Last updated: 3rd June 2024

At IsThereSomebody, we value your privacy and are committed to protecting your personal information. Here’s what you need to know:

1. Collection of Information:

We only collect the information necessary to provide our services effectively. 

Registration Information

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

• Username (Nickname);
• Email address;
• Gender identity;
• Age band;
• Approximate geographical location;

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

Profile Information

We recommend and encourage you (and all our members) to think carefully about the information you disclose about yourself.  For this reason, we only require you to add a nickname rather than your real name on your profile.  Similarly, we have enabled you to choose an avatar if you prefer not to upload a photo of yourself.

We also do not recommend that you share email addresses, instant messaging details, phone numbers, full names or addresses and other sensitive information which may be open to abuse and misuse on your profile.

When you post information about yourself or use the chat function to communicate with other users, the amount of personal information you share is at your own risk.  Please see Section 4 below for more information on who can access what you post on IsThereSomebody.

Anonymity and Confidentiality

We prioritise your privacy and ensure that all interactions within IsThereSomebody remain completely anonymous and confidential. Your conversations are securely encrypted to safeguard your privacy.

Geolocation Information

If you have given IsThereSomebody access to your location in your device settings, when you use your mobile, we will collect information about WiFi access points as well as other location information about your longitude and latitude and may save your device’s coordinates to offer certain features to you.  This information helps us identify your physical location and we use it to personalise the app and make it easier for you to interact with other users, by enabling the general locality information to be displayed to users seeing your profile and showing you the profiles of other users who are near you.

If you have given IsThereSomebody access to your location, but wish to turn this off, you can do so by the following methods:

1. iPhone app — settings, privacy, location services, IsThereSomebody
2. Android — settings, location, IsThereSomebody, permissions, location

Device Information

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

Links

We may keep track of how you interact with links available on IsThereSomebody 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.

IsThereSomebody Surveys, Feedback and other Contributions

From time to time, we may run surveys for research purposes and may contact you to find out if you would like to take part.  We may also contact you to find out if you would like to provide feedback, to give a testimonial or take part in marketing campaigns.  Such surveys and marketing campaigns are optional and more information will be provided at the point of contact.  

Cookies and similar technologies

When you visit our site 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 Information:

Your information is used solely to enhance your experience with IsThereSomebody. We do not share or sell your personally identifiable information to third parties.

We may use your Registration and other information to:

• contact you with information about the app (e.g., updates and new features).
• personalise the app/site and the content we deliver to you.
• conduct research and analytics about how you use and interact with the app/site.
• to test new technologies and processes designed to enhance and improve the app/site.
• resolve disputes, troubleshoot problems and to enforce our Terms & Conditions.
• investigate fraud, protect our legal rights, and to enforce our Terms & Conditions.
• protect our users and third parties from harm.

We will only share aggregated anonymised data from the IsThereSomebody app with regards to trends and patterns in addiction and recovery paths.

Our Matching Algorithms

IsThereSomebody’s mission is to help you connect with others with similar shared experiences and signpost you to organisations who are able to support you.  We have developed matching algorithms to find other users like you who have or are experiencing similar experiences with their loved ones due to addiction – our matching algorithm helps us show you people we think are a good connection for you.  We also will match you with professional organisations who are best placed to help you, based on your profile.  

We use different indications based on users’ profiles on our app (for example, the relationship type to your loved one and the addiction type in question). We use these indications to recommend the most relevant profiles to everyone to maximise everyone’s chances of finding meaningful connections on our app.  Our matching algorithms are based on a range of factors and use machine learning to rank profiles for you to maximise your chance of finding the most relevant connections. 

We use the following data about you and other users to predict your likely connection and empathy with others and generate recommended matches: the information you provide us about yourself in your profile such as age, gender, relationship with your loved one and addiction type, so we can show you people who you are most likely to resonate with and who are more likely to empathise with you and be a supportive connection.  The legal basis for processing profile information is that this is necessary for the provision of our contractual services to you pursuant to Article 6(1)(b) GDPR. Where we process information about your app activity, this is based on our legitimate interests pursuant to Article 6(1)(f) GDPR, and specifically our legitimate interest in generating more personalised and relevant recommendations for who you can match with in our app.  Where you have included sensitive information in your profile, such as information about your beliefs, the processing of this information is based on your voluntary and explicit consent.

Moderation Practices

We use a combination of automated tools and human moderation to monitor and review accounts (including information uploaded onto user profiles) and messages for content that indicates breaches of our Terms and Conditions of Use. If an account or message meets certain criteria that demonstrate that the Terms and Conditions of Use are likely to have been breached, the relevant account will be subject to a warning and the user’s access restricted and/or blocked. Affected Users can contact IsThereSomebody at support@istheresomebody.com to contest the decision.

If you post anything that is inconsistent with our Terms and Conditions of Use, we reserve the right to terminate or restrict access to your Account. In the case that an account is terminated, its data will be securely deleted.

Lawful Basis

Under EU and UK data protection laws, we are required to tell you our lawful basis for using your data and we have set this out in the table below. Where the legal basis is consent, you can withdraw consent at any time. Where the legal basis is legitimate interests, you have a right to object to our use of your data. We explain in the relevant sections in this Policy how you can withdraw consent or opt-out of certain data uses (where applicable).

Purpose for which the data is created	Data	Source	Legal basis
To provide you with the IsThereSomebody service.	Email address, age band, gender	You provide your email address, age band and gender to us. We obtain location data from the device that you use to access the service.	Contractual necessity
To facilitate networking opportunities on the IsThereSomebody App.	Optional information that you choose to provide in your profile – e.g. relationship with your loved one, your bio, your story, your interests etc.	You provide this information to us.	Contractual necessity and our legitimate interests – it is in our legitimate interests to facilitate connection opportunities in the IsThereSomebody app. For special category/sensitive personal data, we rely on your explicit consent.
To send you marketing information about our events, offers and services.	Log and usage data, including IP address, browser type, referring domain, pages accessed, mobile carrier and search terms, images, registration information, profile information.	You provide photos to us. We obtain the log and usage information from the device that you use to access the service.	Legitimate interests – it is in our legitimate interests to analyse the way in which users are accessing and using our services and to test new technologies so that we can further develop the app, implement security measures and improve the service.
To investigate and block Users for reported infringements of our Terms and Conditions of Use	Name and user registration details, profile information, content of messages and photographs + usage and device data such as IP address and IP session information	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.	Legitimate interests – it is in our legitimate interests to prevent unauthorised behaviour and to maintain the safety and integrity of our services
To improve your experience on the App	Data about interactions with matches on the app, in respect of clicking on a matches’s story, connecting with a match, clicking on an organisation’s profile and updating profile information.	We obtain this information from the way users interact with the App	Legitimate interest – it is in our legitimate interest to improve our users’ experience
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	Email address	You provide this information to us	Legitimate interests – it is in our legitimate interests to carry out research so that we can further develop the app and improve the service
To defend legal claims, protect legal rights and to protect people from harm	This could include any information that is relevant to the issue	This information may be obtained directly from you, from your device or from third parties, depending on the information involved	Legitimate interests – it is in our legitimate interests to protect our legal rights, defend legal claims and to protect our users and third parties from harm

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
Service Providers – we may engage certain trusted third parties to perform functions and provide services to us. We may share your Registration Information or personal data with these third parties, but only for the purposes of performing these functions and providing such services. More details below.	Email addresses, uploaded profile avatars.
Moderators – to monitor activity on the app and approve content.	Name and user registration details, profile information, content of messages and any uploaded or shared photographs.
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 cooperate with lawfully made law enforcement requests for information from within or outside your country of residence where we are required to by law. This may include where there is an investigation into alleged criminal behaviour or to protect the vital interests of a person. We may preserve or disclose 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 in good faith that disclosure is necessary:to comply with a binding direction court order, or lawful 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; orto 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 IsThereSomebody holds about you, depending on the nature of the request or the issue that we are dealing with.
Marketing Services Providers – to help us serve marketing and advertising on third party websites and applications and measure the effectiveness of our advertising campaigns. More information on this is available below	Advertising identifier associated with your device (Device ID), estimated location (based on your IP address), age band, gender and data about your visit to our site or app and action taken on those (for example if you downloaded our app or created an account with our app), hashed email address (for ‘custom audiences’ only)

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.

More information about Service Providers 

For example, to provide our services to users, we typically use the following suppliers:

• Product improvement and market research – we use third party platforms (such as Typeform) to carry out customer surveys and market research to improve our products and services
• IT services – some of the third-party software providers used in the operation of our business may process users’ personal data for example, Amazon SES for sending password reset emails, and Digital Ocean Spaces for storing uploaded avatars.

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.

More information about Marketing Service Providers 

We partner with providers of marketing services (such as Google for example) (‘Marketing Services Providers’) to help us market and advertise our app and services on third party websites and applications and measure the effectiveness of our advertising campaigns. For example:

• to exclude you from advertising campaigns aimed at finding new users, if you already have a IsThereSomebody account;
• to show IsThereSomebody adverts to users who have visited the IsThereSomebody app/site but haven’t yet created a IsThereSomebody account;
• to create an audience for our advertisements of other potential users who have similar characteristics to you based on the information the Marketing Service Providers holds about you (also known as a Lookalike Audience); or
• to include you in a ‘custom audience’ that will receive IsThereSomebody advertising content (a custom audience is essentially a list of people who we think are most likely to be interested in a particular advertisement).

We share a limited amount of your personal data with these Marketing Services Providers, such as:

• the advertising identifier associated with your device (this is a random number assigned by your mobile device manufacturer (for example Apple or Google) to your device to help advertisers (including the manufacturer) know when an ad has been viewed or clicked in an app, and when an ad causes a ‘conversion’ (for example, downloading the app advertised to you))
• your estimated location (based on your IP address)
• age and gender
• data about your visit to our site or app and action taken on those (for example if you downloaded our app, created an account with our app, or details of any purchases made on site or in app)
• a hashed* version of your email address (to create ‘custom audiences’).

*Hashing is a way of encrypting information by turning it into a combination of random numbers and letters – this code cannot be traced back to the email address. When hashed email addresses are sent to a Marketing Service Provider, they’re then matched against the Provider’s own existing list of their own users’ hashed information and our ads are served to those of our users who have successfully been matched with the Provider’s. Matched and unmatched hashes are then deleted by the Provider.

In some cases, these third parties will also use the data that they collect for their own purposes, for example they may aggregate your data with other data they hold and use this to inform advertising related services provided to other clients.

4. What others may see about you

Our app is designed to make it easier for you to connect with other users and to interact with them.

However, please be careful about posting sensitive details about yourself on your profile.  Please also remember that any photographs that you post on IsThereSomebody may reveal information about yourself as well.  When you 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 (unless you specify otherwise in your profile).

5. Our policy towards age.

Although we want as many people as possible to enjoy our creation, you have to be at least 13 years old to use IsThereSomebody.

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. We also take great care to collect as little personally identifying information from you as possible.

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 IsThereSomebody Account with anyone else.
3. Change your password periodically.
4. Use a complex password for your account that isn’t shared with other online accounts you hold.
5. Avoid giving out any personally identifiable information in the username or bio of your IsThereSomebody account, or when communicating with other IsThereSomebody users.
6. Be suspicious of people asking for information about your IsThereSomebody account, or claiming to work for IsThereSomebody. We will never ask you for your account password, for example.

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. 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 want to exercise any of your rights listed above please email us at dpo@istheresomeobody.com. For your protection and the protection of all of our users, we may need to request specific information from you to help us confirm your identity before we can answer the above requests.

If you have a concern about how we have processed your request or your personal data, you should contact us in the first instance via the contact details listed above.

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. 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.

8. Data retention and deletion.

When your Account is deleted, we make sure it is no longer viewable in the app and the account is immediately irretrievably.

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.

9. Changes to this policy.

As IsThereSomebody 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 istheresomebody.com/privacy. 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 IsThereSomebody.