CCPA Privacy Notice Addendum

For California Consumers

This section supplements the Privacy Policy and applies exclusively to California consumers, excluding FlipTree personnel. The table below outlines how the personal information of California consumers (excluding personnel) is processed, in accordance with the definitions provided by the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA).

Please note that not all items listed in the table may apply to you. For instance, while we do not collect Social Security numbers from users, we may collect such data when evaluating job applicants.

Personal Information Processing Activities

Categories of Personal Information Collected Over the 12-Month Period Prior to the Effective Date of Our Privacy Policy

The categories of personal information listed below are derived from the statutory list provided under the California Consumer Privacy Act (CCPA).

Sources of Collection Over the 12-Month Period Prior to the Effective Date of Our Privacy Policy

Categories of Third Parties with Whom We Disclosed Personal Information for a Business Purpose Over the 12-Month Period Prior to the Effective Date of Our Privacy Policy

Business or Commercial Purposes for Which the Personal Information Was Collected Over the 12-Month Period Prior to the Effective Date of Our Privacy Policy (In Addition to the Purposes Listed in the Privacy Policy)

The following identifiers may be collected: real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers, and similar technologies; customer number, unique pseudonym, or user alias), telephone number, and other forms of persistent or probabilistic identifiers. Additional identifiers include online identifier, Internet Protocol (IP) address, email address, account name, Social Security number, driver’s license number, passport number, and other similar identifiers.	From you (for instance if you create an account or apply for a position at our company) From social media networks (for example if you log into our service through an account you have on a social media network) From partners (for example, where our ads promoting our services are published on a partner's website or where a partner or consumer reporting agency shares with us information about bad actors) From our affiliated companies (notably for anti-fraud and safety purposes) From data brokers (e.g. for anti-fraud and safety purposes)
Signature, physical characteristics or description, state identification card number, education, bank account number, credit card number, debit card number, other financial information, and medical information	From You: Collected when you create an account or apply for a position with our company. From Our Affiliated Companies: Collected primarily for anti-fraud and safety purposes.
Protected classifications under California or federal law may include the following: race, color, national origin, ethnicity, religion, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, medical condition, disability, citizenship status, and military or veteran status.	From You: Collected when you create an account or apply for a position at our company. From Consumer Reporting Agencies: Collected when consumer reporting agencies share information with us about bad actors. From Social Media Networks: Collected when you log into our service using an account from a social media network. From Our Affiliated Companies: Collected primarily for anti-fraud and safety purposes.
Commercial Information This may include records of personal property, products or services purchased, obtained, or considered, as well as other purchasing or consuming histories or tendencies.	From You: Collected when you make a purchase from us.

Other Users: Personal information may be shared with other users as part of the general operation of the service.
Others: Information may be disclosed upon the instruction of a user through the use of profile sharing functionality.
Our Affiliates: Affiliates may receive information, particularly for the prevention, detection, and mitigation of fraud or other illegal or unauthorized activities under our Terms.
Payment Service Providers and Fraud Vendors: Personal information may be shared with payment service providers and fraud vendors to address anti-fraud concerns and combat other illegal activities.
Joint Marketing Partners: Information may be disclosed to joint marketing partners in relation to marketing activities.
Other Vendors and Professional Services Organizations: Personal information may be shared with vendors and professional service providers who assist in fulfilling the business or commercial purposes outlined herein.

Performing Services: This includes maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, delivering advertising or marketing services, providing analytics and storage services, or similar functions.
Auditing: Conducting audits related to counting ad impressions for unique visitors, verifying the positioning and quality of ad impressions, and ensuring compliance with advertising standards.
Short-Term, Transient Use: Utilizing personal information for purposes such as contextual customization of ads shown within the same interaction.
Ensuring Security and Integrity: Helping to ensure the security and integrity of our services.
Debugging: Identifying and repairing errors that impair the intended functionality of our services.
Internal Research: Undertaking internal research for technological development and demonstration.
Quality and Safety: Verifying or maintaining the quality or safety of a service or device that is owned, manufactured, or controlled by us, as well as improving, upgrading, or enhancing such services or devices.
Career Opportunities: Managing and overseeing our career opportunities and related processes.

Biometric information	From You: Collected when you use our photo verification feature.	Our Payment Processors and Fraud Vendors: Disclosed for anti-fraud purposes and to combat other illegal activities. Other Vendors and Professional Services Organizations: Disclosed to assist in fulfilling the business or commercial purposes outlined herein.
Internet and Other Electronic Network Activity Information This may include, but is not limited to, browsing history, search history, and information regarding your interactions with websites, applications, or advertisements.	From You: Collected through logs generated as you use our services. From Users of Our Services: Collected through interactions with other users. From Advertising Partners: Collected when our ads promoting services are published on a partner’s website.	Vendors and Professional Services Organizations: Disclosed to assist in fulfilling the business or commercial purposes outlined herein.
Geolocation data, including precise geolocation information	From Your Device: Collected when you consent to the collection and use of your geolocation while using our services.	Vendors and Professional Services Organizations: These entities assist us in fulfilling the business or commercial purposes outlined in this policy.
Audio, electronic, visual, and similar information	From You: Collected from the photos you upload when creating an account with us. From Social Media Networks: Collected when you upload photos from one of your social media accounts. From Consumer Reporting Agencies: Collected when they share information about bad actors. From Our Affiliated Companies: Collected primarily for anti-fraud and safety purposes.	Other users as part of the general operation of the service. Others, upon the instruction of a user using a profile sharing functionality. Our affiliates (in particular to prevent, detect and fight fraud or other illegal or unauthorized activities under our Terms). Joint marketing partners. Other vendors and professional services organizations who assist us in relation to the business or commercial purposes laid out herein.
Professional or employment-related information	Created from data in your profile	Vendors and Professional Services Organizations: These entities assist us in fulfilling the business or commercial purposes outlined in this policy.
Contents of your messages on our services	From You: Collected when you use the messaging features on our services.	Vendors and Professional Services Organizations: These entities assist us in fulfilling the business or commercial purposes outlined in this policy.

Some of the information we collect constitutes “sensitive personal information” under the CCPA. This includes information that reveals your social security number, driver’s license number, state identification card number, passport number, precise geolocation, racial or ethnic origin, sex life or sexual orientation, religious or philosophical beliefs, biometric information, and the contents of your messages. We use sensitive personal information solely for the purpose of providing and improving our services, as well as protecting our services and community. We do not use sensitive personal information to infer characteristics about you.

How Long We Retain Your Information

We retain your personal information only for as long as necessary for legitimate business purposes and as permitted by applicable law. If you choose to stop using our services, you can close your account, at which point your profile will no longer be visible to other members. Please note that if your account remains inactive for a period of two years, it will be automatically closed. Once your account is closed, your personal information will be deleted according to the guidelines outlined below:

Safety Retention Window: To ensure the safety and security of our members, we retain your information for a safety retention period of three months following account closure or one year following an account ban. During this time, the information may be necessary to investigate unlawful or harmful activities. This retention is based on our legitimate interest and the potential interests of third-party victims.
Post-Retention Period: After the safety retention window expires, your data will be deleted, except for limited information retained for the following purposes:

a) Legal Compliance: We retain certain data to comply with legal obligations, such as transaction data for 10 years for tax and accounting purposes, credit card information for the duration users may dispute transactions, and “traffic data”/logs for one year to comply with legal data retention requirements. Consent records are also retained for five years to demonstrate compliance with applicable laws.
b) Business Purposes: We retain customer care records, supporting data, and imprecise location of downloads/purchases for five years to support customer service, enforce our rights, and defend against claims. Information related to past accounts and subscriptions is kept for three years after account closure to ensure accurate financial forecasting. Profile data may be retained for one year in anticipation of potential litigation, and data necessary to prevent banned users from creating new accounts is kept for as long as needed to protect the safety and vital interests of our members.
c) Outstanding Legal or Dispute Issues: In cases of ongoing or potential disputes, claims, or legal issues, we retain relevant information for as long as necessary. This includes instances where we receive valid legal requests, subpoenas, or if data is necessary for legal proceedings.

California Consumer Privacy Rights

Sales/Sharing Opt-Out: We do not “sell” or “share” your personal information, as defined by the California Consumer Privacy Act (CCPA). This means there is no need to opt out of any sale or sharing of your personal data for monetary or other valuable consideration or cross-context behavioral advertising.
Know/Access: You have the right to request information about the personal data we process about you, including the right to obtain a copy of the specific pieces of personal information we have collected.
Correction: You have the right to request corrections to any inaccurate personal information we hold about you.
Deletion: You have the right to request the deletion of personal information that we have collected from you.
Non-Discrimination: You are entitled to non-discriminatory treatment should you choose to exercise any of your rights under the CCPA.

How to Submit a Rights Request

We aim to give you control over your information. Section 6 of our Privacy Policy provides tools and options for accessing, correcting, and deleting your personal information. You may also submit a request directly to us for access, correction, or deletion of your information.

To submit a request, [click here] or contact us using the information provided in Section 12 of our Privacy Policy. To safeguard your privacy and maintain security, we will take steps to verify your identity before granting access or complying with your request. If you submit a request while logged into your account, that may suffice for verification; otherwise, we may request additional proof of identity. Authorized agents may submit requests on your behalf, but we may require proof of authorization, such as a valid power of attorney or other written consent, and we may verify your identity as well. If you are an authorized agent submitting a request, please contact us with proof of authorization.