OUR COMMITMENT TO YOU

At Matchmakers, LLC, your privacy is a top priority. Your privacy is at the core of the way we design and build the services and products you know and love, so that you can fully trust them and focus on building meaningful connections.

We appreciate that you put your trust in us when you provide us with your information and we do not take this lightly.

We do not compromise with your privacy. We design all of our products and services with your privacy in mind. We involve experts from various fields, including legal, security, engineering, product design and others to make sure that no decision is taken without respect for you.

We work hard to keep your information secure. We have teams dedicated to keeping your data safe and secure. We constantly update our security practices and invest in our security efforts to enhance the safety of your information.

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PRIVACY POLICY

Welcome to Matchmaker’s LLC Privacy Policy. Thank you for taking the time to read it.

We appreciate that you trust us with your information and we intend to always keep that trust. This starts with making sure you understand the information we collect, why we collect it, how it is used and your choices regarding your information. This Policy describes our privacy practices in plain language, keeping legal and technical jargon to a minimum.

1. HOW TO CONTACT US

You may contact us in the United States at: customerservice@matchmakersusa.com
2. KEY TERMS.

“We”, “us”, “our” shall mean Matchmakers, LLC;

Biometric Information shall mean an individual’s physiological, biological, or behavioral characteristics, including information pertaining to an individual’s deoxyribonucleic acid (DNA), that is used or is intended to be used singly or in combination with each other or with other identifying data, to establish individual identity. Biometric information includes, but is not limited to, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice

recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.

Personal information shall mean any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked with a particular consumer or household;

Sensitive personal information shall mean personal information revealing a consumer’s social security number, driver’s license and passport numbers, account numbers and credentials, precise geolocation, racial or ethnic origin, religious beliefs, or union membership, personal information concerning a consumer’s health, sex life, or sexual orientation, contents of a consumer’s mail, email and text messages where the business is not the intended recipient, genetic data, and biometric information.

Service shall mean access to Matchmaker’s website, mobile application, computer application and all related benefits and privileges associated therewith, and as accessed upon the creation of a profile on any of the aforementioned platforms.

User shall mean a person or person that make use of the Service. 3. WHERE THIS PRIVACY POLICY APPLIES

This Privacy Policy applies to websites, mobile and computer applications, events and other services operated by Matchmaker’s LLC. For simplicity, we refer to all of these as our “services” in this Privacy Policy.

4. CATEGORIES OF PERSONAL INFORMATION WE COLLECT

In the preceding 12 months we have collected the following categories and specific types of consumer personal information:

Categories of Personal Information Specific Types of Personal Information Collected

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Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers)

When you create an account, you provide us with at least your login credentials, as well as some basic details necessary for the service to work, such as your gender and date of birth.

Additionally, we may collect a User’s Internet Protocol address and email address.

Information that identifies

We may collect a User’s name, physical characteristics including but not limited to hair color and eye color, race, ethnic identity, gender identity, sex identity, location and any

other information that is disseminated on the Service.

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Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies)

When you subscribe to a paid service or make a purchase directly from us (rather than through a platform such as iOS or Android), you provide us or our payment service provider with information, such as your debit or credit card number or other financial information.

Internet or other electronic network activity information

The User’s browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement may be collected.

Geolocation data

If you give us permission, we can collect your precise geolocation (latitude and longitude) through various means, depending on the service and device you’re using, including GPS, Bluetooth or Wi-Fi connections. The collection of your geolocation may occur in the background even when you aren’t using the services if the permission you gave us expressly permits such collection. If you decline permission for us to collect your geolocation, we will not collect it.

Audio, electronic, visual, or similar information

Any pictures, videos or sound clips posted on the Service, or sent or received using the Service are collected.

Professional or employment-related information

All professional and/or employment information included in a User’s profile, or at any time disseminated using the Service is collected.

Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (FERPA)

All educational information included in a User’s profile, or at any time disseminated using the Service is collected.

Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological

All information provided or collected may be used to create a profile for the User and to draw inferences about the User that might be

trends, predispositions, behavior, attitudes, used to match Users with one another and intelligence, abilities, and aptitudes such information may be collected.

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Sensitive Personal Information

Information about the User’s log-in credentials, credit card, debit card or payment information, geolocation, racial or ethnic background, sexual preference, gender identity, sex identity, political views, dietary preferences and restrictions, religious or philosophical beliefs, union membership, email address inter alia may be collected.

5. HOW INFORMATION IS COLLECTED

We collect most of this personal information directly from you in person, by telephone, text or email, via our website, mobile applications and/or computer applications. However, we may also collect information from the following categories of sources:

  1. Publicly accessible sources;

  2. Third parties, including:

    1. advertising networks;

    2. internet service providers;

    3. social networks, including but not limited to Instagram and Facebook;

    4. data analytics providers, government entities, and data brokers;

    5. other Users;

    6. third party partners LLC including but not limited to entities who have agreed to display our advertisements on their websites or platforms from which we may receive information about the advertisement.

  3. Third parties, with your consent, for example, when you use a profile on a third party platform to create an account on our platform;

  4. Cookies on our website:

    1. We use and may allow others to use cookies and similar technologies (e.g., web beacons, pixels) to recognize you and/or your device(s). You may read our Cookie Policy for more information on why we use them (such as authenticating you, remembering your preferences and settings, analyzing site traffic and trends, delivering and measuring the effectiveness of advertising campaigns, allowing you to use social features) and how you can better control their use, through your browser settings and other tools.

    2. Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) have a “Do Not Track” (” DNT”) feature that tells a website that a User does not want to have his or her online activity tracked. If a website that responds to a DNT signal receives a DNT signal, the browser can block that website

from collecting certain information about the browser’s User. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many businesses, including Matchmaker’s LLC, do not currently respond to DNT signals.

  1. Automated information collection;

  2. From you:

    1. You choose to give us certain information when using our services. This

      includes:
      When you create an account, you provide us with at least your login

      credentials, as well as some basic details necessary for the service to

      work, such as your gender and date of birth.

      •   When you complete your profile, you can share with us additional

        information, such as details on your personality, lifestyle, interests and other details about you, as well as content such as photos and videos. To add certain content, like pictures or videos, you may allow us to access your camera or photo album. Some of the information you choose to provide us may be considered “special” or “sensitive” in certain jurisdictions, for example your racial or ethnic origins, sexual orientation and religious beliefs. By choosing to provide this information, you consent to our processing of that information.

      •   When you subscribe to a paid service or make a purchase directly from us (rather than through a platform such as iOS or Android), you provide us or our payment service provider with information, such as your debit or credit card number or other financial information.

      •   When you participate in surveys or focus groups, you give us your insights into our products and services, responses to our questions and testimonials.

      •   When you choose to participate in our promotions, events or contests, we collect the information that you use to register or enter.

      •   If you contact our customer care team, we collect the information you give us during the interaction. Sometimes, we monitor or record these interactions for training purposes and to ensure a high quality of service.

      •   If you ask us to communicate with or otherwise process information of other people (for example, if you ask us to send an email on your behalf to one of your friends), we collect the information about others that you give us in order to complete your request.

      •   Of course, we also process your chats with other Users as well as the content you publish, as part of the operation of the services.

    2. Information collected when you use our services:
      When you use our services, we collect information about which

      features you’ve used, how you’ve used them and the devices you use to

      access our services. See below for more details:

Usage Information. We collect information about your activity on our

services, for instance how you use them (e.g., date and time you logged in, features you’ve been using, searches, clicks and pages which

have been shown to you, referring webpage address, advertising that you click on) and how you interact with other Users (e.g., Users you connect and interact with, time and date of your exchanges, number of messages you send and receive).

Device information. We collect information from and about the device(s) you use to access our services, including:

  • hardware and software information such as IP address, device ID and type, device-specific and apps settings and characteristics, app crashes, advertising IDs (such as Google’s AAID and Apple’s IDFA, both of which are randomly generated numbers that you can reset by going into your device’ settings), browser type, version and language, operating system, time zones, identifiers associated with cookies or other technologies that may uniquely identify your device or browser (e.g., IMEI/UDID and MAC address);

  • information on your wireless and mobile network connection, like your service provider and signal strength;

  • information on device sensors such as accelerometers, gyroscopes and compasses.

iii. Other information with your consent: If you give us permission, we can collect your precise geolocation (latitude and longitude) through various means, depending on the service and device you’re using, including GPS, Bluetooth or Wi-Fi connections. The collection of your geolocation may occur in the background even when you aren’t using the services if the permission you gave us expressly permits such collection. If you decline permission for us to collect your geolocation, we will not collect it. Similarly, if you consent, we may collect your photos and videos (for instance, if you want to publish a photo, video or streaming on the services).

6. HOW AND WHY WE USE INFORMATION

The main reason we use your information is for business purposes, namely to deliver and improve our services. Additionally, we use your info to help keep you safe and to provide you with advertising that may be of interest to you. Read on for a more detailed explanation of the various reasons we use your information, together with practical examples.

  1. To administer your account and provide our services to you:

    1. Create and manage your account

    2. Provide you with customer support and respond to your requests

    3. Complete your transactions

    4. Communicate with you about our services, including order management and billing

  2. To help you connect with other Users

i. Analyze your profile and that of other Users to recommend meaningful connections

ii. Show Users’ profiles to one another
c. To ensure a consistent experience across your devices

i. Link the various devices you use so that you can enjoy a consistent experience of our services on all of them. We do this by linking devices and browser data, such as when you log into your account on different devices or by using partial or full IP address, browser version and similar data about your devices to help identify and link them.

  1. To serve you relevant offers and ads

    1. Administer sweepstakes, contests, discounts or other offers

    2. Develop, display and track content and advertising tailored to your interests on our services and other sites

    3. Communicate with you by email, phone, social media or mobile device about products or services that we think may interest you

  2. To improve our services and develop new ones

    1. Administer focus groups and surveys

    2. Conduct research and analysis of Users’ behavior to improve our services and content (for instance, we may decide to change the look and feel or even substantially modify a given feature based on Users’ behavior)

    3. Develop new features and services (for example, we may decide to build a new interests-based feature further to requests received from Users).

  3. To prevent, detect and fight fraud or other illegal or unauthorized activities

    1. Address ongoing or alleged misbehavior on and off-platform

    2. Perform data analysis to better understand and design countermeasures against these activities

    3. Retain data related to fraudulent activities to prevent against recurrences

  4. To ensure legal compliance

    1. Comply with legal requirements

    2. Assist law enforcement

    3. Enforce or exercise our rights, for example our Terms

  5. Debugging to identify and repair errors that impair existing functionality of the Service.

  6. Providing advertising and marketing services to the consumer.

  7. To comply with legal and regulatory requirements.

  8. For our or a third party’s legitimate interests.

  9. To process your information as described above, we rely on the following legal bases:

i. Provide our service to you: Most of the time, the reason we process your information is to perform the contract that you have with us. For instance, as

you go about using our service to build meaningful connections, we use your information to maintain your account and your profile, to make it viewable to other Users and recommend other Users to you.

  1. Legitimate interests: We may use your information where we have legitimate interests to do so. For instance, we analyze Users’ behavior on our services to continuously improve our offerings, we suggest offers we think might interest you, and we process information for administrative, fraud detection and other legal purposes.

  2. Consent: From time to time, we may ask for your consent to use your information for certain specific reasons. You may withdraw your consent at any time by contacting us at the address provided at the end of this Privacy Policy.

iv.

7. WHO WE SHARE YOUR INFORMATION

Since our goal is to help you make meaningful connections, the main sharing of Users’ information is, of course, with other Users. We also share some Users’ information with service providers and partners who assist us in operating the services, with other Match Group companies and, in some cases, legal authorities. Read on for more details about how your information is shared with others.

  1. With other Users: You share information with other Users when you voluntarily disclose information on the service (including your public profile). Please be careful with your information and make sure that the content you share is stuff that you’re comfortable being publicly viewable since neither you nor we can control what others do with your information once you share it.

    If you choose to limit the audience for all or part of your profile or for certain content or information about you, then it will be visible according to your settings.

  2. With our service providers and partners. We use third parties to help us operate and improve our services. These third parties assist us with various tasks, including data hosting and maintenance, analytics, customer care, marketing, advertising, payment processing and security operations.

    We may also share information with partners who distribute and assist us in advertising our services. For instance, we may share limited information on you in hashed, non-human readable form to advertising partners.

    We follow a strict vetting process prior to engaging any service provider or working with any partner. All of our service providers and partners must agree to strict confidentiality obligations.

  3. For corporate transactions. We may transfer your information if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control.

  1. When required by law. We may disclose your information if reasonably necessary: (i) to comply with a legal process, such as a court order, subpoena or search warrant, government / law enforcement investigation or other legal requirements; (ii) to assist in the prevention or detection of crime (subject in each case to applicable law); or (iii) to protect the safety of any person.

  2. To enforce legal rights. We may also share information: (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary to protect our legal rights and legal rights of our Users, business partners or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.

  3. With your consent or at your request. We may ask for your consent to share your information with third parties. In any such case, we will make it clear why we want to share the information.

    We may use and share non-personal information (meaning information that, by itself, does not identify who you are such as device information, general demographics, general behavioral data, geolocation in de-identified form), as well as personal information in hashed, non-human readable form, under any of the above circumstances. We may also share this information with other Match Group companies and third parties (notably advertisers) to develop and deliver targeted advertising on our services and on websites or applications of third parties, and to analyze and report on advertising you see. We may combine this information with additional non-personal information or personal information in hashed, non-human readable form collected from other sources..

8. PERSONAL INFORMATION SOLD OR SHARED

a.

In the past twelve months we have sold the following information about our Users:

  1. Identifiers

  2. Information that identifies

  3. Commercial information

  4. Internet or other electronic network activity information

  5. Geolocation data

  6. Audio, electronic, visual, or similar information

  7. Professional or employment-related information

  8. Education information

  9. Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes

  10. Sensitive Personal Information

9. PERSONAL INFORMATION DISCLOSED FOR A BUSINESS PURPOSE

a.

In the past twelve months we have disclosed the following information about our Users for business purposes:

  1. Identifiers

  2. Information that identifies

  3. Commercial information

  4. Internet or other electronic network activity information

  5. Geolocation data

  6. Audio, electronic, visual, or similar information

  7. Professional or employment-related information

  8. Education information

  9. Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes

  10. Sensitive Personal Information

10. CROSS-BORDER DATA TRANSFERS

Sharing of information laid out in this policy sometimes involves cross-border data transfers, for instance to the United States of America and other jurisdictions. Standard contractual clauses are commitments between companies transferring personal data, binding them to protect the privacy and security of your data.

11. YOUR RIGHTS

a. We want you to be in control of your information, so we have provided you with the following tools:

  1. Access/Update tools in the service. Tools and account settings that help you to access, rectify or delete information that you provided to us and that’s associated with your account directly within the service. If you have any question on those tools and settings, please contact our customer care team for help. (provide link?)

  2. Device permissions. Mobile platforms have permission systems for specific types of device data and notifications, such as phone book and location services as well as push notifications. You can change your settings on your device to either consent or oppose the collection of the corresponding information or the display of the corresponding notifications. Of course, if you do that, certain services may lose full functionality.

  3. Deletion. You can delete your account by using the corresponding functionality directly on the service.

  1. We want you to be aware of your privacy rights. Here are a few key points to remember:

    1. Reviewing your information. Applicable privacy laws may give you the right to review the personal information we keep about you (depending on the jurisdiction, this may be called right of access, right of portability or variations of those terms). You can request a copy of your personal information by putting in such a request (place link)

    2. Updating your information. If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion or object to its processing, please contact us (Place Link)

  2. For your protection and the protection of all of our Users, we may ask you to provide proof of identity before we can answer the above requests.

  3. Keep in mind, we may reject requests for certain reasons, including if the request is unlawful or if it may infringe on trade secrets or intellectual property or the privacy of another User. If you wish to receive information relating to another User, such as a copy of any messages you received from him or her through our service, the other User will have to contact our Privacy Officer to provide their written consent before the information is released.

  4. Also, we may not be able to accommodate certain requests to object to the processing of personal information, notably where such requests would not allow us to provide our service to you anymore. For instance, we cannot provide our service if we do not have your date of birth.

i. Uninstall. You can stop all information collection by an app by uninstalling it using the standard uninstall process for your device. If you uninstall the app from your mobile device, the unique identifier associated with your device will continue to be stored. If you re-install the application on the same mobile device, we will be able to re-associate this identifier to your previous transactions and activities.

12. RESIDENTS OF CALIFORNIA

If you are a California resident:

  1. You can request a notice disclosing the categories of personal information about you that we have shared with third parties for their direct marketing purposes during the preceding calendar year. To request this notice, please submit your request (Link) Please allow 30 days for a response. For your protection and the protection of all of our Users, we may ask you to provide proof of identity before we can answer such a request.

  2. You have the right to:

    1. Know what information is being collected;

    2. Know what information is sold or shared;

    3. Op-out of selling or sharing of your information;

  1. Limit the use of sensitive personal information;

  2. Have specific pieces of information deleted;

  3. Have personal information corrected;

  4. Not be retaliated against for exercising any of your rights.

13. HOW WE PROTECT YOUR INFORMATION

We work hard to protect you from unauthorized access to or alteration, disclosure or destruction of your personal information. As with all technology companies, although we take steps to secure your information, we do not promise, and you should not expect, that your personal information will always remain secure.

We regularly monitor our systems for possible vulnerabilities and attacks and regularly review our information collection, storage and processing practices to update our physical, technical and organizational security measures.

We may suspend your use of all or part of the services without notice if we suspect or detect any breach of security. If you believe that your account or information is no longer secure, please notify us immediately (Link)

14. HOW LONG WE RETAIN YOUR INFORMATION

We keep your personal information only as long as we need it for legitimate business purposes (as laid out in Section 5 and as permitted by applicable law. To protect the safety and security of our Users on and off our services, we implement a one-year safety retention window following account deletion. During this period, account information will be retained although the account will of course not be visible on the services anymore.

In practice, we delete or anonymize your information upon deletion of your account (following the safety retention window) or after two years of continuous inactivity, unless:

  1. we must keep it to evidence our compliance with applicable law (for instance, records of consents to our Terms, Privacy Policy and other similar consents are kept for five years);

  2. there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or

  3. 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 behavior or security incidents from opening a new account.

    Keep in mind that even though our systems are designed to carry out data deletion

processes according to the above guidelines, we cannot promise that all data will be deleted within a specific time frame due to technical constraints.

15. CHILDREN’S PRIVACY

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Our services are restricted to Users who are 18 years of age or older. We do not permit Users under the age of 18 on our platform and we do not knowingly collect personal information from anyone under the age of 18. If you suspect that a User is under the age of 18, please use the reporting mechanism available through the service.

16. PRIVACY POLICY CHANGES

Because we’re always looking for new and innovative ways to help you build meaningful connections, this policy may change over time. We will notify you before any material changes take effect so that you have time to review the changes.

17. HOW TO CONTACT US

If you have questions about this Privacy Policy, or if you would like to submit requests for the disclosure, deletion or correction of information, please contact us at:

customerservice@matchmakersusa.com

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