Privacy Policy

1. SCOPE OF THIS POLICY

FlipTree Technologies (India) Private Limited ("FlipTree", “Facilitator", "we", "our", or "us") values your privacy. When you use the Platform, you trust us with your personal data. That starts with helping you understand our privacy practices. This Privacy Policy ("Policy") describes the personal data we collect, how it is used and shared, and your choices regarding this data. This Policy applies to the Platform, and all Users on the Platform. This Policy is incorporated by reference into the Terms. Any capitalized terms used and not defined in this Policy shall have the meaning given to them in the Terms. By accessing or using the Platform, you agree to this Policy. IF YOU DO NOT AGREE TO THIS POLICY, PLEASE DO NOT ACCESS OR USE THE PLATFORM.

2. KEY TERMS

"Platform" means all Peck Dating websites, mobile or other applications, software, processes, and any other services provided by or through Peck Dating Mobile App, which enable Users to connect to other Users.

"User" (each a "User" and, collectively, the "Users") means a person who voluntarily submits information to the Platform and completes the Facilitator's Account registration process on the Platform regardless of whether such person uses the Service as a free member or a paid member on the Platform.

"Member" (each a "Member" and, collectively, the "Members") means a User on the Platform.

"Candidate" (each a "Candidate" and, collectively, the "Candidates") means a User on the Platform.

"Application" (each a "Application" and, collectively, the "Applications") means mobile or other applications.

"Account" (each a "Account" and, collectively, the "Accounts") or "User Account" (each a "User Account" and, collectively, the "User Accounts") means a personal account of a User on the Platform.

"Service" (each a "Service" and, collectively, the "Services") means the matchmaking service provided by the Platform to a User where the User is matched against another User(s) on the Platform based on the User’s preferences or the Facilitator’s recommendations.

"Content" means text, graphics, images, music, software, audio, video, information, or other materials, including but not limited to profile information, message threads, reviews, and other information or materials available on or through the Platform.

"Peck Dating Content" means all Content the Facilitator makes available on or through the Platform, including any Content licensed from a third-party, but excluding User Content.

"User Content" means all Content submitted, posted, uploaded, published, or transmitted on or through the Platform by any User or other User of the Platform, including but not limited to photographs, profile information, personal contact information, descriptions, postings, reviews, requests, messages, and payments made through the Platform, but excluding Peck Dating Content and Feedback.

"Collective Content" means User Content and Peck Dating Content together.

"Digital Good" (each a "Digital Good" and, collectively, the "Digital Goods") means digital goods including but not limited to messages, features, memberships, subscriptions etc. purchased on the Platform by the User.

"Payment Method" (each a "Payment Method" and, collectively, the "Payment Methods") means a current, valid, accepted method of payment submitted by User such as UPI, Net Banking, credit card, debit card, prepaid card, Google Pay, Apple Pay etc. as may be updated from time to time.

"Payment Processor" means the third-party payment service provider providing payment processing services on the Platform.

"Device" (each a "Device" and, collectively, the "Devices") or "Mobile Device" (each a "Mobile Device" and, collectively, the "Mobile Devices") means Apple iOS or Android smartphone capable of accessing the Platform.

“Terms" means Peck Dating Terms and Conditions. "Internet" means internet.

3. OVERVIEW

The Platform collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular User or Device (collectively, the "Personal Information"). By using the Platform, you are authorizing us to collect, parse, and retain data related to the provision of the Platform. However, we also provide Users with options and choices regarding how we use and disclose some or all of your Personal Information, as set forth specifically below, including how to access, correct, and/or remove it. You may avoid further said data collection by uninstalling the Application from your Mobile Device, or otherwise not using the Platform.

4. INFORMATION WE COLLECT

When you visit or use the Platform, we collect information about you. This includes basic profile details and the types of individuals you wish to connect with. Additionally, using our service generates information such as your login times and how you interact with various features of the Platform. We may also acquire data from third parties, such as when you access the Platform through an account on another service (Facebook, Google, or Apple) or when you import information from your account on another platform to complete your profile. We collect the following information in the following general manner:

• a. Data provided by Users to the Facilitator: When Users engage in the Platform, information is gathered in forms completed, images uploaded, or products and Services purchased. This includes:

  Account Registration: We collect data when Users of the Platform create or update their Accounts including their name, phone number, email address, login name, address, profile picture etc. We may use the photographs submitted to verify their identities. While creating your Account, it is necessary to upload pictures of yourself and to select a display picture for your Account. We may use an external face recognition tool and other techniques to select the best pictures for your Account. This selection may be based on features like image quality, composition, and authenticity. Images uploaded by you may be modified by us to make them more presentable on the platform. New pictures uploaded by you will be reviewed before they appear on your Account. The pictures that you upload will be displayed to other Users. Your Avatar or other photos may also be included in email messages from the Platform to other Users if the Platform considers you to be a good match with that User. Your Account, including pictures might be displayed on the homepage of the Platform for public viewing.

  Customer Support: We may collect Personal Information such as your name, email address, phone number, mailing address, feedback, photographs, or other recordings through your communications with our Customer Support team.

  Information to be published or displayed (User Content): Your User Content is posted on and transmitted to others at your own risk. The Facilitator cannot control the actions of other Users of the Platform with whom you share your User Content.

• b. Information We Collect When You Use the Platform: The Facilitator gathers Data created during use of the Platform. This includes:

  Location Information: We collect precise or approximate location data through the Platform when it is used by Users if the Users' devices permit such information collection. We may collect this information when certain functionalities are used, such as selecting "my location" or navigating to a location to provide the Services. We may also collect the precise location of User's device when the Platform is running in the foreground or background of their mobile device. Users may use the Platform without enabling the Facilitator to collect location data from their mobile devices. However, this may affect some functionality available on the Platform. For example, a User who has not enabled location data collection will have to manually enter their address. We may derive a User's approximate location from the User's IP address. We also may use and disclose geo-location we collect through the Platform for other business purposes, including for legal purposes. The geo-location information obtained about a User will be retained in an identifiable manner, along with geo-location data. In addition, the location data collected from a User will be linked to the User's account, even if they have not enabled location data to be collected from their device, including for purposes of customer support, fraud detection, insurance, and litigation.

  Your chat messages and other written content: Your chat messages are strictly confidential and is only processed in order to give you access to your chat history. Please note that we do use filter software and techniques that notifies us of chat messages with inappropriate content (derogatory or aggressive language, or unlawful use of the Platform for advertisements or link-building.) After such notification we reserve the right to erase the offensive content or even close your Account. This is applicable to all User Content.

  Inviting friends: If you refer a friend to the Platform, you will send an email message, WhatsApp message, SMS, Messenger message to the contact details you submitted to us. We won't share these details with anyone else. By choosing to invite your friend to join the Platform you confirm that your friend agreed to receive the invitation. You also hereby agree to indemnify and hold the Facilitator harmless from all claims arising out of your messages to any person through the Platform. You must and will not use our invite friends feature to send spam.

  Device Information: We may collect information about your mobile device, including the hardware model, operating system/version, software names/versions, file names/versions, preferred language, unique device identifier, IP address, advertising identifiers, serial number, device motion information, and mobile network information.

  Usage and Preference Information: We collect data about how Users and visitors interact with the Platform. This includes data such as access dates and times, Platform features or pages viewed, Platform crashes and other system activity, type of browser, and third-party sites or Services used before interacting with our Services. In some cases, we collect this data through cookies, pixels, tags, and similar tracking technologies that create and maintain unique identifiers. When we associate such information with specific personal information, we will treat the combination as Personal Information, as set forth herein.

  Log Information: When you interact with the Platform, we collect server logs, which may include device IP addresses, access dates and times, Platform features or pages viewed, Platform crashes and other system activity, browser type, and the third-party site/service accessed immediately prior to interacting with the Platform.

  Cookies and Third-Party Technologies: Like most online services and mobile applications, we and our Third- Party Providers may use cookies, web beacons, and similar tracking technologies to collect information about your activity from the computer or devices you use to access the Platform for purposes described in this Policy. A cookie is a file saved on a User's hard drive that stores certain information about User activity. Users must agree to let cookies be saved for them, and most web browsers are set to accept cookies by default. Although you can modify your browser/device settings to reject cookies if desired, this could potentially affect the availability and functionality of our Services. The Facilitator uses cookies and similar technologies for purposes such as authenticating Users, remembering User preferences and settings, determining the popularity of content, delivering and measuring the effectiveness of advertising campaigns, analyzing site traffic and trends, and generally understanding the online behaviors and interests of people who interact with the Platform.

• c. Information We Collect from Third-Party Providers: The Facilitator engages with Third-Party Providers that provide information that makes it possible to run elemental aspects of the Platform. Some of the things these service providers allow for are identity verification, marketing, and other businesses. The Facilitator may combine the data collected from these sources with other data in its possession. Information we receive from these third parties includes:

  • Safety and Security Information, such as identity verification of the User.
  • Third-Party program participation information, such as transactions and fraud detection;

  Third-Party Site Account Access: If you log in to the Platform through a third-party site, such as Apple, Google or Facebook, we may collect your authentication token, registration information (including but not limited to name, email address, photograph (if any)), and account identification number and use that information to provide you with access to your Account on the Platform.

  The information we gather from members and visitors who apply for the various Services our Website/Apps offers includes, but may not be limited to, photo of the user, email address, name, date of birth, educational qualifications, a user-specified password, mailing address, pin code and telephone/mobile number or fax number. Cookies are used to store the login information. Cookies are small files placed on your hard drive that will assist us in providing our services. You may also encounter Cookies or identical/related devices on certain pages of the website/apps that are placed by third parties. We do not control the use of cookies by third parties.

  We may also use your Personal Information for verification, analysis of data, usage trends and to evaluate and improve our Platform, marketing research, prevention of frauds. In our efforts to continually improve our product and service offerings, we collect and analyze demographic and profile data about User activity on the Platform. We identify and use your IP address to help diagnose problems with our server, and to administer the Platform. Your IP address is also used to help identify you and to gather broad demographic information.

  If you're interested in all the details, be sure to check out the table below.

  Information Provided by Users to the Facilitator

  Categories	Description
  Account Data	When setting up your account, you provide key information such as your phone number, email address, and date of birth to facilitate the creation and management of your account on the Platform.
  Profile Data	When you complete your profile, you provide additional personal details, such as your gender, interests, preferences, and approximate location. In some cases, this information may be classified as sensitive, including aspects like sexual orientation, health, or political beliefs, depending on your country. By choosing to share this information, you consent to its use in accordance with this Privacy Policy.
  Content	When using our services, you may upload and share various types of content, including photos, videos, audio, text, and chat messages exchanged with other members.
  Purchase Data	When you make a purchase, we retain details of the transaction, such as the item purchased, transaction date, and price. The specific information we collect depends on the payment method you choose. If you pay directly through our platform, you provide your debit or credit card details or other financial information.
  Marketing, Survey, and Research Data	We occasionally conduct surveys, focus groups, or market studies for research, and run promotions, events, or contests for marketing purposes. By participating, you provide information that allows us to process your entry, manage your participation, and record your responses and feedback.
  Third-Party Data	If you provide us with information about other individuals (such as their contact details for a feature or when submitting a query or report about another member), we process this data on your behalf to fulfill your request.
  Customer Support Data	When you contact us, you provide the details necessary to address your inquiry. Other users may also submit reports or queries about you. Our moderation tools and team may gather additional data as part of any investigations. Where permitted by law, we may also receive information from third parties about individuals suspected or convicted of harmful behavior to ensure the safety and security of our members.
  Social Media Data	You may choose to share information with us through your accounts on other platforms (Facebook, Instagram, Spotify, Apple). This could include logging into your account via these platforms or uploading data, such as photos or playlists, from them to our service.

  Data generated or automatically collected

  Categories	Description
  Usage Data	When you use the service, data about your activity is generated, such as when you logged in, the features you accessed, actions you took, and the information displayed to you. This also includes data about how you interact with others (searching, matching, messaging). Additionally, we may collect information regarding your interactions with ads on third-party websites or apps.
  Technical Data	When you use the service, we collect data from and about the device(s) you use, including hardware and software details such as IP address, device ID and type, app settings and characteristics, app crashes, advertising IDs, and identifiers linked to cookies or other technologies that can uniquely identify your device or browser. For more details, please refer to our Cookie Policy.

  Other data we collect with your permission/consent

  Categories	Description
  Geolocation Data	With your permission, we can collect your device’s geolocation (latitude and longitude). If you choose to decline, certain features that depend on precise location may not be accessible to you.
  Face Geometry Data	Face Geometry Data: You may choose to participate in features like Photo Verification or ID Verification, which involve collecting face geometry data. In some jurisdictions, this may be considered biometric data. Learn more about how we process your face geometry data through these verification features.
  ID Data	You may provide us with a copy of your government-issued ID to help verify your identity and confirm that you are who you claim to be.

5. HOW WE USE YOUR INFORMATION

When you visit or use the Platform, we collect information about you for data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns, evaluating and improving our websites or apps, products, and services, conducting market research to ensure that we are able to fulfill your requirements, and delivering a personalized experience. The primary reason we process your data is to provide and enhance our service over time. This includes connecting you with members who share your interests, personalizing your experience, and assisting you in making the most of our service. Additionally, we process your data to maintain the safety and security of you and all our members while using our service. We take this responsibility very seriously and are continuously working to improve our systems and processes to protect you.We may use your information for any of the following reasons:

• For the purposes for which you provided it.

• Automated Decision-making: We use personal data to make automated decisions relating to use of our Services.

• Customer Support: The Facilitator uses the information we collect (including recordings of customer support calls) to provide customer support, including to direct questions to the appropriate customer support person, investigate and address User concerns, monitor and improve our customer support responses and processes.

• Internal record-keeping purposes.

• Legal Proceedings and Requirements: We may use the personal data we collect to investigate or address claims or disputes relating to your use of the Platform and Services, or as otherwise allowed by applicable law, or as requested by regulators, government entities, and official inquiries.

• Marketing Communications: The Facilitator may use the data we collect to market our Services to our Users. This includes sending Users communications about Services, features, promotions, sweepstakes, studies, surveys, news, updates, events etc.

• Non-Marketing Communications: The Facilitator may use the data we collect to generate and provide users with receipts; inform them of changes to our Terms or policies; or send other communications that are not for the purpose of marketing the Services or products of the Facilitator or its partners.

• Personalize your platform experience and deliver content and product and service offering relevant to your interests, including targeted offers and ads through our platform, and via email or text (SMS) message.

• Research and Development: We may use the information we collect for testing, research, analysis and product development, including to develop and improve our Platform, Services, and User experience. This allows us to improve and enhance the safety and security of our Platform, develop new features and products in connection with our Services.

• Safety and Security: Monitor, maintain, improve, and enhance the safety, security, and integrity of our Platform, Services, Users, databases and other technology assets, and business. This includes screening Users through identity verification as well as using Device, location, profile, usage, and other data to prevent, detect, and combat fraud or unsafe activities.

• To address fraud or safety concerns, or to investigate complaints or suspected fraud or wrongdoing.

• To contact you in connection with your activities on the Platform (including, but not limited to, confirmation email, account verification text (SMS) messages, push notification alerts, or important alerts) that could affect your relationship with the Facilitator.

• To create, maintain, customize, update, and secure your Account.

• To enable communications between Users.

• To enable you to use the Services available through the Platform, including registering you for our Services and verifying your identity and authority to use our Services.

• To monitor and analyze usage and activity trends.

• To perform internal operations necessary to provide our Services.

• To protect the Facilitator and other Users of the Platform, and to enforce any legal terms that govern your use of the Platform.

• To troubleshoot software bugs and operational problems.

• To contact you by phone or text (SMS) message regarding Platform features, improvements, or other products and Services that may interest you.

• To contact you by text (SMS) message regarding certain Services or information you have requested.

We may display information related to you, including your name, photograph, pictures, registered phone number, location, contact information, Services offered, license(s) and/or certification(s) (if any), publicly on your profile, except to the extent we tell you we will not display such information. If the information you provide us upon signing up for an account differs from the information you provide us as part of the verification data we collect, we have sole discretion in determining which information will be displayed publicly on your profile. We may combine information that we collect from you through the Platform with information that we obtain from affiliated and nonaffiliated third parties, and information derived from any other products or Services we provide. We may aggregate and/or de-identify information collected through the Platform. We may use de-identified or aggregated data for any purpose, including without limitation for research and marketing purposes and may also share such data with any third parties, including without limitation, advertisers, promotional partners, sponsors, event promoters, and/or others. We may, either directly or through third parties we engage to provide Services to us, review, scan, or analyze your communications with other Users exchanged via the Platform or as otherwise described in this Policy for fraud prevention, risk assessment, regulatory compliance, investigation, debugging, troubleshooting, product improvement, research and development, and customer support purposes.

6. HOW WE SHARE YOUR INFORMATION

As set forth herein, we do not rent, sell, or share Personal Information about you with other people or nonaffiliated companies for their direct marketing purposes unless we have your permission. We may allow access to other data collected by the Platform to enable the delivery of our online advertising on the Platform and on other websites and online services, or to send you information we think may be useful or relevant to you. We may share such identifiable information with our associates/affiliates/subsidiaries and such associates/affiliates/subsidiaries may market to you as a result of such sharing. Any information you give us is held with the utmost care and security. We are also bound to cooperate fully should a situation arise where we are required by law or legal process to provide information about a User. Where required or permitted by law, information may be provided to others, such as regulators and law enforcement agencies or to protect the rights, property or personal safety of other members or the general public. We may voluntarily share your information with law enforcement agencies/Gateway service providers/anti-fraud solution provider(s) if we feel that your transactions on the Platform are of suspicious nature. From time to time, we may consider corporate transactions such as a merger, acquisition, reorganization, asset sale, or similar. In these instances, we may transfer or allow access to information to enable the assessment and undertaking of that transaction. If we buy or sell any business or assets, personal information may be transferred to third parties involved in the transaction. Our Platform links to other websites/apps that may collect personally identifiable information about you. We are not responsible for the privacy policy or the contents of those linked websites/apps. The following are examples of how we share your information.

• a. Sharing between Platform Users: We will display certain information about you to other Users, including your name, photograph, location, contact information such as registered phone number etc.
• b. Sharing with Third-Party Providers for a Business Purpose:

By using the Platform, you acknowledge and agree that the Facilitator cannot and does not control the actions of third parties with whom your data may be shared in accordance with this Policy. The Facilitator expressly disclaims any liability for third-party practices or the misuse of your personal information by third parties.

Categories of Information We Share: To operate the Platform, including processing your transactions and supporting your activities on the Platform, we may disclose the following categories of your Personal Information with vendors, agents, and Third-Party Providers for a business purpose. We may also use the below categories of information for compliance with applicable laws and regulations, and we may combine the information we collect ("aggregate") or remove pieces of information ("de-identify") to limit or prevent identification of any particular User or Device.

• Identifiers: Name, address, unique personal identifier, IP address, email address, government-issued ID (Aadhaar Card, Passport, Permanent Account Number (PAN) Card, Driving License, or Voter Identity Card), phone number, or other similar identifiers.
• Personal information: Name, date of birth, address, email address, photos, physical characteristics or description, phone number.
• Internet or Other Network or Device Activity: Browsing history, IP address, search history, information on User's interaction with a website, application, or advertisement.
• Geolocation information: Physical location or movements.
• Sensory information: Audio or Video recordings of User on the Platform as well as Audio recordings if you call our customer support.
• Inferences drawn from other personal information.
• Other information: User generated content such as reviews.

Third-Party Providers: To operate the Platform, including processing your transactions, we may share your information with our agents, representatives, vendors and service providers (each a "Third-Party Provider" and, collectively, the "Third-Party Providers"). Third-Party Providers assist us with services such as identity verification, data storage, cloud services, data analytics, marketing and advertising, website hosting, fraud prevention and detection, communication services, and technical support. We share information, including Personal Information, with Third-Party Providers that process information on our behalf for our business purposes as follows:

• To originate emails.
• To provide support services.
• To perform data analytics services on the Platform.
• To provide customer relationship management services.
• To create, maintain, customize, service and secure your Account with us.
• To fulfill or meet the reason for which you provided the information. If you provide your Personal Information to purchase or provide a product or Service, we will use that information to process your request and facilitate delivery. We may also save your information to facilitate new requests or address disputes.
• To provide, support, personalize, and develop our Platform and Services.
• Insurance Service Providers: In the event of an insurance claim, we would provide the information necessary for reporting and documentation, including name and address.
• External Mediators: We may use a third-party mediator to resolve disputes between Users when necessary. The Facilitator shares the name, address, phone number, and email address of Users with such third-party mediator service providers.
• Research and Development: We may use the information we collect for testing, research, analysis and product development, including to develop and improve our Platform, Services, and User experience. This allows us to improve and enhance the safety and security of our Platform, develop new features and products in connection with our Services.

c. Legal Obligations and Protecting the Platform and Others: We may disclose your information when required by law or when we believe in good faith that such disclosure is necessary to: (a) comply with subpoenas, court orders, regulation, operating license or agreement, legal process or governmental request, other legal process we receive or where the disclosure is otherwise appropriate due to safety or similar concerns; (b) establish or exercise our legal rights including enforcing and administering agreements with Users; or (c) defend the Facilitator against legal claims. This includes sharing personal data with law enforcement officials, public health officials, other government authorities, or other third parties as necessary to enforce our Terms, or other policies; to protect the Facilitator's rights or property or the rights, safety, or property of others; or in the event of a claim or dispute relating to the use of our services. The Facilitator may also disclose your Personal Information as part of a dispute among Users or between Users and the Facilitator to an attorney in the process of obtaining legal advice. If we are required by law to disclose your information, we will use commercially reasonable efforts to notify you unless: (a) we believe in our sole discretion that providing notice could create a risk of injury or death, or that harm or fraud could be directed to the Facilitator or Users; or (b) we are precluded from providing notice by law. We will attempt to provide the notice by email if you have given us an email address. While you may challenge the disclosure request, please be advised that we may still be legally required to turn over your information. We may disclose your information to whomever necessary when we believe it is appropriate to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of the Terms or any other legal terms governing use of the Platform, and/or to protect our rights and property and the rights and property of other Users.

d. Merger, Sale, or Other Asset Transfers: If we are involved in a merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company, your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. We cannot control how such entities may use or disclose such information.

e. App Store Providers. We may provide your identity and mobile device identifier to third-party app store providers (for the Apple App Store or Google Play Store) to allow you to download our mobile apps.

f. Academics and Research. We may provide information about Users to third parties for academic and research purposes, in anonymized or aggregated form.

g. With Your Permission: We may also disclose your Personal Information with your permission as set forth herein.

THE FACILITATOR SHALL NOT BE HELD RESPONSIBLE OR LIABLE FOR ANY MISUSE OR BREACH OF YOUR PERSONAL INFORMATION BY THIRD PARTIES, INCLUDING BUT NOT LIMITED TO, THIRD-PARTY PROVIDERS, ADVERTISING PARTNERS, SOCIAL MEDIA PLATFORMS, OR LINKED WEBSITES.

• Social Networking and Other Websites: The Platform may allow you to share information, including Personal Information, with social networking websites, such as Facebook, Google, etc. Except for our marketing and advertising purposes, we do not share your Personal Information with them unless you specifically authorize it. If you choose to log in to the Platform through social networking websites, we may share information about your Account with the social networking site. Their use of the information will be governed by their privacy policies, and you may be able to modify your privacy settings on their websites. Please be advised that some information you provide and/or that we collect will be publicly accessible. For instance, registration for an Account requires that you provide us with your name. If you register through Apple, Google or Facebook, the Platform will use the name associated with your account on those platforms. Your name (full name, or in some instances, your first name and last initial) may be visible to other Users. Depending on the circumstances, your name may be attached to your Content or information, such as scheduling of Services, Service requests, reviews, participating in discussions or forums, messaging, and profile information. Certain other people, including other Users with whom you have interacted via the Platform, will see information about you that is attached to your name. Users may be able to personally identify you based on Content you provide. Similarly, the information we collect, including but not limited to when you last accessed the Platform, may be shared with other Users with whom you are interacting or otherwise made public.

We invite you to post Content on or through our Platform, including, but not limited to, your comments, photographs, pictures, User profile, and any other information. However, please be careful and responsible whenever you are online. If you choose to post User Content on or through the Platform, such as through intra-User messaging or through our review boards, forums, blogs, or other postings, that information: (a) may be or may become publicly available; (b) may be collected and used by third parties with or without our knowledge; and (c) may be used in a manner that may violate this Policy, the law, or your personal privacy.

Cross-Border Data Transfers: As we provide a global service, the sharing of your data as described in this section may involve transfers to the United States and other countries with different data protection laws. When we transfer personal data outside of the EEA, United Kingdom, Switzerland, or countries with laws deemed adequate by the European Commission or other governing bodies, we typically rely on standard contractual clauses. These clauses are legal commitments between companies to ensure the privacy and security of your data. Contact us if you would like a copy.

For more please refer to this table.

7. HOW WE STORE AND PROTECT YOUR INFORMATION

• a. Information Retention: The Facilitator retains User profile, transaction, and other personal data for as long as a User maintains their Account. The Facilitator may retain certain User data after receiving an Account cancellation request if necessary, such as to comply with legal requirements. To preserve the integrity of our databases, standard procedure calls for us to retain information submitted by Users for an indefinite length of time. You agree that we may store the information we collect for this indefinite length of time.
• b. Our Security Precautions: Your Account is linked to your phone number so that only you and authorized Facilitator employees have access to your Account information. In order to maintain this protection, do not give your Account password to anyone. The Facilitator staff will never proactively reach out to you and ask for any personal Account information, including your password. If you share a Mobile Device or computer, in order to protect your information entered on public terminals from disclosure to third parties, you should sign out of your Account before someone else logs on. We employ physical, procedural, and technological security measures to help protect your Personal Information from unauthorized access or disclosure. The Facilitator may use encryption, passwords, and physical security measures to help protect your Personal Information against unauthorized access and disclosure. You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, keeping your log-in and password private, and not recycling passwords from other websites or accounts. The Facilitator is not responsible for the unauthorized use of your information nor for any lost, stolen, or compromised passwords, or for any activity on your Account via unauthorized password activity.
• c. As stipulated in the Privacy Policy we will retain the information we collect from Users for as long as the Users subscribe to our Services to meet their suitable purpose(s) for which it was collected, for the sake of enforcing agreements, for performing audits, for resolving any form of disputes, for establishing legal defenses, for pursuing legitimate businesses and to comply with the relevant applicable laws.

The Facilitator takes steps to ensure that your information is secure on its system. No security measures, however, are 100% failsafe. As a result, the Facilitator cannot guarantee the security of any information you transmit to us, and you do so at your own risk. The Facilitator EXPRESSLY DISCLAIMS ANY REPRESENTATION OR WARRANTY, WHETHER EXPRESSED OR IMPLIED, WITH RESPECT TO ENSURING, GUARANTEEING, OR OTHERWISE OFFERING ANY DEFINITIVE PROMISE OF SECURITY IN CONNECTION WITH YOUR PERSONAL INFORMATION OR USAGE INFORMATION AND FURTHER DISCLAIMS ANY LIABILITY THAT MAY ARISE SHOULD ANY OTHER INDIVIDUALS OBTAIN THE INFORMATION YOU SUBMIT TO THE PLATFORM.

Account Closure: If you choose to discontinue using our service, you have the option to close your account. Once closed, your profile will no longer be visible to other members. Additionally, if your account remains inactive for two years, we will automatically close it.

Data Deletion After Account Closure: Upon closing your account, we handle your data as follows:

• a. Safety Retention Period To ensure the safety and security of our members, we retain your data for three months following account closure or for one year following an account ban. During this period, your data is preserved to investigate any unlawful or harmful activities. This retention is based on our legitimate interests and those of potential third-party victims.

• b. Legal Compliance
  We maintain specific data to adhere to legal data retention obligations:

  • Transaction Data: Retained for 10 years to comply with tax and accounting requirements.

  • Credit Card Information: Kept for the duration that a user may dispute a transaction.

  • Traffic Data/Logs: Stored for one year to satisfy legal data retention laws.

  • Consent Records: Held for five years to demonstrate our compliance with applicable laws.

• c. Legitimate Interests
  Based on our legitimate interests, we retain certain data:

  • Customer Care Communications: Stored for six years from the date of communication.

  • Customer Care Records and Supporting Data: Maintained for five years to support safety measures, customer service decisions, rights enforcement, and legal defense.

  • Past Accounts and Subscriptions Information: Deleted three years after the closure of your last account to ensure accurate financial forecasting and reporting.

  • Profile Data: Kept for one year in anticipation of potential legal actions.

  • Banned Members Data: Retained as long as necessary to prevent banned members from reopening accounts, thereby ensuring the safety and vital interests of our members.

  • Outstanding Legal Issues
    If there are ongoing or potential issues, claims, or disputes, or if we receive a valid legal subpoena or request to preserve data, we will retain the necessary data to comply with legal obligations and participate in legal proceedings.

• d. Use of Non-Identifiable Data Where legally permissible, we may retain and use data that cannot specifically identify you for the purposes outlined in this Privacy Policy. This includes activities such as improving our service, developing new features and technologies, and ensuring our safety.

8. PRIVACY OF MINORS

Our Services are not designed for minors (Less than 18 years). If we discover that a minor has registered on the Platform with false information, we will close the Account. We may, where permitted by law, retain certain information internally for purposes described in this Policy.

9. LINKS TO THIRD-PARTY WEBSITES

The Platform may contain links to other websites or resources over which the Facilitator does not have any control. Such links do not constitute an endorsement by the Facilitator of those external websites. You acknowledge that the Facilitator is providing these links to you only as a convenience, and further agree that the Facilitator is not responsible for the content of such external websites or the protection and privacy of information you provide while visiting such external websites.

10. YOUR RIGHTS AND CHOICES REGARDING YOUR DATA

The Facilitator enables Users to access and control the data that the Facilitator collects through:

• a. Changing or Updating Information: The Facilitator provides you with the ability to access, review and edit your Personal Information. Sign into the Platform, and then edit your Account information. So that we can protect the integrity of sensitive data, there are certain pieces of information, such as your name, age, gender, identity information that you cannot alter yourself. Please contact us at privacy@peckdating.com to change information you cannot access through your Account.
• b. Push Notifications: You can deactivate push notifications intended for marketing purposes. Push notifications for important updates regarding your appointments and Account activity are required for proper functioning of the Platform.
• c. Location Information: You can stop your Device from sharing Device location information via the Device system settings, although this could impact the full range of Services and features available through the Platform.
• d. Device Permissions: Most mobile device platforms (iOS, Android, etc.) have defined certain types of device data that apps cannot access without the device owner's permission, and these platforms have different methods for how that permission can be obtained. iOS devices notify users the first time the Platform requests permission to access certain types of data and gives users the option to grant or refuse permission. Android devices notify users of the permissions that the Platform seeks before their first use of the app, and use of the Platform constitutes a grant of such permission.
• e. Email Communications: We may send periodic emails to you. To opt out of promotional emails, you may submit a request to privacy@peckdating.com. If you opt out of receiving promotional emails, we may still send you emails about your Account or any Services you have requested or received from us.
• f. Cookies and Third-Party Technologies: Like most online services and mobile applications, we and our Third-Party Providers may use cookies, web beacons, and similar tracking technologies to collect information about your activity from the computer or devices you use to access the Platform for purposes described in this Policy. A cookie is a file saved on a User's hard drive that stores certain information about User activity. Users must agree to let cookies be saved for them, and most web browsers are set to accept cookies by default. Although you can modify your browser/device settings to reject cookies if desired, this could potentially affect the availability and functionality of our Services. The Facilitator uses cookies and similar technologies for purposes such as authenticating Users, remembering User preferences and settings, determining the popularity of content, delivering and measuring the effectiveness of advertising campaigns, analyzing site traffic and trends, and generally understanding the online behaviors and interests of people who interact with the Platform. Any third-party with whom we are allowed to share your Personal Information is authorized to use your Personal Information in accordance with our contractual arrangements with such third parties and in accordance with their own privacy policies, over which we have no control. You agree that we are not responsible or liable for any of their actions or omissions. Those who contact you will need to be instructed directly by you regarding your preferences for the use of your Personal Information by them.
• g. In some regions (like the EEA, UK, certain parts of US), you have certain rights under applicable data protection laws. You will be asked to provide consent to the collection, processing, and sharing of your personal information. These may include the right (i) to request access and obtain a copy of your personal information; (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. You have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent. If you are a resident in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority.

Your personal information may be stored in databases located outside of the EU including in India. Where we transfer personal data outside of EU, we either transfer personal information to countries that provide an adequate level of protection, or we have appropriate safeguards in place. We may require proof of or need to verify your identity before we can give effect to these rights. To request to review, update, or delete your personal information, please submit a request form by sending an email to privacy@peckdating.com. We may share your information with third-party anti-fraud solution provider(s). They help us to ensure we keep you safe from scammers and fraudsters.

For your protection and the protection of all members, we may request information to verify your identity or authority to act on behalf of a member before responding to your requests. We want to ensure your data stays secure.

Please note that we may deny requests if we cannot authenticate you, if the request is unlawful or invalid, or if fulfilling it would infringe on trade secrets, intellectual property, or someone else’s privacy rights. If you wish to obtain information related to another member, such as messages from them, they will need to submit the request themselves.

If you are a resident of Texas, Oregon, Montana, Virginia, Colorado, or Connecticut in the USA, and we deny your privacy request, you may appeal by contacting us and referencing “Privacy Request Appeal.” If you’re unsatisfied with the appeal result, you can contact your state’s attorney general.

In certain countries, including those in the European Economic Area and the United Kingdom, you can lodge a complaint with the relevant data protection authority if you have concerns about how we handle your data. You can find your data protection regulator in the EEA [here] and in the UK [here]. The appropriate authority could be in the region of your habitual residence, where you work, or where an infringement may have occurred.

11. CHANGES TO THIS POLICY

This Policy is current as of the effective date set forth above. The Facilitator may, in its sole and absolute discretion, change this Policy at any time to the extent permitted by law. The Facilitator will post its updated Policy on the platform and update the Policy effective date. The Facilitator encourages you to review this Policy regularly for any changes. Your continued access to or use of the Platform after such posting will constitute your acceptance of such changes. IF YOU DO NOT AGREE, YOU MAY NOT ACCESS OR USE THE PLATFORM.

12. GRIEVANCE OFFICER

As a User, if you have any grievance regarding the Platform or the Service, or any questions regarding this Privacy Policy, you can contact our Grievance Officer: Mr. Shanu V Shaji,
No. 4/461, 2nd Floor, Suite No.1327,
Valamkottil Towers, Judgemukku, Kakkanad,
Kochi, Kerala, India – 682021
or by sending an email to grievance@peckdating.com