Dapper Group – FZCO, trading as Dapper ("Dapper", "Company", "we", "us", or "our"), respects the privacy of visitors, applicants, clients, and prospective clients who use our website, application forms, communications, and dating management concierge services (collectively, the "Services"). This Privacy Policy explains how we collect, use, disclose, retain, and protect personal data.
Dapper provides personal lifestyle, relationship consultancy, dating management, profile optimization, messaging, coaching, and date logistics services. Because these Services are personal by nature, some information you provide may be sensitive. We process such information only as necessary to evaluate, administer, and deliver the Services, and where required, with your explicit consent.
1. Who this policy applies to
This policy applies when you visit dapper.black, submit an inquiry or application, communicate with us, purchase or receive Services, participate in coaching or strategy sessions, or otherwise provide personal data to Dapper.
Our Services are intended only for adults who are at least 18 years old. We do not knowingly collect personal data from minors.
2. Personal data we collect
Depending on how you interact with us, we may collect:
- Identity and contact data, including name, email address, phone number, country of residence, and billing details.
- Membership request and consultation data, including goals, preferences, relationship background, lifestyle context, and information you choose to share with us.
- Dating profile materials, including photos, profile text, prompts, social media handles, preferences, and platform-related information needed to deliver the Services.
- Communications data, including emails, messages, calls, surveys, support requests, and notes from strategy or coaching sessions.
- Payment and transaction data, including plan, amount, currency, payment status, taxes, and payment processor confirmations. We do not intentionally store full payment card details on our own systems.
- Website and device data, including IP address, browser type, device information, pages viewed, approximate location, timestamps, diagnostics, analytics, cookies, and similar technologies.
3. Sensitive personal data
To provide dating management services, you may voluntarily disclose information about relationship history, dating preferences, sexual orientation, lifestyle, photos, social media presence, or other personal matters. We treat this information as confidential and process it only where necessary for the Services, with your explicit consent where required by applicable law.
4. How we collect data
We collect data directly from you, automatically through our website, from service providers acting for us, and from platforms or materials you authorize us to use in connection with the Services.
5. How we use your data
We use personal data to:
- Review applications and determine whether there is a fit for the Services.
- Deliver dating management, concierge, coaching, profile, messaging, and date logistics services.
- Manage client communications, scheduling, billing, payments, and support.
- Personalize strategy based on your stated goals, preferences, and feedback.
- Improve website performance, security, analytics, and client experience.
- Send service communications and, where permitted, marketing communications.
- Protect Dapper, our clients, and third parties from fraud, abuse, unlawful conduct, platform misuse, and reputational harm.
- Comply with legal, tax, accounting, regulatory, dispute resolution, and law enforcement obligations.
6. Legal bases for processing
Where EU, UK, or similar privacy law applies, we rely on one or more legal bases: performance of a contract, steps taken before entering into a contract, legitimate interests, consent, explicit consent for sensitive data where required, and compliance with legal obligations.
7. Sharing personal data
We may share personal data with:
- Team members, coaches, contractors, affiliates, and subcontractors who help provide the Services.
- Service providers for hosting, forms, email, analytics, customer relationship management, scheduling, payment processing, security, storage, and operations.
- Professional advisers, insurers, auditors, regulators, courts, law enforcement, tax authorities, or dispute resolution bodies where required or appropriate.
- Successor entities in connection with a merger, acquisition, restructuring, sale, or transfer of business assets.
We do not sell your personal data. Service providers are expected to process personal data only for the services they provide to us and to protect it using appropriate safeguards.
8. International transfers
Dapper may operate from, or use providers located in, the United Arab Emirates, the European Economic Area, the United Kingdom, the United States, and other jurisdictions. Where personal data is transferred internationally, we use appropriate safeguards where reasonably applicable, including contractual protections, access controls, data minimization, restricted disclosure, and other technical and organizational measures.
9. UAE and EU data protection standards
We aim to process personal data in accordance with applicable data protection laws, including where relevant the UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data, the EU General Data Protection Regulation (Regulation (EU) 2016/679), the UK GDPR, and the UK Data Protection Act 2018. Mandatory consumer and privacy rights under the law of your habitual residence are not excluded by this policy.
10. Retention
We retain personal data for as long as necessary to provide the Services, manage client relationships, comply with legal, tax, accounting, and dispute obligations, enforce agreements, and protect our legitimate interests. When data is no longer needed, we delete, anonymize, or securely restrict it where reasonably possible.
11. Security and confidentiality
We use reasonable administrative, technical, and organizational safeguards designed to protect personal data from unauthorized access, disclosure, alteration, misuse, loss, or destruction. No internet transmission or storage system is completely secure.
12. Your rights and choices
Depending on your location, you may have the right to request access, correction, deletion, restriction, portability, objection to processing, withdrawal of consent, and information about how we process or disclose your data. You may also have the right to lodge a complaint with a competent data protection authority.
To exercise privacy rights, contact us at hello@dapper.black. We may need to verify your identity before responding.
13. Marketing communications
You may opt out of non-essential marketing communications at any time by following the instructions in the message or by contacting us. We may still send service, transactional, security, legal, or account-related communications.
14. Cookies and analytics
We may use cookies and similar technologies to operate the website, understand website performance, remember preferences, improve the Services, and support security. Where required by law, non-essential cookies are used with consent.
15. Changes to this policy
We may update this Privacy Policy from time to time. Updates will be posted on this page with a revised effective date. Continued use of the Services after an update means the updated policy applies.
16. Contact
For privacy questions or requests, contact Dapper Group – FZCO at hello@dapper.black.