(s) are published
- Any contacts between eharmony and members who share their success story
The following data is made available online: First name, any pseudonym, age, occupation, county, your success story and any other information with your consent.
You will receive further information on the processing and/or storage of your data if you choose to share your success story with us.
Processing purposes
eharmony processes the personal data of its users for the following purposes. The legal bases we rely upon are also stated. If data processing is based on the legal basis of a legitimate interest, we have also explained our legitimate interest:
- To provide the eharmony platform and thereby perform our Services as described in our General Terms and Conditions.In particular, this includes:
- Provision of our website for non-registered users;
- Use of our website and app for registered eharmony members;
- Ability to contact other users and respond to requests via the platform;
- Facilitation of the conclusion of a contract, incl. invoicing and contract termination processes;
- Sending emails and/or push messages regarding partner suggestions or other contractually relevant information.
- (The legal basis of processing is contractual necessity, i.e. to provide you with the services you have asked for from eharmony. In some cases, the legal basis is your consent.).
- For user experience testing (so-called A/B testing). (The legal basis is eharmony’s legitimate interest in improving the user-friendliness and enhancing the attractiveness of our website.)
- If applicable, upstream anonymization of data records for training purposes of our artificial intelligence systems (Art. 6 (4) GDPR applies here.)
- To provide a login via the eharmony platform, Google login, Facebook login or Apple login. (The legal basis of processing is contractual necessity.)
- For the prevention of and defence against abuse. eharmony automatically collects, processes and uses personal data and geodata we collect during your registration and the completion of the eharmony compatibility quiz and/or your eharmony profile, to check for any evidence of the misuse of the platform. This information is stored in a database and compared against empirical values and information. In addition, Customer Care representatives perform profile checks to check members’ profiles that have been reported by other members through the function “suspicious profile?” or as having breached our General Terms and Conditions. Furthermore, as mentioned above, if you have provided your mobile phone number, eharmony may use this information to carry out an identity check (SMS verification). (The legal basis for these activities is the legitimate interests of eharmony and our eharmony members, to ensure that the eharmony Service is not used in a way that is in breach of our General Terms and Conditions and/or the law. In doing so, we also comply with our legal obligation regarding data security to guarantee system security and to detect and trace unauthorised access attempts or accesses.)
- For purposes of data security (in particular, in accordance with our obligations under the UK GDPR). (We rely on the legal bases of our and our members’ legitimate interest (to ensure data is securely held and used and the eharmony service is not misused for contractual and / or illegal actions) and our legal obligation (to ensure system security and the detection and tracking of unauthorised access attempts or accesses)).
- For automated price determination reasons. This is achieved through the processing of some of your data automatically in order to offer you suitable products but this processing does not lead to any decisions being made about that you that might affect your use of the Service. The following data is used for this purpose: age, income, registration device (app or website). (The legal basis for these activities is contractual necessity as well as our legitimate interest in contacting our users through targeted and individual communications.)
- To ensure that you comply with your obligations under your subscription and our General Terms and Conditions, including your payment obligation (if you have made a purchase via eharmony). If you do not pay outstanding invoices / instalments despite repeated reminders, we will transfer relevant data to a debt collection service provider for the purpose of fiduciary debt collection. In the event of payment disputes, we also transfer data as necessary and appropriate for the purpose of asserting our rights (e.g. in the case of disputed payment obligations, requests from banks, or within the framework of conflict resolution for chargebacks). (The legal basis for these activities is the legitimate interests of eharmony to ensure that (as applicable) you provide the agreed payment for our Service in accordance with your subscription.)
- For the protection and defence of our rights (for example, intellectual property and in the context of legal or regulatory proceedings)and the fulfilment of legal obligations (for example, compliance with finance and tax legislation). (The legal basis for these activities is the fulfilment of our legal obligations and our legitimate interest in asserting and defending our rights.)
- To provide you with services requested via our website, the provision of messaging, and the operation of our website/app. (The legal basis here is consent of the individual and PECR Reg 6(4)(b)).
- For the purposes of sending advertising relating to our own products through promotional emails and/or push messages, newsletters, surveys and personalised guidance. (The legal basis is our legitimate interests in relation to sending direct marketing about our own products, and/or your consent; also Art. 22 Privacy and Electronic Communications (EC Directive) Regulations 2003 (PECR) applies here.)
- To comply with statutory data retention obligations and other statutory or legal obligations and provisions (e.g. in connection with tax audits, official or judicial orders for information or other purposes). (The legal basis is the fulfilment of our legal obligations).
- For the purpose of considering the advertising objection. (Legal basis is the fulfilment of our legal obligations; also Art. 22 PECR applies here.)
- To answer communications or questions from you. (The legal basis is contractual necessity, complying with our legal obligations, and eharmony’s and our users’ legitimate interests in offering/receiving customer service and improving the customer experience.)
- To publish your love story (success story) on the eharmony website and other online and offline channels. (The legal basis is your consent.)
- If applicable, for archiving purposes in the public interest, for scientific or historical research purposes or for statistical purposes pursuant to Article 89(1) (the legal basis in these cases is UK GDPR Article 9(2)(j) or Article 6(1)(e) in conjunction with Article 6(2)).
- Sending you service-related emails/messages, including invitations to review eharmony services. For this purpose, we may also contract with and send limited personal information (email, name, and customer reference number) to third parties to facilitate sending such emails/messages on our behalf. (The legal basis is our contractual relationship and our legitimate interests in managing our relationship and improving our services, which may include sending service communications including asking you, directly or via a service provider, to leave a review or take a survey.)
You will find the processing purposes and legal basis for the processing of personal data regarding the use of “cookies” and other tracking technologies when using eharmony in our cookies & tracking policy.
Legal basis for the processing of personal data
- Where we obtain your consent as our lawful basis of processing, our legal basis is point (a) of Article 6(1) of the UK General Data Protection Regulation (UK GDPR).
- Where the processing of special categories of data according to Article 9(1) UK GDPR is required, our legal basis is point (a) of Article 9(2) UK GDPR – your consent.
- When the processing of your personal data is required to fulfil our contractual relationship (either in relation to Basic Membership or Premium Membership), our legal basis is point (b) of Article 6(1) UK GDPR. This also applies to any processing that is required to carry out any pre-contractual actions.
- When the processing of your personal data is required to fulfil a legal obligation, our legal basis is point (c) of Article 6(1) UK GDPR.
- If we store information in your terminal equipment or access such information that is already stored in your terminal equipment, PECR Reg. 6(4)(b) serves as the legal basis.
- If the processing is necessary to safeguard the legitimate interests of eharmony or a third party, such as our members, and the interests, fundamental rights and freedoms of the data subject do not override those legitimate interests, our legal basis for the processing is point (f) of Article 6(1) UK GDPR.
- For further data processing, Art. 6 (1) UK GDPR takes effect in its relevant littera depending on the data processing constellation.
- When the processing of personal data is required for our own marketing (either in relation to Basic Membership or Premium Membership), the legal basis for the processing is point (f) of Article 6(1) UK GDPR.
- If applicable, for archiving purposes in the public interest, for scientific or historical research purposes or for statistical purposes pursuant to Article 89(1) (the legal basis in these cases is Article 9(2)(j) GDPR or Article 6(1)(e) GDPR in conjunction with Article 6(2) GDPR; Art. 6 para. 2 GDPR).
- If, in exceptional cases, specific personal data are processed for reasons of substantial public interest, Art. 9 (2) (g) GDPR serves as the legal basis.
When the legal basis for processing is your consent, you are entitled to withdraw your consent at any time. However, this withdrawal will not affect the lawfulness of any processing carried out on the basis of your consent before your withdrawal. If the legal basis is a legitimate interest, you are also entitled, in general, to object to the processing of your personal data, at any time, for reasons arising from your specific situation. Please see the section “Rights of the data subject at a glance” below.
Transfer of data to third parties; service provider
eharmony generally only discloses your personal data to third parties:
- for the provision of the Services to you,
- if we or the third party have a legitimate interest for disclosing,
- if we have your consent or,
- if this is required in order to fulfil a legal obligation.
If we disclose your personal data to third parties on the basis of a legitimate interest, we will explain the legitimate interest in this privacy policy.
We may share your personal information within our group of companies, and other entities within our group may also store and/or process your information in accordance with this privacy policy.
In the following cases, personal data may also be transferred to third parties:
- to service providers, if the data is required for the fulfilment of their data processing agreement with us;
- any providers of marketing tracking technologies and analysis tools (you can find out more about this in our cookies & tracking policy);
- where we are obliged to do so by law, including at the request of a regulator or an enforceable official order (e.g., a court order);
- in connection with legal disputes, debt collections or audits. In these cases, we would share information with the courts and our advisers (e.g., lawyers, chartered accountants or tax auditors);
- relevant investigating authorities in connection with possible criminal offences (e.g., the police);
- in the event of the sale of the business, we would transfer personal data to the.
- If we have your consent, we will share success stories with media outlets and on social media (such as Instagram, Facebook, Twitter and YouTube).
Insofar as data is regularly transferred to other third parties, this is explained in this privacy policy and/or our cookies & tracking policy. If the transfer takes place on the basis of consent, the explanation may also be provided when obtaining consent.
In the context of maintenance and support, “X” (Twitter) feeds of the eharmony account may be integrated on the eharmony maintenance page, in which current tweets regarding possible and ongoing maintenance and repair work by eharmony are displayed. This should make it possible to inform users about the progress of this maintenance and repair work via “X” (Twitter). Through the integration of the “X” (Twitter) feed of the eharmony account, Twitter may collect certain personal data, as described here: https://help.twitter.com/en/twitter-for-websites-ads-info-and-privacy.
Transfers to service providers
eharmony may use service providers when collecting or processing your personal data. eharmony will ensure that service provider only receive that portion of your personal data they need for their specific activity.
eharmony engages service providers to:
- send promotional emails and push messages to members.
- send service-related messages and receive customer review management services (e.g., with Trustpilot, whose privacy notice is available here).
- store your information (e.g., cloud-based server providers)
- process financial payments and engage the service providers to help us with the settlement of payments and debt collection. Depending on the particular payment method you choose when purchasing your Premium Membership over our website, eharmony will send your payment information to the bank or to the particular payment service provider that we have appointed. Please be aware that such payment service providers will be responsible for their use of your personal data for their own purposes (i.e., to process your payment). As such, the privacy policy of the respective payment service provider will also apply.
Unless otherwise stated, the service providers that we appoint are engaged as our processor and may only use the personal data of our members in accordance with our instructions.
Please note that if you purchase a Premium Membership over the eharmony app, eharmony will not process any payment. In this case, the app store operator will be responsible for handling the payment process and we will not receive your card details.
Transfer of data to non-European countries
eHarmony may disclose your personal data to third-party controllers (joint or independent) or to our processors who are located outside the UK and European Economic Area (“EEA”) (collectively, “Europe”). When this happens, and before disclosing your data we ensure that the recipient has an adequate level of protection to enable the lawful transfer of your data. For example, this may be because the recipient is in a country that has been determined as offering an adequate level of data protection; or has entered into standard data protection clauses and implemented appropriate technical and organizational measures; or (where permitted by law) because you have expressly consented to this transfer.
If necessary, we also conclude a corresponding “UK Addendum” with our contractual partners in accordance with the requirements of the Information Commissioner’s Office (ICO) and a corresponding “CH Addendum” in accordance with the requirements of the Swiss Federal Data Protection and Information Commissioner (FDPIC).
We can provide you with an overview of recipients (both of the companies within the Group; collection service providers, if applicable; and all processors) in third countries and a copy of agreed-upon regulations regarding ensuring an adequate level of data protection (standard contractual clauses including UK or CH Addendum, where applicable).
Please use the information provided under Contact for this purpose.
How do we protect your personal data?
Eharmony uses a variety of security measures, including state-of-the-art encryption and authentication tools, to protect the security, integrity and availability of our customers’ and users’ personal data. In particular, these measures include the following:
- Strict criteria for the authorization to access your data as well as 2-factor authentication,
- Storage of confidential data in encrypted form,
- Firewall protection of IT systems to prevent unauthorized access,
- Permanent monitoring of access to IT systems to detect and prevent the misuse of personal data.
In this context, we recommend that you familiarise yourself with eharmony’s security tips when using the eharmony service. Here you can find more information on this topic.
In this context, eharmony also uses service providers from the USA. In particular, the following service providers are involved:
Cloudflare
A “Content Delivery Network” (CDN) is used to secure the online services provided by eharmony (web/native apps) and optimise their loading times. This CDN is a service of Cloudflare, Inc, 101 Townsend St, San Francisco, CA 94107, USA. Use of the Cloudflare service requires website enquiries and website content to be transmitted and processed via its server. In connection with this, data is consolidated to form statistics, which cannot be deactivated.
We have entered into a processing agreement with Cloudflare on the basis of the standard contractual clauses and the use of additional technical and organisational security measures.
Here you can find information about the data collected by Cloudflare.
MaxMind
eharmony uses the GeoIP2 Precision City geolocation service from MaxMind, Inc, Waltham, MA, 14 Spring St., Suite 3, Waltham, Massachusetts 02451, USA. With this service, we use IP addresses to determine approximate location/geolocation data based on the country of origin. No personal data is exchanged with MaxMind.
Here you can find further information about MaxMind.
iovation
In order to protect the eharmony platform and eharmony users from fraud and abuse, we employ the abuse prevention service provided by iovation Inc. 555 SW Oak Street #300, Portland, OR 97204, USA. iovation checks your IP address, date and time of access, referrer URL and browser information when you access the platform in order to determine the probability of fraudulent behaviour. All personal data received by iovation is pseudonymised, encrypted and subject to principles of data minimisation.
eharmony’s service provider, PE Digital GmbH, has concluded an agreement with iovation as independent controllers on the basis of the EU standard contractual clauses (Module 1).
You can find out more about iovation here.
Duration of storage; retention obligations
We store your data for as long as is necessary for the provision of our Service (Basic and Premium Memberships) and any associated services or where we have a legitimate interest which permits the further storage of that information. In all other cases, we will erase your personal information once it is no longer necessary, except for any information we need to retain in order to comply with any contractual or statutory (e.g. tax or commercial) retention periods (e.g. invoices).
Data that is subject to a mandatory retention period is blocked from deletion until the end of that period.
For Basic Members: You can choose to remove the data in your profile at any time. If you have neither an active Premium Membership nor Match Unlocks, you can also erase your profile data yourself (when you have completed the compatibility quiz) by starting the deletion process in the “Profile Settings” area of your eharmony account. If you are a web or iOS user, you can also erase your profile data yourself (when you have completed the compatibility test) by starting the deletion process in the “Profile Settings” area of your eharmony account. Otherwise, eharmony automatically erases personal profile data of Basic members who are inactive for 24 months.
Profile data related to Match Unlocks will be deleted either after two years of inactivity or no later than 4 years after the date of purchase.
For Premium Members: Your personal data will be stored for the duration of our contractual relationship. However, we will erase your data following your request as long as there is no legal storage obligation that applies to that information. Once your Premium Membership is over, if you do not ask us to erase your data before your Premium subscription comes to an end, your Premium Membership will be converted into a Basic Membership. In this case, the description above relating to the retention period of Basic Members’ data will apply.
The following applies to all members: If the number of displayed and stored chats exceeds 5,000, we will delete the excess number of chats automatically in accordance with the provision in the T&C, depending on the age of the chats (based on the chronology of how they are displayed in the customer’s profile), see also section 7.7. of the T&C.
If you uninstall the eharmony app on your device, this will not delete the data in your profile. The above statements related to the deletion of Basic Members’ data and Premium Members’ data also apply here.
eHarmony stores log files (i.e., records of your usage and interaction with us, regardless of the communication channel) in an inaccessible archive for 30 days and then deletes them. Log files that need to be retained for evidentiary purposes may, in some cases, be provided to investigating authorities.
If you ask us to do so, we will delete your data, provided there is no legal obligation to retain this data. Please note that if the deletion of your data is prevented due to a mandatory retention period, your data will be blocked and stored for no other purposes, until we can delete it.
eharmony will also store any personal data which is required to demonstrate that eharmony has lawfully complied with a valid data subject’s rights request within the required period.
Are you obliged to provide us with personal data?
n principle, you are not obliged to provide your personal data to us. However, the use of certain services may require the provision of personal data (e.g. registration or participation in a competition). If this is the case, we will let you know by marking mandatory data fields with an asterisk (*). If you do not wish to provide the required data, you will unfortunately not be able to use the corresponding services.
Rights of the data subject at a glance
Under the UK GDPR and data protection laws, you have rights. Whether and to what extent the rights apply may depend upon the circumstances. The rights are
Your right to be informed – You have a right to receive concise, transparent, intelligible, and easily accessible information about your personal data and our use of it.
Your right of access – You have the right to ask us for copies of your personal data. This right always applies but there are some exemptions to its application, which means you may not always receive all the information you have requested. When you request data, this is known as making a data subject access request (DSAR).
Your right to rectification – You have the right to ask us to rectify personal data you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Your right to erasure – You have the right to ask us to erase your personal data in certain circumstances. We have the right to refuse to comply with a request for erasure if we are processing the personal data for one of the following reasons:
- To exercise the right of freedom of expression and information.
- To comply with a legal obligation.
- To perform a task in the public interest or exercise official authority.
- For archiving purposes in the public interest, scientific research, historical research or statistical purposes.
- For the exercise or defence of legal claims.
Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal data in certain circumstances. In such case, we will still hold the data but will not process it any further. This right is an alternative to the right to erasure. If one of the following conditions applies, you may exercise the right to restrict processing:
- The accuracy of the personal data is contested.
- Processing of the personal data is unlawful.
- We no longer need the personal data for processing, but the personal data is required for part of a legal process.
- The right to object has been exercised and processing is restricted pending a decision on the status of the processing.
Your right to object to processing – You have the right to object to processing in certain circumstances. You can also object if the processing is for a task carried out in the public interest, the exercise of official authority vested in you, or our legitimate interests (or those of a third party).
Your right to data portability – This right only applies if we are processing information based on your consent or for the performance of a contract and the processing is automated.
If you would like to exercise any of your rights, please use the information under Contact. Please also ensure that when you do so, you provide sufficient information to enable us to clearly identify you.
Alternatively, you may use the setting options in your eharmony profile to rectify certain information that you provided during your registration or to object to advertising.
You can also delete your data or your complete profile from an eharmony Basic Membership yourself in your profile (if you have completed the eharmony compatibility quiz). To do this, log in to your profile on the eharmony website and delete your profile under Data & Settings / Profile. Alternatively, Basic Members can contact our customer service using the information under Contact and request the deletion of their data. However, please note that Premium Members can only delete data regarding their Premium Membership by contacting our customer care.
Right to lodge a complaint with a supervisory authority
You have the right to file a complaint with a data protection authority. If you are located in the UK, you can contact the UK’s data protection authority, the Information Commissioner’s Office, at: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, Telephone Number: + 44 (0) 303 123 1113, Email: casework@ico.org.uk.
If you are located elsewhere in Europe, you can contact your local data protection authority or our appointed data protection authority. This is:
Free and Hanseatic City of Hamburg, The Hamburg Commissioner for Data Protection and Freedom of Information, E-Mail: mailbox@datenschutz.hamburg.de
Social Media
In general, if social media plugins are used, the providers of such plugins will store cookies. However, the social media buttons that we use on our website contain only text links to the respective social media pages, they are not properly a social media plugin. Therefore, eharmony will not transfer any data to the respective social media providers. The operator of the social media page is responsible for compliance with data protection law. You can get more information about their data protection practices in their respective privacy policies.
Cookies & other tracking technologies
You will find information on cookies and other tracking technologies that are used on our website and in our app in our cookies & tracking policy. If personal data is processed in connection with tracking-based processes, you will also find detailed information on the reasons for doing so in that policy, which includes information on how to object to this type of data processing.