Article 1: Personal Data Protection

1.1 Data controller – Data recipients

Data are collected by:

Deutschland Digital GmbH registered under the number HRA 203103 at Amtsgericht Oldenburg.

The headquarters are located Felix-Wankel Str. 16, 26125 Oldenburg and the company is represented by their CEO's Rolf Hilchner and Heinz-Wilhelm Bogena.

Only some of the support team employees and authorized managers can process the data for the purpose described at article 1.2. These employees and authorized managers only have access to the data necessary to the performance of their duty.

CMPLMNTS can also contract with authenticated and reliable subcontractors that can access, host and/or process some of the personal data on the behalf of CMPLMNTS and according to its instructions with respect to the Privacy Policy, and must guaranty the security and confidentiality of Member’s personal data.

These subcontractors allow CMPLMNTS among other things to establish statistics on the volume of traffic and/or the use of the app and/or ensure the smooth operation of the service.

1.2 Purpose of the process of personal data by CMPLMNTS

The data collected by CMPLMNTS are necessary to the smooth operation and improvement of the service proposed by the Application to the Members.

These data can also allow CMPLMNTS to realize statistical studies and marketing analysis relating to the use of the Application and its services by the Members. It allows CMPLMNTS to send promotional messages from advertisers and other partners via the Application. However, CMPLMNTS never transfers any personal data of its Members to such advertisers and partners.

CMPLMNTS can access, store and share the Member’s personal data with authorized third parties in order to answer to a legal demand or to conform itself to legal obligations, to detect or prevent fraudulent activities or security attempt to the services, in application of the legislation.

1.3 Fair Collection of Personal Data – Type of data collected

Identity data: The registration form must be completed in order to access the Services, and CMPLMNTS creates a user-id and needs a picture of the user to identify themselves to other users within a radius of 25 meter. By option a user can add gender and age.

For the sake of transparency, the published photos must represent the member and shouldn’t mislead the other Members on his identity and/ or physical appearance.

These photos cannot represent neither a famous person nor include the photo of a minor, neither represent a racist, chocking, illegal, sexual message nor contained personal information.

The photos are published in the App under the sole responsibility of the Member.

By becoming a Member, the latter accepts the publication of his picture on the App and by option following informations:

  • His/her year of birth 
  • His/her sex (publicly visible on CMPLMNTS after giving a compliment)

The personal data the Member can add to his/her profile are not mandatory and can be communicated at his/her sole discretion and under his/her sole responsibility.

Location Data (geo-tracking):

CMPLMNTS has for main purpose and vocation to allow Members to find the people they want to give compliments to.

The Member will be asked for permission to collect and process his/her geo-tracking in order to allow CMPLMNTS to identify the crossing points with other Members that accepted the geo-tracking.

CMPLMNTS may, in case of express consent, access the Member's position, approximately or more precisely depending on which technology is being used. CMPLMNTS does not track the movements and/or itinerary of its Members and reminds only the crossing points between the Members.

The exact position or the itinerary of a single Member is not available to the other Members.

The Member is free to withdraw his/her consent at any time, and deactivate the geo-tracking technology on his smartphone.

Communications Data exchanged: Communication data is stored on CMPLMNTS’s servers solely in order to provide the Service that allows conversations to take place between members having a Crush.

Mobile Data: When the Member uses the Application, CMPLMNTS collects server logs which may include information such as IP addresses, operating systems or application crashes. CMPLMNTS cannot access its Members' browsing history.

1.4 Complementary information concerning the data collected

CMPLMNTS ensures that the personal data the Member has published on the Application is strictly invisible to non-registered internet users and third parties. CMPLMNTS cannot be held liable for data published on its platform and disclosed by a Member.

The Member's profile will not appear on the Application to Members.

1.5 Sensitive Data

The Member may decide to provide sensitive data related to him/her on his/her description such as gender and age.

The Member won’t be in any case forced to give us some sensitive data and CMPLMNTS does not encourage the disclosure of such sensitive data. 

1.6 Lack of cession of your personal data

The personal data, visible or not to the other Members, are not commercialized by CMPLMNTS to third parties.

1.7 Storage of Personal Data

CMPLMNTS will store the Member's personal data for as long as required in order for the Member to use his/her Account. The Member is however informed that all of his/her personal data shall be stored for one year after his/her account is deleted so that it can be reallocated if the Member signs up again.

Furthermore, please note that in accordance with its status as a hosting provider, CMPLMNTS has a legal obligation to retain some of Members' personal data for a period of one year.

1.8 Transfer of Personal Data outside the EU

When registering, the Member expressly consents to his/her data being transmitted to subcontractors and hosted on servers by our service providers outside the European Union, for proper provision of the service, to the end of elaborating statistical studies and for the purpose of providing customer care support to Members.