PRIVACY POLICY

Last Updated: November 13, 2024

This Privacy Policy (“Privacy Policy” or “Policy”) explains how SuccessfulMatch.com, Inc., a California corporation, with its principle place of business at 800 West El Camino Real, #180, Mountain View, California 94040 USA (“Company”, “We”, “Us” or “Our”) may gather, collect, record, hold, distribute, share, disclose, or otherwise use any information or data about any user (“User” or “You” or “Your”) of the Company’s website at www.seniormatch.com (“Company Website”) or through any other site, program, activity, technology platform, technology application, or service offered by Company (the Company Website and these other programs, activities, platforms, applications, and services are collectively referred to as “Company Program(s)”).

BY CONTINUING TO USE THE COMPANY WEBSITE OR ANY OTHER COMPANY PROGRAM OFFERED BY THE COMPANY, YOU HEREBY AGREE TO BE BOUND BY ALL OF THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY AS IT IS PRESENTED TO YOU AS OF THE DATE OF YOUR FIRST USE OF THE COMPANY WEBSITE OR ANY OTHER COMPANY PROGRAM.

NO CHANGES (ADDITIONS OR DELETIONS) BY YOU TO THIS POLICY WILL BE ACCEPTED BY THE COMPANY. IF YOU DO NOT AGREE TO ALL THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY, OR YOU DO NOT WISH YOUR PERSONAL INFORMATION TO BE USED PURSUANT TO THIS PRIVACY POLICY, THEN YOU SHOULD NOT USE ANY OF THE COMPANY WEBSITE OR ANY OTHER COMPANY PROGRAM, AND YOU SHOULD NOT PROVIDE ANY OF YOUR PERSONAL INFORMATION TO THE COMPANY.

THIS IS A BINDING CONTRACT BETWEEN YOU AND THE COMPANY, AND YOU SHOULD DOWNLOAD AND PRINT THIS PRIVACY POLICY FOR YOUR RECORDS.

1. INFORMATION WE COLLECT.

During a User’s access or use of the Company Website or any other Company Program, the Company may, either directly or by using its Service Providers/Contractors (as defined below), gather, collect, record, hold, distribute, share, disclose, or otherwise use personal information or data about You that You provide to Us, as described in Section 1.1 below, that is automatically collected, as described in Section 1.2 below, or that is collected or received from other sources, as described in Section 1.3 below (hereinafter collectively referred to as the User’s “Personal Information”, subject however, to Section 1.4 herein).

 1.1  INFORMATION THAT YOU PROVIDE TO US.

We collect Personal Information that You provide directly to Us, including without limitation any Personal Information You provide during Your use of the Company Website or any other Company Program. For example, We may collect Personal Information from You if You:

• Provide Us with any data about You through the Company Website or through any other Company Program, including without limitation creating an account (including a user name and/or password) with Us and providing data to Us via Your account;
• Seek, purchase, procure, use, or otherwise request any of the Company’s services, goods, or products (hereinafter collectively referred as the Company’s “products/services”);
• Seek any information about Your purchase, procure, exchange, or return of, or Your refund related to, any of the Company’s products/services;
• Request any customer support;
• Request any exchange or return of, or refund for, any of the Company’s products/services;
• Request, subscribe to, or otherwise choose (if applicable now or in the future) to receive any information from or about the Company, such as signing up for and receiving any newsletter, e-alert, blogs, or any other information about the Company, Our products/services, events (collectively referred to as “Newsletters/Blogs”), and/or business partners, including our affiliates as defined below;
• Choose to participate (if applicable now or in the future) in any of the Company’s contests, loyalty programs, promotions, or sweepstakes (collectively referred to as “Contests/Sweepstakes”);
• Choose to participate (if applicable now or in the future) in any of the Company’s customer surveys, customer forums or other information gathering activities or events with Our Customers (collectively referred to as “Customer Surveys”);
• Choose to participate in or otherwise communicate with the Company via any social media activities, offerings, or features which may be made available through Your use of any of the Company’s Programs;
• Fill out any other information through any Company Program;
• Communicate with any other representatives of Our Company; or
• Otherwise communicate with Us in any other way.

In these instances, the following are the types of Personal Information that may be collected from You:

• Your name;
• Your mailing address and/or billing address and/or shipping address;
• Your email address;
• Your phone (or mobile) number;
• Your date of birth or age;
• Your account name and/or account password;
• Your credit or debit card number, expiration date, security code, and/or other information about the same (if You make a payment either directly to Us or by using a third party payment provider that handles payments and will receive Your payment card information);
• Information about Your bank or checking account (if You make a payment through Your bank transfer);
• Gift card information or related gift information;
• Your title/position at place of employment, and any membership in professional associations;
• Your government issued identification including Your driver’s license and/or passport number;
• Your gender, race, national origin, religious or philosophical beliefs, marital status, sexual orientation,  citizenship, educational levels, military status/service, disability/other medical condition; 
• Your user name/password for Your account;
• Your income information, any credit rating information, or any related passwords to access this information;
• Photos, videos, audio or similar content uploaded by You;
• The history of Your prior purchases or procurements of Our product/services or any records about the foregoing;
• Other information You may provide when set up Your account or otherwise seeks, purchase, procure or otherwise request any of the Company’s products/services, such as scope of the products/services You decided to use, Your preferences when using any of the Company’s products/services, and of Your end user comments about the Company’s products/services, and/or  the date of Your use of any such Company products/services; 
• Other information You provide or otherwise used in the return or exchange of, refund for, of the Company’s products/services, such as information about the transaction, products/services details, procurement price, and the date and location/media of the transaction;
• If You choose to subscribe, receive, or otherwise participate in any Newsletters/Blogs (as defined above in this Section 1.1), We may collect from You, in addition to the above described Personal Information, additional information from and/or about You, such as additional demographic information or other information You may provide as part of Your participation in any such Newsletter/Blogs.
• If You choose to participate in any Contest/Sweepstakes (as defined above in this Section 1.1), We may collect from You, in addition to the above described Personal Information, additional information from and/or about You, such as additional information necessary to determine if You are eligible to participate in Contest/Sweepstakes or to otherwise facilitate the Contest/Sweepstakes.

• If You choose to participate in any Customer Surveys (as defined above in this Section 1.1), We may collect from You, in addition to the above described Personal Information, additional information from and/or about You, such Your purchase history, habits, and/or preferences or other information You may provide as part of Your response or feedback to the Customer Surveys;
• Without limiting the foregoing descriptions in any way, and for clarity, as part of Your use of the Company’s products/services:
• We collect special categories of personal data about You (which may include details about Your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, and information about Your health (collectively referred to as “Special Categories”); and
• Your Personal Information which We collect may also include any other information You provide in Your profile data or otherwise include in your account,, including without limitation identifiers such as Your first name, last name, marital status, age, gender, sexual orientation, other information and preferences You decide to add to Your profile, including financial data, Special Categories (as defined above), blog posts, audio, electronic, or visual information such as photos used in connection with Your account, education information, professional or employment-related information, government-issued identification, and any other information You provide in relation to services You request, such as photograph verification; profile data also includes inferences based on the information described above and other information described in this Privacy Policy.

1.2  INFORMATION THAT IS AUTOMATICALLY COLLECTED.

When a User accesses or otherwise uses the Company Website or any other Company Program, We may automatically collect certain Personal Information about You, including:

• Device Information. We (or Our Service Providers/Contractors as defined below in Section 3) may collect information about the computer, tablet, phone, or other device You use to access any of the Company Programs, including the Internet Protocol address, hardware models, operating system and version, mobile network information, and other unique device identifiers.
• Cookies and Other Web-based Tracking Technologies. We (or Our Service Providers/Contractors as defined in Section 3 herein) may use different technologies such as cookies, web beacons, or other types of small temporary files or web-based tracking technologies to gather certain information. A cookie is a small data file stored by Your web browser on Your computer or mobile device (hard drive) that helps Us to improve the way We deliver Our Company Website or other Company Programs to You, helps Us improve Your overall experience using Our Company Website or other Company Programs, and/or helps Us analyze the areas and features of Our Company Programs that are most popular or to detect fraud. Web beacons are electronic images that may be used in Our Company Programs or emails and help deliver cookies, count visits, and understand usage. Like many other websites, cookies and these other web-based tracking technologies may be used by Us (or Our Service Providers/Contractors) during Your visit to the Company Website or other Company Program in order to improve Your individual experience as a User of the Company Website or other Company Program or to generally improve or enhance the overall functionality of the Company Website or other Company Program. While most websites automatically accept cookies for these purposes, You may be able to instruct Your browser to stop accepting cookies or prompt You before accepting a cookie from the sites You visit, including the Company Website. SEE SECTION 5.6 OF THIS PRIVACY POLICY WHICH PROVIDES FURTHER NOTICE ABOUT HOW THESE COOKIES ARE USED AND PROVIDES INSTRUCTIONS IF YOU WANT TO DISABLE ANY OF THESE COOKIES.
• Geo-location Data. Subject to any of Your device permissions, We (or Our Service Providers/Contractors as defined below) may be able to collect information about the precise location of Your device or may gather other general location data based on GPS data, mailing address, and/or billing address (hereinafter collectively referred to as “Geo-location Data”).
• Social Media Information. If any social media activities, offerings, or features, such as the Facebook “Like” button or similar social media interactive programs ( collectively, “Social Media Activities”), are made available to You through any of the Company’s Programs, and in addition to the collection of other Personal Information noted above, the following may apply:

• We may obtain and collect certain information from Your social media account consistent with Your settings within the social media service, such as location, check-ins, activities, interests, photos, status updates, and friends list. We may also allow You to enter into contests to provide photos, such as of products/services You have purchased or procured, which You may share with Your connections on social media for votes, shared offers, or other promotions.
• A third party that is hosting the Social Media Activities may also collect Your Internet Protocol address, which page You are visiting on Our Company Program, Your Geo-location Data, and other Personal Information about You, and may also set a cookie to enable the feature to function properly.
• These Social Media Activities may be hosted by a third party or hosted directly on Our Company Program. Thus, Your interactions with these Social Media Activities may be governed by the privacy policies of the third party that is hosting the Social Media Activities (see Section 8 regarding Third Party Sites).

1.3  ADDITIONAL SOURCES FROM WHOM OR WHERE WE MAY RECEIVE OR COLLECT INFORMATION ABOUT YOU.

In addition to the Personal Information provided by You as described in Section 1.1 and in addition to the collection of Personal Information as described in Section 1.2, the following are additional ways We may collect Personal Information about You or additional sources from which We may receive Personal Information about You:

• From our Affiliates. From our Affiliates, as such term is defined in Section 3 of this Privacy Policy.
• From our Related Parties. From our Related Parties, as such term is defined in Section 3 of this Privacy Policy.
• From Our Service Providers/Contractors. From Our Service Providers/Contractors, as such term is defined in Section 3 herein, including without limitation from Our Traffic Influencers, Our Data Analytics Providers and/or from Our Third Party Application Providers, as such terms are defined in Section 3 of this Privacy Policy.
• From Our Advertising Network. From Our Advertising Network, as such term is defined in Section 3 of this Privacy Policy.
• Individuals Representing Businesses. We may collect Personal Information in the context of Your role as a representative of a business. The Personal Information We collect in these cases may include name, address, email address, telephone, date of birth, gender, Social Security number, and personal financial information. We use this information for communicating with You in Your role as a representative of a business or if You are an owner of a business to evaluate Your creditworthiness.
• Other Sources From Which We Collect Personal Information. We may collect Personal Information about You from a number of sources in addition to those means of collection indicated above, including offline or through sources unrelated to Your use of Our Company Website or other Company Programs. For example, We may collect Personal Information from publicly accessible sources (e.g., property records); directly from a third party, (e.g., credit reporting agencies or customer due diligence providers); or from a third party with Your consent (e.g., Your bank). We may merge or co-mingle that Personal Information with the Personal Information We maintain about You and other data collected on or through Our Company Website. Categories of sources from which We may collect Personal Information include: advertising networks; internet service providers; data analytics providers; government entities; operating systems and platforms; and social networks.
  • EXCLUSIONS FROM PERSONAL INFORMATION SUBJECT TO THIS PRIVACY POLICY.

“Personal Information” for purposes of this Privacy Policy does not include any of the following types of information: (i) publicly available information from government records; or (ii) de-identified or aggregated consumer information, including without limitation any of the Aggregated Data as defined in Section 3 below; or (iii) any information that, pursuant to the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CCPA”), is excluded from the CCPA’s governance, including without limitation any of the following information: (a) any health information or medical information covered or otherwise subject to the U.S.  Health Insurance Portability and Accountability Act of 1996 and its related regulations  (HIPAA) and any  health information or medical information covered by or otherwise subject to the California Confidentiality of Medical Information Act and its related regulations (CMIA); or (b) any information covered by certain other sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA), the California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

2. HOW WE USE YOUR PERSONAL INFORMATION.

2.1  PRIMARY WAYS WE USE YOUR INFORMATION. In addition to Section 1 above, a User’s Personal Information may be gathered, collected, recorded, held, processed, or otherwise used by or on behalf of the Company (including by Our Service Providers/Contractors as defined in Section 3below) to provide, maintain, and improve Our Services to You, including for the following purposes:

• To manage Your account;
• To provide You with our products/services, including without limitation providing You with customer services;
• To help Us maintain Our products/services, including without limitation helping Us with security, troubleshooting, testing, system maintenance, support, reporting, hosting of data, and blocking unauthorized users;
• To send support and administrative messages, and respond to Your comments, questions, and customer service requests;
• To otherwise communicate with You via email or through other means of communication about products/services, offers, or any other events offered by Us and others, and/or to offer and provide You with news and information that the Company thinks will be of interest to You. If You prefer not to receive promotional communications from Us, You may opt-out at any time by following the “Communication Opt Out” instructions in Section 5.1 herein;
• To allow You to sign up and participate in any other Company communication resources, including without limitation any Newsletters/Blogs, as defined in Section 1.1 herein, which may exist now or in the future. If You prefer not to continue to receive these other Company communications, You may “Opt Out” at any time by following the “Opt Out” instructions in Section 5.1 herein;
• To allow Us to monitor, analyze, and better understand the needs, preferences, and trends of the Company’s customers, You, and/or any other Users, including to monitor, analyze, and better understand trends, preferences, usage, and activities in connection with the Company’s products/services and the Company’s overall industry;
• To personalize Your experience and the advertisements and content You see when You use any Company Program based on Your preferences, interests, usage, and browsing and purchasing behavior;
• To allow Us to perform credit checks or to conduct credit card screenings or to otherwise protect against fraud or unauthorized transactions, including by identifying potential unauthorized users or hackers;
• For compliance purposes as may be required by applicable laws or regulations or as requested by any judicial process or governmental agency (including without limitation for Company’s tax reporting) or as may be requested under any subpoena or by any other Government Entities (as defined in Section 2.2 herein);
• To facilitate Your use of or participation in various Social Media Activities (as defined in Section 1.2 herein) or other integrated tools (including, for example only, certain Facebook features, such as a Facebook “Like” button) which You may use as part of any Social Media Activities;
• To facilitate Our Contests/Sweepstakes (as defined in Section 1.1 herein), which may exist now or in the future;
• To carry out any Customer Surveys (as defined in Section 1.1 herein); or
• To carry out any other purpose described to You at the time the Personal Information is collected.

2.2  OTHER WAYS WE MAY USE YOUR INFORMATION.  In addition to the above, Your Personal Information may be gathered, collected, recorded, held, or otherwise used for the following additional purposes:

• Outside Professionals. To use with, or otherwise distribute, share, or disclose to, any of the Company’s professional advisors such as attorneys, accountants, financial advisors, investment plan administrators, or insurance providers (which for purposes of this Privacy Policy and its Appendices are hereinafter collectively defined and referred to as “Outside Professionals”) in order to facilitate the professional advice from those Outside Professionals (See Section 3); or
• Government Entities. To use with, or otherwise distribute, share, or disclose to, any court, tax authorities, law enforcement authorities, other administrative agencies, other governmental agencies, or any other government entities (which for purposes of this Privacy Policy and its Appendices are hereinafter collectively defined and referred to as “Government Entities”) in order to comply with, or otherwise pursuant to, any subpoena, court order, or other governmental order, law, or regulation, or in order to respond to any request of any Government Entities, including without limitation tax reporting (See Section 3).
• Auditing. Auditing related to a current interaction with You, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards;
• Security. Helping to ensure security and integrity to the extent the use of Your Personal Information is reasonably necessary and proportionate for these purposes;
• Debugging. Debugging to identify and repair errors that impair existing intended functionality;
• Transient Use. Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of a consumer’s current interaction with Us provided that Your Personal Information is not disclosed to a third party and is not used to build a profile about You or otherwise alter Your experience outside the current interaction with Us;
• Services. Performing services on Our behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on Our behalf;
• Advertising. Providing advertising and marketing services to You.
• Research. Undertaking internal research for technological development and demonstration;
• Quality and Safety. Undertaking activities to verify or maintain the quality or safety of Our products and services and to improve, upgrade, or enhance Our products and services; and
• Commercial Interests. Advancing Our commercial or economic interests, such as by inducing a person to buy, rent, lease, join, subscribe to, provide, or exchange products, goods, property, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction.

2.3  OTHER TERMS REGARDING THE USE OF YOUR INFORMATION.

2.3.1  The Company may also use or share Your Personal Information only for the purposes as described in this Section 2 and in Section 3 herein, unless We reasonably determine We need to use it for another reason and that reason is compatible with the original purpose(s) described herein. For example, We consider de-identification, aggregation, and other forms of anonymization of Personal Information to be compatible with the purposes listed herein and in Your interest because the anonymization of such information reduces the likelihood of improper disclosure of that information. If We need to use Your Personal Information for an unrelated purpose, We will notify You and We will explain the legal basis which allows Us to do so. If You wish to receive an explanation as to how the processing for a particular purpose is compatible with the original purpose, please contact Us via the information specified in the Contact section below.

2.3.2  PLEASE NOTE THAT WE MAY PROCESS YOUR PERSONAL INFORMATION WITHOUT YOUR KNOWLEDGE OR ADDITIONAL CONSENT IN COMPLIANCE WITH THIS PRIVACY POLICY AND WHERE DOING SO IS REQUIRED OR PERMITTED BY LAW INCLUDING WITHOUT LIMITATION ANY SUBPOENA OR OTHER TYPE OF COURT ORDER.

2.4  AUTOMATED PROCESSING AND CONTENT MODERATION.

Our platform utilizes a range of automated systems to enhance user experience, maintain a safe and welcoming community, and optimize service efficiency. These automated tools may include, but are not limited to, the following functions:

• Monitoring and moderating user-generated content to identify and filter out content that violates our guidelines, including detecting explicit material or inappropriate language.
• Verifying user-provided images and information to enhance authenticity and protect against fraud or impersonation.
• Providing personalized recommendations, tailored content, and customized service responses based on user interactions and feedback.
• Supporting customer service and feedback analysis to improve our services and address user inquiries promptly.

3. SHARING OF INFORMATION.

We may distribute, share, or disclose Personal Information about You as follows or as otherwise described herein:

• Affiliates. We may share or disclose, for any of the purposes described in this Privacy Policy, Your Personal Information with Our parent company, Our subsidiaries, or Our other entities that are Our affiliates (which may exist now or in the future), including without limitation other dating sites that We may own or We may have control over (which for purposes of this Privacy Policy and its Appendices are hereinafter collectively defined and referred to as “Affiliates”).
• Related Parties. We may share or disclose, for any of the purposes described in this Privacy Policy, Your Personal Information with other dating sites that We may have a business relationship with but do not necessarily have an ownership interest in or do not necessarily have any control over (which for purposes of this Privacy Policy and its Appendices are hereinafter collectively defined and referred as “Related Parties”);
• Traffic Influencers. We may share or disclose Your Personal Information, for any of the purposes described in this Privacy Policy, with individuals or entities with whom We may engage or have a business relationship with in order to try to attract traffic to the Company Website, to any of the other Company Programs, or to any other websites controlled by our Affiliates and Subsidiaries (as defined above in this Section 3).
• Service Providers/Contractors. We may share, distribute, or disclose Your Personal Information to or with service providers or contractors that the Company engages or retains in connection with the provision of the Company Programs or otherwise to help Us carry out and fulfill a business or commercial purpose for the Company, including without limitation the following types of service providers or contractors that We may engage or retain (which for purposes of this Privacy Policy and its Appendices are hereinafter collectively defined and referred to as “Service Providers/Contractors”).
  • Email, internet, or other telecommunication Service Providers/Contractors, including website hosting;
  • Cloud, other data storage, or other hosting Service Providers/Contractors;
  • Third party payment Service Providers/Contractors, including without limitation third party credit card processors (see Third Party Application Providers below in this Section 3);
  • Data analytics companies who assist Us with various types of data analytics, web analytics, and app analytics (see Data Analytics Providers and Data Analytics Tools or Services below in this Section 3);

Other third party contractors or service providers We engage to assist Us in providing Our products/services;

• App designers;
• Database management;
• Third party advertising or marketing companies that We engage (see Advertising Networks below in this Section 3); and
• The Traffic Influencers as defined above in this Section 3.
• Third Party Application Providers. If a third party application is used to support Our Company Programs, We may share or disclose Your Personal Information to such third party application providers, including without limitation third party credit card processors, other third party payment service providers, or intermediary services that assist in processing Your payments service provider (which for purposes of this Privacy Policy and its Appendices are hereinafter collectively defined and referred to as “Third Party Application Providers”).
• Data Analytics Providers and Data Analytics Tools or Services. We may use analytics tools or services provided by a third party data analytics service provider (which for purposes of this Privacy Policy and its Appendices are hereinafter collectively defined and referred to as “Data Analytics Providers”) or by using one of their tools, such as, but not limited to Google Analytics, to collect and process certain analytics data (which for purposes of this Privacy Policy and its Appendices are hereinafter collectively defined and referred to as “Data Analytics Tools or Services”). These Data Analytics Tools or Services may also collect data about Your use of other websites, apps, and online resources. SEE SECTION 5.6 OF THIS PRIVACY POLICY THAT PROVIDES FURTHER NOTICE ABOUT HOW SOME OF THESE DATA ANALYTICS PROVIDERS AND DATA ANALYTICS TOOLS OR SERVICES MAY USE COOKIES AND PROVIDES INSTRUCTIONS IF YOU WANT TO DISABLE ANY OF THESE COOKIES.
• Advertising Network. We may work with third party advertising companies or marketing companies or sales representative organizations (which for purposes of this Privacy Policy and its Appendices are hereinafter collectively defined and referred to “Advertising Network”) in order to provide You or other parties with advertisements, marketing, or other information that We think may be of interest to You or to others. These Advertising Networks may set or access their own cookies, pixel tags, or similar technologies on Our Company Programs or they may otherwise collect or have access to data about You that they may collect over time and across different online services. These Advertising Networks may also provide Us with their own independent data about potential customers and such data could include data about You previously collected by the Advertising Network.
• Aggregated Form. We may make, create, or collect certain aggregated or otherwise de-identified Personal Information and use it for the Company’s purposes or make it available to third parties for various other purposes, including (i) compliance with various reporting obligations; (ii) for business or marketing purposes, including without limitation evaluating industry trends, consumer trends or improving our products/services; or (iii) to assist such parties in understanding Our Users’ interests, habits, and usage patterns for certain programs, content, services, advertisements, promotions, and/or functionality available through the Company Programs (collectively “Aggregated Data”). Without limiting the foregoing in any way, such Aggregated Data that is derived from Personal Information is not considered to be “Personal Information” under this Privacy Policy because it has been de-identified and does not directly or indirectly reveal Your identity.
• Social Media Activities. The Company Programs may, now or in the future, offer certain Social Media Activities (as defined in Section 1.2 above), including without limitation certain sharing tools or other integrated tools (such as the Facebook “Like” button), which let You share actions that You take on Our social media pages. Your use of such features enables the sharing of Personal Information with the public, depending on the settings You establish with the entity that provides the social sharing feature.
• Company’s Outside Professionals. We may share or disclose Your Personal Information with any of the Company’s Outside Professionals (as defined in Section 2.2 herein) in order to facilitate the professional advice such Outside Professionals provide to the Company.
• Consent. We may also share or disclose Your Personal Information with Your permission.
• Merger, Sale, or Other Asset Transfers. We may share, disclose, or otherwise transfer Your Personal Information to the Company’s Outside Professionals (as defined in Section 2.2 herein), other advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which We are acquired by or merged with another company or We sell, liquidate, or transfer all or a portion of Our assets.
• Government Entities or as Otherwise Required By Law, Subpoena, or Similar Government Order. We may use, distribute, share, disclose, access, or preserve Your Personal Information if We believe doing so is required or appropriate to: (i) comply with all laws or regulations, including any tax reporting requirements of the Company; (ii) comply with any other law enforcement requests or legal process or requirements of any Government Entities (as defined in Section 2.2 above), such as a court order or subpoena; (iv) comply with any other form of request from any Government Entities; (v) respond to Your requests; or (vi) protect Your, Our, or others’ rights, property, or safety. FOR THE AVOIDANCE OF DOUBT, WE MAY BE REQUIRED TO DISCLOSURE YOUR PERSONAL INFORMATION TO: (I) TAXING AUTHORITIES AS PART OF OUR TAX REPORTING REQUIREMENTS; OR (II) LAW ENFORCEMENT AUTHORITIES OR OTHER GOVERNMENTAL ENTITIES OR VIA SUBPOENA ARISING OUT OF YOUR USE OF ANY UNLAWFUL OR INFRINGING CONTENT WHILE USING ANY COMPANY PROGRAM.

4. CHILDREN; COPPA NOTICE.

This Company Website and other Company Programs are not directed to children under the age of 13. We adhere to the U.S. federal Children's Online Privacy Protection Act ("COPPA") and will not knowingly register or otherwise collect any Personal Information from any child under the age of 13. We ask that minors under the age of 13 not submit any Personal Information to the Company. If You have reason to believe a child under the age of 13 has provided the Company with any Personal Information, please contact the Company at this email address support<AT>SeniorMatch.com or contact us and request that such information be deleted from Our records.

5. CERTAIN ADDITIONAL CHOICES YOU MAY HAVE ABOUT YOUR INFORMATION.

5.1  OPT-OUT FROM RECEIVING COMMUNICATIONS FROM THE COMPANY.

5.1.1  YOU CAN OPT-OUT FROM RECEIVING COMMUNICATIONS FROM THE COMPANY. In the event a User has provided the Company with Personal Information such as that discussed above, and thereafter a User does not want to continue to directly receive further notices, or information or communications from the Company, such as emails or newsletters related to the Company’s products/services, the User must send an email message to support<AT>SeniorMatch.com or contact us and stating that the User no longer wants to receive these communications directly from the Company (“Communication Opt Out”). Once the Company has received the User’s request for the Communication Opt Out, the Company will use commercially reasonable efforts, in a commercially reasonable time period, to try to carry out such User’s request for the Communication Opt Out; provided, however, the Company will not have any obligation to retrieve, and cannot prevent the further use by others of, such User’s Personal Information that may have been shared up to that time with other parties as permitted by the provisions of this Privacy Policy.

5.1.2  EFFECT OF COMMUNICATION OPT OUT.  If a User elects to send the Company a Communication Opt Out (as defined in Section 5.1.1), and provided such User has properly delivered its Communication Opt Out request to the Company in accordance with Section 5.1.1 herein, such User will no longer receive emails or other communications directly from the Company after a commercially reasonable time from the date such User sent its Communication Opt Out notice to the Company. However, the Company does not have any obligations under, or liability arising out of, this Privacy Policy with regard to a User’s decision to share its Personal Information with, Our use of, any other internet websites, forums, or programs that the User may have linked to via the Company Website that are not under the Company’s direct control or ownership. Accordingly, after sending Your Communication Opt Out notice to the Company, You may need to contact these other entities directly regarding their use of Your Personal Information.

5.2  OPT-OUTING OF BEHAVIORAL ADVERTISING OR USE OF ANALYTICS TOOLS.

5.2.1  OPTING OUT OF BEHAVIORAL ADVERTISING.  Our Company Website or other Company Programs may use behavioral advertising. This means that a third party may use technology (e.g., a cookie) to collect information about Your use of the Company Website or other Company Programs so that they can provide advertising about products and services tailored to Your interests. That advertising may appear either on the Company Website or other Company Program(s), or on other websites not operated by Us. If You do not want third parties to collect information about Your use of the Company Website or other Company Program(s), You can opt-out of such at the Digital Advertising Alliance in the US, the Digital Advertising Alliance of Canada in Canada, or the European Digital Advertising Alliance in Europe. PLEASE NOTE THAT OPTING-OUT OF BEHAVIORAL ADVERTISING DOES NOT MEAN THAT YOU WILL NOT RECEIVE ADVERTISING WHILE USING OUR COMPANY WEBSITE OR OTHER COMPANY PROGRAM(S). IT WILL, HOWEVER, EXCLUDE YOU FROM INTEREST-BASED ADVERTISING CONDUCTED THROUGH PARTICIPATING NETWORKS, AS PROVIDED BY THEIR POLICIES AND CHOICE MECHANISMS.

5.2.2  OPTING OUT OF USE OF ANALYTICS.  Many analytics providers allow end-users to opt out of the retention of their information, including Our third-party Data Analytics Providers (as defined in Section 3 herein). Please note that, typically, unless You create an account with the analytics provider, Your choice to opt out applies only to the device from which You make the request, because the providers use cookies on that device to recognize Your choice. If You get a new device, install a new web browser, update Your browser, or otherwise erase/alter Your browser cookie files You may clear the opt-out cookie. 

5.3  DO NOT TRACK NOTICE.

Some browsers have a “DO NOT TRACK” feature that lets website users inform websites or other applications that they do not want to have their online activities tracked. These “do not track” features may also give website users other choices regarding the collection of their personal identifiable information. However, these “do not track” features and “do not track’ signals are not yet uniform. ACCORDINGLY, EACH USER OF THE COMPANY WEBSITE OR ANY OTHER COMPANY PROGRAM IS HEREBY NOTIFIED THAT THE COMPANY WEBSITE AND THE OTHER COMPANY PROGRAMS ARE NOT CURRENTLY SET UP TO RESPOND TO ANY OF THE USER’S “DO NOT TRACK” FEATURES OR “DO NOT TRACK” SIGNALS. This “DO NOT TRACK” notice is provided to Users at the recommendation of the U.S. Federal Trade Commission and to residents of the State of California as required pursuant to the California Online Privacy Protection Act (CalOPPA).

5.4  GEO-LOCATION DATA.

You may be able to prevent Your device from sharing precise location information, including without limitation some or all of the Geo-Location Data described in Section 1.2 above, at any time through Your device’s operating system settings.

5.5  HOW YOU CAN ACCESS OR CORRECT YOUR PERSONAL INFORMATION.

You can ask Us to correct Your Personal Information by sending an email to Us at support<AT>SeniorMatch.com or contact us  and by identifying the error and the correction. For example, You can ask Us to correct factual errors in your Personal Information by sending Us the above described request provided, however, your request credibly shows the error.

5.6  HOW YOU CAN DISABLE YOUR ACCOUNT OR REQUEST THAT YOUR ACCOUNT BE DELETED.

5.6.1  HOW YOU CAN DISABLE YOUR ACCOUNT. You can disable Your account: (i) by using the "disable account" feature on the Company Website settings page; or (ii) by sending a request to Us that We disable Your account by emailing Us at support<AT>SeniorMatch.com or contact us. When Your account is disabled, Your account will be removed from Our service and it will no longer be viewable by other users or the public. You may reactivate Your account by logging into Company Website with Your current email and password.

5.6.2  HOW YOU CAN REQUEST THAT YOUR ACCOUNT BE DELETED. You can delete Your account (which would delete Your Personal Information): (i) by using the "delete account" feature on the settings page (provided it is no longer necessary for legal purposes or to provide services to you); or (ii) by sending a request to Us that We delete Your Account by emailing Us at support<AT>SeniorMatch.com or contact us.  IF YOU REQUEST THAT YOUR ACCOUNT BE DISABLED:

• ANY OUTSTANDING ORDER OR TRANSACTION OR OTHER PRODUCTS/SERVICES WE PROVIDE WILL BE IRREVOCABLY TERMINATED;
• YOU WILL NOT BE ABLE TO RESTORE OR GET ACCESS TO YOUR ACCOUNT OR RETRIEVE YOUR PERSONAL INFORMATION UPON DELETION; PROVIDED, HOWEVER, WITHIN 6 MONTHS OF YOUR REQUEST TO DELETE YOU CAN CONTACT US (USING THE EMAIL ADDRESS SET FORTH ABOVE IN THIS SECTION 5.5) TO REVOKE YOUR DELETE REQUEST AND WE WILL MAKE A REASONABLE EFFORT TO DO SO BUT WILL NOT BE LIABLE IF WE CANNOT CARRY OUT YOUR REVOCATION REQUEST.

5.7  USE OF COOKIES; HOW TO DISABLE COOKIES.

5.7.1  What Are Cookies? As is common practice with almost all professional websites this Company Website or other Company Program use cookies, which are tiny files that are downloaded to your computer, to improve your experience. This section describes what information they gather, how We use it and why We sometimes need to store these cookies. We will also share how you can prevent these cookies from being stored however this may downgrade or ‘break’ certain elements of a website’s functionality.

5.7.2  How We Use Cookies. We may use a variety of technologies such as cookies, web beacons, embedded scripts, or other technologies to collect data about visits to and the users of our service and interactions with our emails and online and mobile advertisements, to allow us to keep track of analytics and certain statistical information. Please consult our Cookie Policy for more information (“Our Cookie Policy”). The provisions of our Cookie Policy is hereby incorporated by reference into this Privacy Policy by this reference.

5.7.3  How to Disable Cookies. Please consult Our Cookie Policy regarding how You could disable certain cookies

6. ENFORCEMENT OF THIS PRIVACY POLICY BY COMPANY.

Each User confirms and agrees that by the User’s act of using any of the Company Programs, including without limitation uploading any of the User’s Personal Information or any other content via any Company Program, the User: (a) unconditionally agrees to all of the terms and conditions of this Privacy Policy; and (b) further agrees that no provision of this Privacy Policy shall limit, condition, alter, or amend, in any way whatsoever, any rights that User may have separately granted to the Company pursuant to any other agreement that the User may have separately entered into with the Company.

7. USER RESPONSIBLE FOR UPDATING USER’S OWN PERSONAL INFORMATION.

Users are solely responsible for correcting, updating, or modifying any and all of the User’s Personal Information as it appears in, and as otherwise stored or contained in, any Company Program. Without in any way limiting the foregoing, User acknowledges and agrees that the Company does not have an independent obligation to maintain the accuracy or completeness of any of Personal Information provided by the User to the Company, including such Personal Information once it is stored, described, or otherwise contained in the Company Website or in any other Company Program.

8. LINKS TO, AND USE OF, THIRD PARTY SITES OR PROGRAMS.

The Company Website or other Company Programs may now or in the future provide links or other access to Internet websites, forums, or other programs that are not under the Company’s sole control and not solely owned by the Company (collectively referred to as “Third Party Sites”). If a User clicks on a link to, or otherwise gains access to, any such Third Party Site, the User will be transported to one of these Third Party Sites.  THIS PRIVACY POLICY ONLY APPLIES TO THE COMPANY WEBSITE AND THE OTHER COMPANY PROGRAMS DIRECTLY OWNED BY THE COMPANY. THEREFORE, THIS PRIVACY POLICY: (A) DOES NOT DESCRIBE THE PRIVACY POLICIES OF ANY OF THESE THIRD PARTY SITES; AND (B) DOES NOT GOVERN THE COLLECTION OR USE OF YOUR PERSONAL INFORMATION BY THE THIRD PARTY SITES. THE COMPANY IS NOT RESPONSIBLE FOR THE PRIVACY PRACTICES OF ANY OF THESE THIRD PARTY SITES.  IF A USER CLICKS ON A LINK TO, OR IS SENT TO A LINK OF, OR OTHERWISE GAINS ACCESS TO, A THIRD PARTY SITE, THE USER SHOULD REVIEW THE PRIVACY STATEMENTS OR POLICIES OF SUCH THIRD PARTY SITES (IF ANY) TO DETERMINE THAT PARTICULAR THIRD PARTY SITES’ PRACTICES WITH REGARD TO THE COLLECTION AND USE OF PERSONALLY IDENTIFIABLE INFORMATION. WITHOUT LIMITING THE GENERALITY OF THE FOREGOING, EACH USER AGREES THAT IF THE USER USES ANY THIRD PARTY SITES IN ANY WAY, THE USER IS AWARE THAT ANY OF THE USER’S PERSONAL INFORMATION THAT THE USER PROVIDES TO THAT THIRD PARTY SITE MIGHT BE READ, COLLECTED, SHARED, DISTRIBUTED, OR OTHERWISE USED BY OTHER USERS OF THAT THIRD PARTY SITE OR BY ANY OTHER THIRD PARTIES, AND COULD BE USED TO SEND THE USER UNSOLICITED MESSAGES. THE COMPANY IS NOT RESPONSIBLE FOR ANY PERSONAL INFORMATION THAT THE USER ELECTS TO SUBMIT IN, OR OTHERWISE MAKE AVAILABLE TO, THESE THIRD PARTY SITES. Any link to any Third Party Site from the Company Website or any other Company Program does not imply any endorsement of the privacy practices of such Third Party Site by the Company, and no such Third Party Site is authorized to make any representation or warranty on Our behalf.

9. INFORMATION SECURITY.

No method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, We cannot guarantee its absolute security. We make efforts to protect Your Personal Information from improper or unauthorized loss, misuse, access, disclosure, alteration, or destruction. If You have questions about the security of Your Personal Information, contact the Company at the email or regular mailing address specified in the Contact Us section below.

10. DATA RETENTION.

We will retain Your Personal Information for as long as necessary to fulfill the purposes for which We collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for Personal Information, We consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of Your Personal Information, the purposes for which We process Your Personal Information, whether We can achieve those purposes through other means, and the applicable legal requirements.

11. THIS PRIVACY POLICY MAY CHANGE.

This Privacy Policy may be changed from time to time and at any time by the Company. The Company reserves the right to change it without notice to a User. YOU HEREBY AGREE THAT YOU ARE BOUND BY THE VERSION OF THIS PRIVACY POLICY THAT IS IN EFFECT AT THE TIME YOU FIRST USE THE COMPANY WEBSITE OR ANY OTHER COMPANY PROGRAM. THE TERMS OF THIS PRIVACY POLICY MAY BE DIFFERENT THE NEXT TIME YOU USE THE COMPANY WEBSITE OR ANY OTHER COMPANY PROGRAM. ANY USE OF THE COMPANY WEBSITE OR ANY OTHER COMPANY PROGRAM BY YOU AFTER SUCH AMENDMENT(S) SHALL BE DEEMED TO CONSTITUTE ACCEPTANCE BY THE USER OF THE AMENDMENT(S) FOR USE OF ALL COMPANY PROGRAMS. EACH USER SHOULD REGULARLY REVIEW AND PRINT THIS PRIVACY POLICY FOR THE USER’S RECORDS.

12. ADDITIONAL NOTICES AND DISCLOSURES UNDER SPECIFIC U.S. STATE LAWS.

NOTICE TO CALIFORNIA RESIDENTS:  Under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CCPA”), residents of the State of California (“California Residents”) have certain rights with respect to their Personal Information, and such rights are hereby disclosed to all California Residents as set forth in Appendix 1 of this Privacy Policy.

NOTICE TO COLORADO RESIDENTS:  Under the Colorado Privacy Act (the “CPA”), residents of the State of Colorado (“Colorado Residents”) have certain rights with respect to their Personal Information, and such rights are hereby disclosed to all such Colorado Residents as set forth in Appendix 2 of this Privacy Policy.

NOTICE TO CONNECTICUT RESIDENTS:  Under the Connecticut Data Privacy Act, Public Act. No. 22-14 (the “CDPA”), residents of the State of Connecticut (“Connecticut Residents”) have certain rights with respect to their Personal Information, and such rights are hereby disclosed to all such Connecticut Residents as set forth in Appendix 3 of this Privacy Policy.

NOTICE TO NEVADA RESIDENTS:  Under Nevada Revised Statues Section 603A., et. seq., residents of the State of Nevada (“Nevada Residents”) have certain rights with respect to the Personal Information, and such rights are hereby disclosed to all such Nevada Residents as set forth in Appendix 4 of this Privacy Policy.

NOTICE TO UTAH RESIDENTS:  Under the Utah Consumer Privacy Act (the “UCPA”), residents of the State of Utah (“Utah Residents”) have certain rights with respect to the Personal Information, and such rights are hereby disclosed to all such Utah Residents as set forth in Appendix 5 of this Privacy Policy.

NOTICE TO VIRGINIA RESIDENTS:  Under the Virginia Consumer Data Protection Act, as amended (the “VCDPA”), residents of the State of Virginia (“Virginia Residents”) have certain rights with respect to the Personal Information, and such rights are hereby disclosed to all such Virginia Residents as set forth in Appendix 6 of this Privacy Policy.

13. ADDITIONAL NOTICES TO INTERNATIONAL USERS

13.1  European Union’s General Data Protection Regulation (GDPR)

13.1.1  Overview. Reference is hereby made to the European Union’s (“EU”) General Data Protection Regulation (for purposes of this Section 13, hereinafter referred to as the “GDPR” or the “Data Protection laws”). For clarity, the GDPR applies to all member countries in the EU and also to countries in the European Economic Area (“EEA”).  Defined terms used in this Section 13 which are not defined elsewhere in this Privacy Policy shall have the meaning set forth in the GDPR, including, without limitation, the terms “Data Subject” and  “Personal Data.”

13.1.2   Applicability to EU “Data Subjects”.  For Users who are “Data Subjects” as defined under the GDPR and have “Personal Data” that is governed by the GDPR, their Personal Data collected in the EU or EEA may be transferred, stored and processed by Us and Our service providers in the United States and other countries whose data protection laws may be different than the laws of Your country. These transfers are required to provide Our services and to perform the agreement with You. Please contact Us at the email address in the Contact Us section above if You want further information on the specific mechanism used by Us when transferring your Personal Data out of the EU or EEA.

13.2  Rights of EU “Data Subjects” Under the GDPR.

Those Users who are “Data Subjects” as defined under the GDPR and have “Personal Data” that is governed by the GDPR,  You have the following rights under the EU’s GDPR. To protect Your privacy and security, We may take reasonable steps to verify Your identity before We exercise of the following rights according to applicable law.

(a) Request Access to Your Personal Data (commonly known as a "information subject access request"). This enables You to receive a copy of the Personal Data We hold about You and to check that We are lawfully processing it.

(b) Request Correction of Your Personal Data. This enables You to have any incomplete or inaccurate data We hold about You corrected, though We may need to verify the accuracy of the new Personal Data You provide to Us.

(c) Request Erasure of Your Personal Data. This enables You to ask Us to delete or remove Personal Data where there is no good reason for Us to continue to process it. You also have the right to ask Us to delete or remove Your Personal Data where You have successfully exercised Your right to object to processing (see below), where We may have processed your Personal Data unlawfully or where We are required to erase Your Personal Data to comply with local law. Note, however, that We may not always be able to comply with Your request of erasure for specific legal reasons which will be notified to You, if applicable, at the time of Your request.

(d) Object to Processing of Your Personal Data. You also have the right to object where We are processing Your Personal Data for direct marketing purposes. In some cases, We may demonstrate that We have compelling legitimate grounds to process Your Data which may override Your rights and freedoms.

(e) Request Restriction of Processing Your Personal Data. This enables You to ask Us to suspend the processing of Your Personal Data in the following scenarios: (i) if You want Us to establish the Personal Data’s accuracy; (ii) where Our use of the Personal Data is unlawful but You do not want Us to erase it; (iii) where You need Us to hold the Personal Data even if we no longer require it as You need it to establish, exercise or defend legal claims; or (iv) You have objected to Our use of Your Personal Data but We need to verify whether We have overriding legitimate grounds to use it.

(f) Request Transfer of Your Personal Data. You may request the transfer of Your Personal Data to yourself or to a third party. We will provide to You, or a third party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which You initially provided consent for Us to use or where We used the Personal Data to enter into a contract with You.

(g) Right to Withdraw Consent. You may withdraw consent at any time where We are relying on consent to process Your Personal Data. However, this will not affect the lawfulness of any processing carried out before You withdraw Your consent. If You withdraw Your consent, We may not be able to provide certain features of Our services to You. We will advise You if this is the case at the time You withdraw Your consent.

(h) Right to Personal Data Portability. You may request Us to transmit certain Personal Data We have about You (collected based on Your consent or in order to provide You with Our products/services) to another data controller in a structured, commonly used and machine-readable format (so long as this is technically feasible).

If You wish to exercise any of the rights set out above, please contact Us at the email address in the Contact Us section above.

13.3  Additional Information About the Rights of EU “Data Subjects” Under the GDPR.

The following is additional information about the rights of EU “Data Subject” under the GDPR:

(a) No fee usually required. You will not have to pay a fee to access Your Personal Data under the GDPR (or to exercise any of Your other rights under the GDPR). However, We may charge a reasonable fee if Your request is clearly unfounded, repetitive or excessive. Alternatively, We may refuse to comply with Your request in these circumstances.

(b) What We may need from You. We may need to request specific information from You to help us confirm Your identity and ensure Your right to access Your Personal Data (or to exercise any of Your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact You to ask You for further information in relation to Your request to speed up Our response.

(c) Time limit to respond. We try to respond to all legitimate requests within one month. Occasionally it may take Us longer than a month if Your request is particularly complex or if You have made a number of requests. In this case, We will notify You and keep You updated.

13.4  Date Retention Notice under the GDPR

We will only retain Your GDPR-protected Personal Data for as long as necessary to fulfill the purposes for which We collected it, including for the purposes of satisfying any legal, accounting, audit, reporting and/or corporate compliance requirements.  To determine the appropriate retention period for Personal Data, We consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of Your Personal Data, the purposes for which We process your Personal Data and whether We can achieve those purposes through other means, and the applicable legal requirements.

13.5  Notice to Certain Other International Members.

If You are a citizen of Canada, Brazil or Mexico and have questions about the accuracy of information that We have collected about You, You can have access to that information in order to verify and update it, unless We are permitted or required under applicable laws to refuse Your access to such information. You may write or email Us the email address in the Contact Us section below.

13.6  Questions or Concerns for EU “Data Subjects”

For those Users who are “Data Subjects” as defined under the GDPR and have “Personal Data” that is governed by the GDPR,  if You have any questions or concerns regarding the use or disclosure of Personal Data under the GDPR, You should first be directed to Us via the email address provided in the Contact Us section below. We will promptly investigate and attempt to resolve all complaints regarding Our use of Personal Data. In the event We are unable to mutually resolve a complaint; We will work with You and agree to refer Your complaint to an independent dispute resolution mechanism. You may also work with the Data Protection Authority in Your country http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm to assist with this process as well.

14. THIS PRIVACY POLICY MAY CHANGE.

This Privacy Policy may be changed from time to time and at any time by the Company. The Company reserves the right to change it without notice to a User. YOU HEREBY AGREE THAT YOU ARE BOUND BY THE VERSION OF THIS PRIVACY POLICY THAT IS IN EFFECT AT THE TIME YOU FIRST USE THE COMPANY WEBSITE OR ANY OTHER COMPANY PROGRAM. THE TERMS OF THIS PRIVACY POLICY MAY BE DIFFERENT THE NEXT TIME YOU USE THE COMPANY WEBSITE OR ANY OTHER COMPANY PROGRAM. ANY USE OF THE COMPANY WEBSITE OR ANY OTHER COMPANY PROGRAM BY YOU AFTER SUCH AMENDMENT(S) SHALL BE DEEMED TO CONSTITUTE ACCEPTANCE BY THE USER OF THE AMENDMENT(S) FOR USE OF ALL COMPANY PROGRAMS. EACH USER SHOULD REGULARLY REVIEW AND PRINT THIS PRIVACY POLICY FOR THE USER’S RECORDS.

15. DOWNLOAD A COPY OF OUR PRIVACY POLICY.

You may download a PDF version of Our Privacy Policy here: https://www.seniormatch.com /privacyPolicy

16. CONTACT US

If there are any questions regarding this Privacy Policy, You may contact Us via e-mail at support<AT>SeniorMatch.com or contact us.

APPENDIX 1

CALIFORNIA PRIVACY RIGHTS NOTICE

Effective Date: April 28, 2023

1. YOUR CALIFORNIA PRIVACY RIGHTS UNDER THE CCPA

Under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CCPA”), if You are a resident of California You have the following rights with respect to Your Personal Information.

1.1 Right to Know About Our Collection, Disclosure, Sharing and Sale of Personal Information about You.

Personal Information as defined in the CCPA is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to You, including the following categories of information: (a) identifiers; (b) categories described in California Civil Code §1798.80(e); (c) characteristics of protected classes; (d) commercial information; (e) biometric information; (f) internet or other electronic network activity; (g) geolocation data; (h) audio, electronic, visual, thermal, olfactory or similar information; (i) professional or employment related information; (j) education information; and (k) inferences drawn from such information to create a consumer profile.

You have the right to know the categories of Personal Information We have collected about You; the categories of sources from which We collect Personal Information; Our business or commercial purpose for collecting, disclosing, sharing, or selling Personal Information; the categories of third parties to whom We disclose, share, or sell Personal Information, if any; and the specific pieces of Personal Information We have collected about You. Personal Information includes “sensitive” Personal Information as described below.

1.2  Right to Know About Our Collection, Disclosure, Sharing and Sale of “Sensitive” Personal Information about You.

“Sensitive” Personal Information as defined in the CCPA is Personal Information that reveals: (a) Your Social Security, driver’s license, state identification card, or passport number; (b) Your account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; (c) Your precise geolocation; (d) Your racial or ethnic origin, religious, or philosophical beliefs, or union membership; (e) the contents of Your mail, email, and text messages unless We are the intended recipient of the communication; and (f) Your genetic data. “Sensitive” Personal Information also includes biometric information that is processed for the purpose of identifying You, information that is collected and analyzed concerning Your health; or Your sex life or sexual orientation.

You have the right to know the categories of “sensitive” Personal Information We have collected about You, the categories of sources from which We collect Personal Information, Our business or commercial purpose for collecting, selling, or sharing “sensitive” Personal Information, the categories of third parties with whom We sell or share “sensitive” Personal Information, if any, and the specific pieces of “sensitive” Personal Information We have collected about You.

1.3  Right to Delete Your Personal Information.

Subject to the exceptions set out below, and upon Your submission of a verifiable request, You have the right to deletion of Your Personal Information from Our records, and to have Us direct Our Service Providers/Contractors and third parties to delete Your Personal Information from their records.

We are not required to, and reserve Our right to not delete Your Personal Information if it is necessary to: (i) complete the transaction for which the Personal Information was collected, provide a good or service requested by You, or reasonably anticipated within the context of Our ongoing business relationship with You, or otherwise perform a contract between You and Us; (ii) help to ensure security and integrity to the extent the use of Your Personal Information is reasonably necessary and proportionate for those purposes; (iii) debug to identify and repair errors that impair existing intended functionality; (iv) exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law; (v) comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code; (vi) engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when Our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided We have obtained Your informed consent; (vii) enable solely internal uses that are reasonably aligned with Your expectations based on Your relationship with Us and compatible with the context in which You provided the information; and (viii) comply with a legal obligation.

1.4  Right to Correct Inaccurate Personal Information.

Subject to the exceptions set out below, and upon Your submission of a verifiable request, You have the right to correct any inaccurate Personal Information in Our records, and to have Us direct Our Service Providers/Contractors and third parties to correct any inaccurate Personal Information from their records.

If We cannot verify Your identity pursuant to the CCPA and its regulations, We may deny a request to correct. In such event, We shall inform You that Your identity cannot be verified.

In determining the accuracy of the Personal Information that is the subject of Your request to correct, We shall consider the totality of the circumstances relating to the contested Personal Information. We may deny Your request to correct if We determine that the contested Personal Information is more likely than not accurate based on the totality of the circumstances.

1.5 Right to Be Free from Discrimination.

You have the right to not be discriminated against by Us because You exercised any of Your rights under the CCPA. This means We cannot, on the basis of the exercise of Your rights thereunder, among other things, deny goods or services to You, charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; provide a different level or quality of goods or services to You; or suggest that You will receive a different price or rate for goods or services or a different level or quality of goods or services or retaliate against You as an employee, applicant for employment, or independent contractor.

1.6  Right to Opt-Out of the Sharing of Personal Information.

We may disclose Your Personal Information to third parties for cross-context behavioral advertising purposes (“Share” or “Sharing”). This means the targeting of advertising to You based on Your Personal Information that We obtain from Your activity across businesses, distinctly-branded websites, applications, or services, other than Our business, distinctly-branded website, application, or service. We may Share Personal Information with advertising networks so they may help Us to deliver advertisements to You based on Your activity on the Company Website or apps and/or Your activity on other websites or apps.

You have the right to opt-out of the Sharing of Your Personal Information and You may exercise Your right by clicking the following link: Do Not Sell or Share My Personal Information. If You exercise Your right to opt-out of the Sharing of Your personal information, We will refrain from Sharing Your Personal Information, unless You subsequently provide express authorization for the sharing of Your Personal Information.

1.7 Right to Opt-Out of the Sale of Personal Information.

We may disclose Your Personal Information to third parties in exchange for monetary or other consideration. Such disclosures are considered to be “Sales” under the CCPA. We may Sell Personal Information to advertising networks so they may help Us to deliver advertisements to You based on Your activity on the Company Website or any other Company Programs and/or to recommend Our products/services to You based on Your activity on other websites or apps. You have the right to opt-out of the Sale of Your Personal Information and You may exercise Your right by clicking on the following link: Do Not Sell or Share My Personal Information. If You exercise Your right to opt-out of the Sale of Your Personal Information, We will refrain from Selling Your Personal Information, unless You subsequently provide express authorization for the Sale of Your Personal Information.

1.8 Right to Limit the Use of “Sensitive” Personal Information

We may use Your “sensitive” Personal Information for purposes other than is necessary to provide Our products/services as reasonably expected by You. For example, We may share Your “sensitive” Personal Information with advertising networks that may use such information to target advertising to You. You have the right to limit Our use of Your “sensitive” Personal Information to that which is necessary to provide Our goods and services to You by clicking on the following link: Do Not Sell or Share My Personal Information.

1.9 Right of Children to Opt-In to the Sale of Personal Information.

We do not knowingly collect or sell the Personal Information of minors under 16 years of age without affirmative authorization. For minors who wish to opt-in to the sale of their Personal Information, We have established the following processes:

Minors between 13 and 16 years of age:

In the case of consumers between 13 and 16 years of age, We require the consumer to affirmatively authorize the sale of the consumer’s Personal Information. In order to opt-in minors in this age range, as part of the account registration process for Our products which may be targeted toward minors, We require the consumer or consumer’s parent or guardian to verify the consumer’s identity by providing at least two data points with data points maintained by the business, which We have determined to be reliable for the purpose of verifying the consumer.

Minors under 13 years of age:

In the case of consumers who are less than 13 years of age, We require the consumer’s parent to affirmatively authorize the sale of the consumer’s personal information. In order to opt-in minors in this age range, as part of the account registration process for Our products/services which may be targeted toward minors, We require that the consumer’s parent or guardian verify the consumer’s identity, which We have determined to be reliable for the purpose of verifying the consumer.

We reserve the right to require additional information or not complete Your request if We cannot verify Your identity. If You are a parent or guardian seeking to opt-out on behalf of their child, please contact Us at 1-888-702-1274 or email Us at support<AT>SeniorMatch.com or contact us with the subject “Minor Opt-Out.”

2. HOW TO EXERCISE YOUR CCPA RIGHTS.

Unless otherwise specified, to exercise any of Your rights described in this Appendix A, please submit Your request to Us at 1-888-702-1274 or at support<AT>SeniorMatch.com or contact us with the subject “CCPA Consumer Request.”

In order to verify Your request, We will need You to provide Us with enough information to identify You (e.g., Your full name, address, and customer or matter reference number), proof of Your identity and address (e.g., a copy of Your driver’s license or passport and a recent utility or credit card bill), and a description of what right You wish to exercise along with any information to which Your requests relates. If feasible, We will match the identifying information provided by You with the personal information that We already maintain about You.

You may designate an authorized agent to make a request under the CCPA on Your behalf. In order to fulfill Your request to know or delete submitted by an authorized agent, You must provide the authorized agent written permission to do so, and We may require that You verify Your own identity with Us directly.

We reserve Our right not to grant a consumer request if We cannot verify that the person making the request is the person about whom We have collected information, or someone authorized to act on such person’s behalf. You may only make a request to access or receive copies of Personal Information twice within a 12-month period. Any Personal Information We collect from You to verify Your identity in connection with Your request will be used solely for the purposes of verification.

3. OUR PERSONAL INFORMATION COLLECTION, USE, AND DISCLOSURE PRACTICES.

A description of the Personal Information that We collect online and off-line is provided in Section 1 of the main Policy.

The purposes for which We collect and use Personal Information are described in Sections 1, 2, 3 and 5 of the main Policy.

Sources from which We receive Personal Information are described in Section 1 of the main Policy.

Our Personal Information disclosure practices are described in Section 1, 2, 3, and 5 of the main Policy.

Our Personal Information retention practices are described in Section 10 of the main Policy.

3.1 Categories of Personal Information Collected; Sold or Shared for Cross-Context Behavioral Advertising; and Disclosed for a Business Purpose within the past 12 months.

3.2 Categories of “Sensitive” Personal Information Collected; Sold or Shared for Cross-Context Behavioral Advertising; and Disclosed for a Business Purpose within the past 12 months.

4. OTHER CALIFORNIA PRIVACY RIGHTS

4.1  Shine the Light Request.

Individual consumers who reside in California and have provided Us with their Personal Information may request information about Our disclosures of certain categories of Personal Information to third parties for their direct marketing purposes. Such requests must include Your name, street address, city, state, and zip code, and be submitted to Us at one of the following addresses: support<AT>SeniorMatch.com or contact us with the subject “California Shine The Light Request” or 10 - 8707 Dufferin St, Suite 160 Vaughan, Ontario L4J 0A6 Canada, attention: Michelle Li. Within thirty (30) days of receiving such a request, We will provide a list of the categories of Personal Information disclosed to third parties for third-party direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. We reserve Our right not to respond to requests submitted to addresses other than the addresses specified in this paragraph.

4.2  Minor’s Right to Remove Posted Content.

If You are a California resident under the age of 18, and a registered User of any website where this Policy is posted, California Business and Professions Code Section 22581 permits You to request and obtain removal of content or information that You have publicly posted. To make such a request, please send an email with a detailed description of the specific content or information to support<AT>SeniorMatch.com or contact us with the subject “Privacy Rights for Minors.” Please be aware that such a request does not ensure complete or comprehensive removal of the content or information You have posted and that there may be circumstances in which the law does not require or allow removal even if requested.  

APPENDIX 2

COLORADO PRIVACY RIGHTS NOTICE

Effective Date:  April 28, 2023

1. YOUR COLORADO PRIVACY RIGHTS

Under the Colorado Privacy Act (the “CPA”) if You are a resident of Colorado, acting only in an individual or household context (and not in a commercial or employment context, as a job applicant or as a beneficiary of someone acting in an employment context), Your rights with respect to Your Personal Data are described below.

1.1 Disclosure of Our Personal Data Collection and Processing Practices.

Personal Data as defined in the CPA means any information that is linked or reasonably linkable to You. Our main Privacy Policy and Appendix 1 describe Our collection and processing of Personal Data (therein also referred to as “Personal Information”) practices, including:

• the categories of Personal Data that We collect or process (Section 1);
• the purposes for processing the Personal Data (Sections 1, 2 and 3);
• the categories of Personal Data shared with third parties (Sections 1, 2 and 3 and Section 3 in Appendix 1)
• the categories of third parties with whom We share Personal Data (Sections 1, 2 and 3 and Section 3 in Appendix 1); and
• Our sale of Personal Data to third parties or targeted advertising (Sections 1, 2 and 3 and Section 3 in Appendix 1 therein “targeted advertising” is referred to as “sharing for cross-context behavioral advertising”).

1.2 Right of Access.

You have the right to confirm whether We are processing Personal Data concerning You and to access to Your Personal Data.

1.3 Right to Correction.

You have the right to correct inaccuracies in Your Personal Data, taking into account the nature of the Personal Data and the purposes of the processing of Your Personal Data.

1.4 Right to Deletion.

You have the right to delete Personal Data concerning You.

1.5 Right to Data Portability.

When exercising the right to access Personal Data, You have the right to obtain the Personal Data in a portable, and to the extent technically feasible, readily usable format that allows You to transmit the Personal Data to another entity without hindrance.

1.6 Right to Opt Out.

You have the right to opt out of the processing of Your Personal Data for (a) targeted advertising, (b) sale of Personal Data, or (c) profiling in furtherance of decisions that produce legal or similarly significant effects concerning You.

       We may disclose Your Personal Data to third parties for targeted advertising purposes. This means the targeting of advertising to You based on Your Personal Data that We obtain from Your activity across businesses, distinctly-branded websites, applications, or services, other than Our business, distinctly-branded website, application, or service. We may share Personal Data with advertising networks so they may help Us to deliver advertisements to You based on Your activity on the Company Website or apps and/or Your activity on other websites or apps.

You have the right to opt-out of the processing of Your Personal Data for targeted advertising or profiling and You may exercise Your right by clicking the following link: Do Not Sell or Share My Personal Information. If You exercise Your right to opt-out of the processing of Your Personal Data for targeted advertising or profiling, We will refrain from processing Your Personal Data for targeted advertising or profiling, unless You subsequently provide express authorization for the sharing of Your Personal Data.

We may disclose Your Personal Data to third parties in exchange for monetary or other consideration. We may sell Your Personal Data to advertising networks so they may help Us to deliver advertisements to You based on Your activity on the Company Website or apps and/or to recommend Our products/services to You based on Your activity on other websites or apps. We may sell Your Personal Data to Data Analytics Providers who may use Your Personal Data for their own behavioral advertising analysis purposes.

You have the right to opt-out of the sale of Your Personal Information and You may exercise Your right by clicking on the following link: Do Not Sell or Share My Personal Information. If You exercise Your right to opt-out of the sale of Your Personal Data, We will refrain from selling Your Personal Data, unless You subsequently provide express authorization for the sale of Your Personal Data.

We will process any opt-out preference signal that (a) is in a format commonly used and recognized by businesses (for example, in an HTTP header field) and (b) is sent from a platform, technology, or mechanism that makes it clear to the consumer, whether in its configuration or in disclosures to the public, that the use of the signal is meant to have the effect of opting the consumer out of the sale and sharing of their Personal Data (“Opt-Out Preference Signal”). We shall treat the Opt-Out Preference Signal as a valid request to opt-out of the sale or sharing of Personal Data for Your browser or device, and, if known, for You.

1.7 Your “Sensitive Data” May Not Be Processed without Your Consent

“Sensitive Data” means (a) Personal Data revealing Your racial or ethnic origin, religious beliefs, a mental or physical health condition or diagnosis, sex life or sexual orientation, or citizenship or citizenship status; (b) the processing of genetic or biometric data for identification purposes and (c) Personal Data from a known child. We will not process Your “Sensitive Data” without Your consent or in the case of a known child, the consent or a parent or lawful guardian.

2. HOW TO EXERCISE YOUR CPA RIGHTS

Unless otherwise specified, to exercise any of Your rights described in this Appendix 2, please submit Your request to Us at support<AT>SeniorMatch.com with the subject “CPA Consumer Request.” We shall respond to Your request within forty-five (45) days of receipt. The response period may be extended once by forty-five (45) additional days when reasonably necessary, taking into account the complexity and number of requests and We inform You of such extension within the initial forty-five (45) day response period, together with the reason for the extension.

If We decline to take action on Your request, We shall so inform You without undue delay, within forty-five (45) days of receipt of Your request. The notification will include a justification for declining to take action and instructions on how You may appeal.

Not more than sixty (60) days after receipt of an appeal, We will inform You in writing of any action taken or not taken in response to the appeal, including a written explanation of the reason for the decision. If We deny the appeal, You may contact the Colorado Attorney General at https://complaints.coag.gov/s/?varCFT=2 or (720) 508-6000.

We shall provide information in response to Your request free of charge, except that, for a second or subsequent request within a twelve (12) month period, We may charge an amount as provided in the CPA. If We are unable to authenticate Your request using commercially reasonable efforts, We may request additional information reasonably necessary to authenticate You and Your request. If We cannot authenticate You and Your request, We will not be able to grant Your request.

You may designate another person to serve as Your authorized agent and act on Your behalf. We will comply with an opt-out request received from an authorized agent if We are able to verify, with commercially reasonable effort, Your identity and the authorized agent’s authority to act on Your behalf.

APPENDIX 3

CONNECTICUT PRIVACY RIGHTS NOTICE

Effective Date: April 28, 2023

1. YOUR CONNECTICUT PRIVACY RIGHTS

Under the Connecticut Data Privacy Act, Public Act. No. 22-14 (the “CDPA”) if You are a resident of Connecticut, acting in an individual or household context (and not in a commercial or employment context or as a representative of business, nonprofit or governmental entity), Your rights with respect to Your Personal Data are described below.

1.1 Disclosure of Our Personal Data Collection and Processing Practices.

Personal Data as defined in the CDPA means any information that is linked or reasonably linkable to You. Our main Privacy Policy and Appendix 1 describe Our collection and processing of Personal Data (therein also referred to as “Personal Information”) practices, including:

• the categories of Personal Data that We collect or process (Section 1);
• the purposes for processing the Personal Data (Sections 1, 2 and 3);
• the categories of Personal Data shared with third parties (Sections 1, 2 and 3 and Section 3 in Appendix 1)
• the categories of third parties with whom We share Personal Data (Sections 1, 2 and 3 and Section 3 in Appendix 1); and
• Our sale of Personal Data to third parties or targeted advertising (Sections 1, 2 and 3 and Section 3 in Appendix 1 therein “targeted advertising” is referred to as “sharing for cross-context behavioral advertising”).

1.2 Right of Access.

You have the right to confirm whether We are processing Personal Data concerning You and to access to Your Personal Data, except if doing so would require Us to reveal a trade secret.

1.3 Right to Correction.

You have the right to correct inaccuracies in Your Personal Data, taking into account the nature of the Personal Data and the purposes of the processing of Your Personal Data.

1.4 Right to Deletion

You have the right to delete Personal Data concerning You.

1.5 Right to Data Portability.

When exercising the right to access Personal Data, You have the right to obtain the Personal Data in a portable, and to the extent technically feasible, readily usable format that allows You to transmit the Personal Data to another entity without hindrance.

1.6 Right to Opt Out.

You have the right to opt out of the processing of Your Personal Data for (a) targeted advertising, (b) sale of Personal Data, or (c) profiling in furtherance of decisions that produce legal or similarly significant effects concerning You.

       We may disclose Your Personal Data to third parties for targeted advertising purposes. This means the targeting of advertising to You based on Your Personal Data that We obtain from Your activity across businesses, distinctly-branded websites, applications, or services, other than Our business, distinctly-branded website, application, or service. We may share Personal Data with advertising networks so they may help Us to deliver advertisements to You based on Your activity on the Company Website or apps and/or Your activity on other websites or apps.

You have the right to opt-out of the processing of Your Personal Data for targeted advertising or profiling and You may exercise Your right by clicking the following link: Do Not Sell or Share My Personal Information. If You exercise Your right to opt-out of the processing of Your Personal Data for targeted advertising or profiling, We will refrain from processing Your Personal Data for targeted advertising or profiling, unless You subsequently provide Your express authorization.

We may disclose Your Personal Data to third parties in exchange for monetary or other consideration. We may sell Your Personal Data to advertising networks so they may help Us to deliver advertisements to You based on Your activity on the Company Website or apps and/or to recommend Our services/products to You based on Your activity on other websites or apps. We may sell Your Personal Data to Data Analytics Providers who may use Your Personal Data for their own behavioral advertising analysis purposes.

You have the right to opt-out of the sale of Your Personal Data and You may exercise Your right by clicking on the following link: Do Not Sell or Share My Personal Information. If You exercise Your right to opt-out of the sale of Your Personal Data, We will refrain from selling Your Personal Data, unless You subsequently provide express authorization for the sale of Your Personal Data.

We will process any opt-out preference signal that (a) is in a format commonly used and recognized by businesses (for example, in an HTTP header field) and (b) is sent from a platform, technology, or mechanism that makes it clear to the consumer, whether in its configuration or in disclosures to the public, that the use of the signal is meant to have the effect of opting the consumer out of the sale and sharing of their Personal Data (“Opt-Out Preference Signal”). We shall treat the Opt-Out Preference Signal as a valid request to opt-out of the sale or sharing of Personal Data for Your browser or device, and, if known, for You.

1.7 Your “Sensitive Data” May Not Be Processed without Your Consent.

       “Sensitive Data” means (a) Personal Data revealing Your racial or ethnic origin, religious beliefs, a mental or physical health condition or diagnosis, sex life or sexual orientation, or citizenship or immigration status; (b) the processing of genetic or biometric data for identification purposes; (c) Personal Data from a known child (individual under the age of 13); and precise geolocation data. We will not process Your “Sensitive Data” without Your consent or in the case of a known child, the consent or a parent or lawful guardian.

2. HOW TO EXERCISE YOUR CDPA RIGHTS

Unless otherwise specified, to exercise any of Your rights described in this Appendix 3, please submit Your request to Us at support<AT>SeniorMatch.com or contact us with the subject “CDPA Consumer Request.” We shall respond to Your request within forty-five (45) days of receipt. The response period may be extended once by forty-five (45) additional days when reasonably necessary, taking into account the complexity and number of requests and We inform You of such extension within the initial forty-five (45) day response period, together with the reason for the extension.

If We decline to take action on Your request, We shall so inform You without undue delay, within forty-five (45) days of receipt of Your request. The notification will include a justification for declining to take action and instructions on how You may appeal.

Not more than sixty (60) days after receipt of an appeal, We will inform You in writing of any action taken or not taken in response to the appeal, including a written explanation of the reason for the decision. If We deny the appeal, You may contact the Connecticut Attorney General to submit a complaint at https://portal.ct.gov/AG/Common/Complaint-Form-Landing-page or (860) 808-5318.

We shall provide information in response to Your request free of charge, except that, for a second or subsequent request within a twelve (12) month period, We may charge an amount as provided in the CDPA. If We are unable to authenticate Your request using commercially reasonable efforts, We may request additional information reasonably necessary to authenticate You and Your request. If We cannot authenticate You and Your request, We will not be able to grant Your request.

You may designate another person to serve as Your authorized agent and act on Your behalf. We will comply with an opt-out request received from an authorized agent if We are able to verify, with commercially reasonable effort, Your identity and the authorized agent’s authority to act on Your behalf.

APPENDIX 4

NEVADA PRIVACY RIGHTS NOTICE

Effective Date:  April 24, 2022

Under Nevada Revised Statutes Section 603A., et. seq., residents of Nevada have certain rights with respect to the Personal Information that We collect on the Company Website.

1. The categories of Personal Information that We collect and the categories of third parties with whom We share Personal Information are described in the chart in the above Appendix 1 under the California Privacy Rights Notice.
2. You may review and request changes to the Personal Information that We collect or process on the Company Website by sending an email to support<AT>SeniorMatch.com or contact us.
3. Any material changes to this notice shall be posted in this Appendix 4 to this Privacy Policy.
4. When You use the Company Website, We may share Personal Information about Your online activities over time and across different internet sites or online services with third parties.

APPENDIX 5

UTAH PRIVACY RIGHTS NOTICE

Effective Date:  April 28, 2023

1. YOUR UTAH PRIVACY RIGHTS UNDER THE UTAH CONSUMER PRIVACY ACT

Under the Utah Consumer Privacy Act (the “UCPA”) if You are a resident of Utah, acting in an individual or household context (and not in a commercial or employment context) Your rights with respect to Your Personal Data are described below.

1.1 Disclosure of Our Personal Data Collection and Processing Practices.

Personal Data as defined in the UCPA means any information that is linked or reasonably linkable to You. Our main Privacy Policy and Appendix 1 describe Our collection and processing of Personal Data (therein also referred to as “Personal Information”) practices in general, including:

• the categories of Personal Data that We collect or process (Section 1);
• the purposes for processing the Personal Data (Sections 1, 2 and 3);
• the categories of Personal Data shared with third parties (Sections 1, 2 and 3 and Section 3 in Appendix 1)
• the categories of third parties with whom We share Personal Data (Sections 1, 2 and 3 and Section 3 in Appendix 1); and
• Our sale of Personal Data to third parties or targeted advertising (Sections 1, 2 and 3 and Section 3 in Appendix 1 therein “targeted advertising” is referred to as “sharing for cross-context behavioral advertising”).

1.2 Right of Access.

You have the right to confirm whether We are processing Personal Data concerning You and to access to Your Personal Data.

1.3 Right to Correction.

You have the right to correct inaccuracies in Your Personal Data, taking into account the nature of the Personal Data and the purposes of the processing of Your Personal Data.

1.4 Right to Deletion.

You have the right to delete Personal Data concerning You.

1.5 Right to Data Portability.

When exercising the right to access Personal Data, You have the right to obtain the Personal Data in a portable, and to the extent technically feasible, readily usable format that allows You to transmit the Personal Data to another entity without hindrance.

1.6 Right to Opt Out.

You have the right to opt out of the processing of Your Personal Data for (a) targeted advertising or (b) sale of Personal Data.

       We may disclose Your Personal Data to third parties for targeted advertising purposes. This means the targeting of advertising to You based on Your Personal Data that We obtain from Your activity across businesses, distinctly-branded websites, applications, or services, other than Our business, distinctly-branded website, application, or service. We may share Personal Data with advertising networks so they may help Us to deliver advertisements to You based on Your activity on the Company Website or apps and/or Your activity on other websites or apps.

You have the right to opt-out of the processing of Your Personal Data for targeted advertising and You may exercise Your right by clicking the following link: Do Not Sell or Share My Personal Information. If You exercise Your right to opt-out of the processing of Your Personal Data for targeted advertising, We will refrain from processing Your Personal Data for targeted advertising, unless You subsequently provide express authorization for the sharing of Your Personal Data.

We may disclose Your Personal Data to third parties in exchange for monetary consideration. We may sell Your Personal Data to advertising networks so they may help Us to deliver advertisements to You based on Your activity on the Company Website or apps and/or to recommend Our products/services to You based on Your activity on other websites or apps. We may sell Your Personal Data to Data Analytics Providers who may use Your Personal Data for their own behavioral advertising analysis purposes.

You have the right to opt-out of the sale of Your Personal Data and You may exercise Your right by clicking on the following link: Do Not Sell or Share My Personal Information. If You exercise Your right to opt-out of the sale of Your Personal Data, We will refrain from selling Your Personal Data, unless You subsequently provide express authorization for the sale of Your Personal Data.

We will process any opt-out preference signal that (a) is in a format commonly used and recognized by businesses (for example, in an HTTP header field) and (b) is sent from a platform, technology, or mechanism that makes it clear to the consumer, whether in its configuration or in disclosures to the public, that the use of the signal is meant to have the effect of opting the consumer out of the sale and sharing of their personal data (“Opt-Out Preference Signal”). We shall treat the Opt-Out Preference Signal as a valid request to opt-out of the sale or sharing of Personal Data for Your browser or device, and, if known, for You.

1.7 Your “Sensitive Data” May Not Be Processed without Your Consent

       “Sensitive Data” means (a) Personal Data revealing Your racial or ethnic origin; religious beliefs; sexual orientation; citizenship or immigration status; or medical history, mental or physical health condition, or medical treatment or diagnosis by a health care professional; (b) the processing of genetic or biometric data for identification purposes and (c) specific geolocation data. We will not process Your “Sensitive Data” without Your consent or in the case of a known child, the consent or a parent or guardian.

2.  HOW TO EXERCISE YOUR UCPA RIGHTS

Unless otherwise specified, to exercise any of Your rights described in this Appendix 5, please submit Your request to Us at support<AT>SeniorMatch.com or contact us with the subject “UCPA Consumer Request.” We shall respond to Your request within forty-five (45) days of receipt. The response period may be extended once by forty-five (45) additional days when reasonably necessary, taking into account the complexity and number of requests and We inform You of such extension within the initial forty-five (45) day response period, together with the reason for the extension.

If We decline to take action on Your request, We shall so inform You without undue delay, within 45 days of receipt of Your request.

We shall provide information in response to Your request free of charge, except that, for a second or subsequent request within a twelve (12) month period, We may charge an amount as provided in the UCPA. If We are unable to authenticate Your request using commercially reasonable efforts, We may request additional information reasonably necessary to authenticate You and Your request. If We cannot authenticate You and Your request, We will not be able to grant Your request.

APPENDIX 6

VIRGINIA PRIVACY RIGHTS NOTICE

Effective Date:  April 28, 2023

YOUR VIRGINIA PRIVACY RIGHTS UNDER THE VCDPA

Under the Virginia Consumer Data Protection Act, as amended (the “VCDPA”) if You are a resident of Virginia acting in an individual or household context (and not in an employment or commercial context), You have the following rights with respect to Your Personal Data.

1.1 Disclosure of Our Personal Data Collection and Processing Practices.

Personal Data as defined in the VCDPA means any information that is linked or reasonably linkable to You. Our main Privacy Policy and Appendix 1 describe Our collection and processing of Personal Data (therein also referred to as “Personal Information”) practices, including:

• the categories of Personal Data that We collect or process (Section 1);
• the purposes for processing the Personal Data (Sections 1, 2 and 3);
• the categories of Personal Data shared with third parties (Sections 1, 2 and 3 and Section 3 in Appendix 1)
• the categories of third parties with whom We share Personal Data (Sections 1, 2 and 3 and Section 3 in Appendix 1); and
• Our sale of Personal Data to third parties or targeted advertising (Sections 1, 2 and 3 and Section 3 in Appendix 1 therein “targeted advertising” is referred to as “sharing for cross-context behavioral advertising”).

1.2 Right of Access.

You have the right to confirm whether We are processing Personal Data concerning You and to access to Your Personal Data.

1.3 Right to Correction.

You have the right to correct inaccuracies in Your Personal Data, taking into account the nature of the Personal Data and the purposes of the processing of Your Personal Data.

1.4 Right to Deletion.

You have the right to delete Personal Data concerning You.

1.5 Right to Data Portability.

When exercising the right to access Personal Data, You have the right to obtain the Personal Data in a portable, and to the extent technically feasible, readily usable format that allows You to transmit the Personal Data to another entity without hindrance.

1.6 Right to Opt Out.

You have the right to opt out of the processing of Your Personal Data for purposes of (i) targeted advertising, (ii) the sale of Personal Data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning You.

We may disclose Your Personal Data to third parties for targeted advertising purposes. This means the targeting of advertising to You based on Your Personal Data that We obtain from Your activity across businesses, distinctly-branded websites, applications, or services, other than Our business, distinctly-branded website, application, or service. We may share Personal Data with advertising networks so they may help Us to deliver advertisements to You based on Your activity on the Company Website or apps and/or Your activity on other websites or apps.

You have the right to opt-out of the processing of Your Personal Data for targeted advertising or profiling and You may exercise Your right by clicking the following link: Do Not Sell or Share My Personal Information. If You exercise Your right to opt-out of the processing of Your Personal Data for targeted advertising or profiling, We will refrain from processing Your Personal Data for targeted advertising or profiling, unless You subsequently provide Your express authorization.

We may disclose Your Personal Data to third parties in exchange for monetary consideration. We may share Personal Data with advertising networks so they may help Us to deliver advertisements to You based on Your activity on the Company Website or apps and/or to recommend Our services/products to You based on Your activity on other websites or apps. We may share Your Personal Data with Data Analytics Providers who may use Your Personal Data for their own behavioral advertising analysis purposes.

You have the right to opt-out of the sale of Your Personal Data and You may exercise Your right by clicking on the following link: Do Not Sell or Share My Personal Information. If You exercise Your right to opt-out of the sale of Your Personal Data, We will refrain from selling Your Personal Data, unless You subsequently provide express authorization for the sale of Your Personal Data.

1.7 Your “Sensitive Data” May Not Be Processed without Your Consent.

“Sensitive Data” means (a) Personal Data revealing racial or ethnic origin, religious beliefs, mental or physical health diagnosis, sexual orientation, or citizenship or immigration status; (b) the processing genetic or biometric data for the purpose of uniquely identifying You; (c) the Personal Data from a known child; or (d) precise geolocation. We do not process “Sensitive Data” If We intend to do so, We will obtain Your consent or in the case of a known child, the consent as required by the federal Children’s Online Privacy Protection Act.

2. HOW TO EXERCISE YOUR VCDPA RIGHTS

Unless otherwise specified, to exercise any of Your rights described in this Appendix 6, please submit Your request to Us at support<AT>SeniorMatch.com or contact us with the subject “VCPDA Consumer Request.” We shall respond to Your request within forty-five (45) days of receipt. The response period may be extended once by forty-five (45) additional days when reasonably necessary, taking into account the complexity and number of requests and We inform You of such extension within the initial forty-five (45) day response period, together with the reason for the extension.

If We decline to take action on Your request, We shall so inform You without undue delay, within forty-five (45) days of receipt of Your request. The notification will include a justification for declining to take action and instructions on how You may appeal.

We shall provide information in response to Your request free of charge, up to twice annually, unless requests are manifestly unfounded, excessive or repetitive. If We are unable to authenticate Your request using commercially reasonable efforts, We may request additional information reasonably necessary to authenticate You and Your request. If We cannot authenticate You and Your request, We will not be able to grant Your request.

Within a reasonable time, not to exceed sixty (60) days, after You have received a notice that We have declined to take action on Your request, You may appeal by sending Your appeal to support<AT>SeniorMatch.com or contact us with the subject “VCPDA Appeal.” We shall respond to You within sixty (60) days of receipt of the appeal in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decision. If We deny Your appeal, You may file a complaint with the Virginia Attorney General at https://www.oag.state.va.us/consumer-protection/index.php/file-a-complaint or call (804) 786-2042.