Welcome to RELUVOTION’s PRIVACY POLICY, operated by DSU RELUVOTION, LLC (“us,” “we,” the “Company” or “RELUVOTION”). Thank you for taking the time to read it. At RELUVOTION, your privacy is a top priority. Your privacy is at the core of the way we design and build the services and products you know and love, so that you can fully trust them and focus on building meaningful connections. We appreciate that you put your trust in us when you provide us with your information and we do not take this lightly. We appreciate that you trust us with your information and we intend to always keep that trust. This starts with making sure you understand the information we collect, why we collect it, how it is used and your choices regarding your information. This Policy describes our privacy practices in plain language, keeping legal and technical jargon to a minimum. For California Consumers: Please see our California Privacy Statement to learn about California privacy rights.

01 Who we are

If you live in the European Union, the company that is responsible for your information under this Privacy Policy (the “data controller”) is: DSU RELUVOTION, LLC
2027 VILLAGE LANE, SUITE 203
SOLVANG CA 93463

If you live outside the European Union, the company responsible for your information is: DSU RELUVOTION, LLC
2027 VILLAGE LANE, SUITE 203
SOLVANG CA 93463

02 Where this Privacy Policy applies

This Privacy Policy applies to websites, apps, events and other services operated by RELUVOTION, including “reluvotion.com” and api endpoint “https://reluvotion-api-eu1-qog7g3owua-ey.a.run.app”. For simplicity, we refer to all of these as our “services” in this Privacy Policy.

03 Information we collect

It goes without saying, we can’t help you develop meaningful connections without some information aboutyou, such as basic profile details and preferences. We also collect information generated as you use our services, for example access logs, as well as information from third parties, like when you access our services through a social media account. INFORMATION YOU GIVE US You choose to give us certain information when using our services. This includes:

• When you create an account, you provide us with at least your login credentials, as well as some basic details necessary for the service to work, such as your gender and date of birth.
• When you complete your profile, you can share with us additional information, such as details on your personality, interests, core purposes, and other details about you, as well as content such as photos and videos. To add certain content, like pictures or videos, you may allow us to access your camera or photo album. Some of the information you choose to provide us may be considered “special” or “sensitive” in certain jurisdictions, for example your racial or ethnic origins, sexual orientation and religious beliefs. By choosing to provide this information, you consent to our processing of that information.
• We collect information about how you use our Products, such as the types of content you view or engage with; the features you use; the actions you take; the people or accounts you interact with; and the time, frequency and duration of your activities. For example, we log when you’re using and have last used our Products, and what posts, videos and other content you view on our Products. We also collect information about how you use features like our camera.
• Information about transactions made on our Products. If you use our Products for purchases or other financial transactions (such as when you make a purchase in a game or make a donation), we collect information about the purchase or transaction. This includes payment information, such as your credit or debit card number and other card information; other account and authentication information; and billing, shipping and contact details.
• When you participate in surveys or focus groups, you give us your insights into our products and services, responses to our questions and testimonials.
• When you choose to participate in our promotions, events or contests, we collect the information that you use to register or enter.
• If you contact our customer care team, we collect the information you give us during the interaction. Sometimes, we monitor or record these interactions for training purposes and to ensure a high quality of service.
• If you ask us to communicate with or otherwise process information of other people (for example, if you ask us to send an email on your behalf to one of your friends), we collect the information about others that you give us in order to complete your request.
• Of course, we also process your chats with other users as well as the content you publish, as part of the operation of the services.
• You can choose to provide information in your profile fields about your religious views, political views, who you are "interested in," or your health. This and other information (such as racial or ethnic origin, philosophical beliefs or trade unio

INFORMATION WE RECEIVE FROM OTHERS In addition to the information you provide us directly, we receive information about you from others,including:

• Other Users: Other users may provide information about you as they use our services. For instance, we may collect information about you from other users if they contact us about you.
• Social Media: You may be able to use your social media login to create and log into your RELUVOTION account. This saves you from having to remember yet another user name and password and allows you to share some information from your social media account with us.
• Other Partners: We may receive info about you from our partners, for instance where RELUVOTION ads are published on a partner’s websites and platforms (in which case they may pass along details on a campaign’s success).

INFORMATION COLLECTED WHEN YOU USE OUR SERVICES When you use our services, we collect information about which features you’ve used, how you’ve used them and the devices you use to access our services. See below for more details: Usage Information: We collect information about your activity on our services, for instance how you use them (e.g., date and time you logged in, features you’ve been using, searches, clicks and pages which have been shown to you, referring webpage address, advertising that you click on) and how you interact with other users (e.g., users you connect and interact with, time and date of your exchanges, number of messages you send and receive)

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

• hardware and software information such as IP address, device ID and type, device-specific and apps settings and characteristics, app crashes, advertising IDs (such as Google’s AAID and Apple's IDFA, both of which are randomly generated numbers that you can reset by going into your device’ settings), browser type, version and language, operating system, time zones, identifiers associated with cookies or other technologies that may uniquely identify your device or browser (e.g., IMEI/UDID and MAC address);
• information from and about the computers, phones, connected TVs and other web-connected devices you use that integrate with our Products, and we combine this information across different devices you use.
• Device operations: information about operations and behaviors performed on the device, such as whether a window is foregrounded or backgrounded, or mouse movements (which can help distinguish humans from bots).
• information on your wireless and mobile network connection, like your service provider and signal strength;
• Device signals: Bluetooth signals, and information about nearby Wi-Fi access points, beacons, and cell towers.
• Data from device settings: information you allow us to receive through device settings you turn on, such as access to your GPS location, camera or photos.
• With permission, we can collect your precise geolocation (latitude and longitude) through various means, depending on the service and device you’re using, including GPS, Bluetooth or Wi-Fi connections. The collection of your geolocation may occur in the background even when you aren’t using the services if the permission you gave us expressly permits such collection. If you decline permission for us to collect your geolocation, we will not collect it. Similarly, if you consent, we may collect your photos and videos (for instance, if you want to publish a photo, video or streaming on the services).

04 Cookies and other similar data collerction technologies

We use and may allow others to use cookies and similar technologies (e.g., web beacons, pixels) to recognize you and/or your device(s). Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) have a “Do Not Track” (“DNT”) feature that tells a website that a user does not want to have his or her online activity tracked. If a website that responds to a DNT signal receives a DNT signal, the browser can block that website from collecting certain information about the browser’s user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many businesses, including RELUVOTION, do not currently respond to DNT signals.

05 How we use information

The main reason we use your information is to deliver and improve our services. Additionally, we use your info to help keep you safe and to provide you with advertising that may be of interest to you. TO ADMINISTER YOUR ACCOUNT AND PROVIDE OUR SERVICES TO YOU

• Create and manage your account
• Provide you with customer support and respond to your requests
• Complete your transactions
• We use the information we have to send you marketing communications, communicate with you about our Products, and let you know about our policies and terms. We also use your information to respond to you when you contact us.
• We use the information we have (including from research partners we collaborate with) to conduct and support research and innovation on topics of general social welfare, technological advancement, public interest, health and well-being. For example, we analyze information we have about migration patterns during crises to aid relief efforts. Learn more about our research programs.

TO ADMINISTER YOUR ACCOUNT AND PROVIDE OUR SERVICES TO YOU

• Analyze your profile, activity on the service, and preferences to recommend meaningful connections to you and recommend you to others
• Show users’ profiles to one another

TO ENSURE A CONSISTENT EXPERIENCE ACROSS YOUR DEVICES

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

TO PROVIDE NEW RELUVOTION SERVICES TO YOU

• Register you and display your profile on new RELUVOTION features and apps
• Administer your account on these new features and apps

TO SERVE YOU RELEVANT OFFERS AND ADS

• Develop, display and track content and advertising tailored to your interests on our services and other sites
• Communicate with you by email, phone, social media or mobile device about products or services that we think may interest you
• Administer sweepstakes, contests, discounts or other offers
• We use the information we have to help advertisers and other partners measure the effectiveness and distribution of their ads and services, and understand the types of people who use their services and how people interact with their websites, apps, and services. Learn how we share information with these partners.
• Location-related information: We use location-related information-such as your current location, where you live, the places you like to go, and the businesses and people you're near-to provide, personalize and improve our Products, including ads, for you and others. Location-related information can be based on things like precise device location (if you've allowed us to collect it), IP addresses, and information from your and others' use of RELUVOTION Products

TO IMPROVE OUR SERVICES AND DEVELOP NEW ONES

• Conduct research and analysis of users’ behavior to improve our services and content (for instance, we may decide to change the look and feel or even substantially modify a given feature based on users’ behavior)
• Develop new features and services (for example, we may decide to build a new interests-based feature further to requests received from users).
• Administer focus groups and surveys

TO PREVENT, DETECT AND FIGHT FRAUD OR OTHER ILLEGAL OR UNAUTHORIZED ACTIVITIES

• Address ongoing or alleged misbehavior on and off-platform
• Perform data analysis to better understand and design countermeasures against these activities
• Retain data related to fraudulent activities to prevent against recurrences

TO ENSURE LEGAL COMPLIANCE

• Comply with legal requirements
• Assist law enforcement
• Enforce or exercise our rights, for example our Terms

TO PROCESS YOUR INFORMATION AS DESCRIBED ABOVE, WE RELY ON THE FOLLOWING LEGAL BASES:

• Provide our service to you: Most of the time, the reason we process your information is to perform the contract that you have with us. For instance, as you go about using our service to build meaningful connections, we use your information to maintain your account and your profile, to make it viewable to other users and recommend other users to you.
• Legitimate interests: We may use your information where we have legitimate interests to do so. For instance, we analyze users’ behavior on our services to continuously improve our offerings, we suggest offers we think might interest you, and we process information for administrative, fraud detection and other legal purposes.
• Consent: From time to time, we may ask for your consent to use your information for certain specific reasons. You may withdraw your consent at any time by contacting us at the address provided at the end of this Privacy Policy.

06 How we share information

RELUVOTION will not sell or share your Personally Identifiable Information (PII) to advertising networks, third party vendors, or any companies with the intent to target you for advertising or other activity. However, since our goal is to help you make meaningful connections, the main sharing of users’ information is, of course, with other users. We also share some users’ non-personal information and personal information in hashed, non-human readable form delivered in aggregate with service providers and partners who assist us in operating the services. WITH OTHER USERS You share information with other users when you voluntarily disclose information on the service (including your public profile). Please be careful with your information and make sure that the content you share is content that you’re comfortable being publicly viewable since neither you nor we can control what others do with your information once you share it. You should consider who you choose to share with, because people who can see your activity can choose to share it with others on and off our Products, including people and businesses outside the audience you shared with. For example, when you share a post or send a message to specific friends or accounts, they can download, screenshot, or reshare that content to others across or off our Products or in person. Also, when you comment on someone else's post or react to their content, your comment or reaction is visible to anyone who can see the other person's content. WITH OUR SERVICE PROVIDERS AND PARTNERS We use third parties to help us operate and improve our services. These third parties assist us with various tasks, including data hosting and maintenance, analytics, customer care, marketing, advertising, payment processing and security operations. We may also share information with partners who distribute and assist us in advertising our services. For instance, we may share limited information on you in hashed, non-human readable form to advertising partners. OTHER BUSINESSES We share your information with partner companies for them to assist us in processing your information, as service providers, upon our instructions and on our behalf. Assistance provided by other partner companies may include technical processing operations, such as data hosting and maintenance, customer care, marketing and targeted advertising, finance and accounting assistance, better understanding how our service is used and users’ behavior to improve our service, securing our data and systems and fighting against spam, abuse, fraud, infringement and other wrongdoings. We may also share information with other partner companies for legitimate business purposes such as corporate audit, analysis and consolidated reporting as well as compliance with applicable laws. We may also share user information with other partner companies to remove users who violate our terms of service, or have been reported for criminal activity and/or bad behavior. In some instances, we may remove that user from all platforms. PUBLIC INFORMATION Some public information can be seen by anyone, on or off our Products, including if they don't have an account. This includes username; any information you share with a public audience; information in your public profile; and content you share on your page, or any other public forum. You, other people using RELUVOTION, and we can provide access to or send public information to anyone on or off our Products, in search results, or through tools and APIs. Public information can also be seen, accessed, reshared or downloaded through third-party services such as search engines, APIs, and offline media such as TV, and by apps, websites and other services that integrate with our Products. FOR CORPORATE TRANSACTIONS We may transfer your information if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control. WHEN REQUIRED BY LAW We may disclose your information if reasonably necessary: (i) to comply with a legal process, such as a court order, subpoena or search warrant, government / law enforcement investigation or other legal requirements; (ii) to assist in the prevention or detection of crime (subject in each case to applicable law); or (iii) to protect the safety of any person. TO ENFORCE LEGAL RIGHTS We may also share information: (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary to protect our legal rights and legal rights of our users, business partners or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing. WITH YOUR CONSENT OR AT YOUR REQUEST We may ask for your consent to share your information with third parties. In any such case, we will make it clear why we want to share the information. We may use and share non-personal information (meaning information that, by itself, does not identify who you are such as device information, general demographics, general behavioral data, geolocation in de-identified form), as well as personal information in hashed, non-human readable form, under any of the above circumstances. We may also share this information with other partner companies and third parties (notably advertisers) to develop and deliver targeted advertising on our services and on websites or applications of third parties, and to analyze and report on advertising you see. We may combine this information with additional non-personal information or personal information in hashed, non-human readable form collected from other sources.

07 Cross-border- data transfers

Sharing of information laid out in Section 6 sometimes involves cross-border data transfers, for instance to the United States of America and other jurisdictions. As an example, where the service allows for users to be located in the European Economic Area (“EEA”), their personal information is transferred to countries outside of the EEA. We use standard contract clauses approved by the European Commission or other suitable safeguard to permit data transfers from the EEA to other countries. Standard contractual clauses are commitments between companies transferring personal data, binding them to protect the privacy and security of your data

08 Your rights

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

• Access / Update tools in the service. Tools and account settings that help you to access, rectify or delete information that you provided to us and that’s associated with your account directly within the service. If you have any question on those tools and settings, please contact our customer care team for help.
• Device permissions. Mobile platforms have permission systems for specific types of device data and notifications, such as phone book and location services as well as push notifications. You can change your settings on your device to either consent or oppose the collection of the corresponding information or the display of the corresponding notifications. Of course, if you do that, certain services may lose full functionality.
• Deletion. You can delete your account by using the corresponding functionality directly on the service.
• If you are a resident of EU, you may have further rights under the GDPR which are further expanded on below. This Privacy Policy makes a good faith effort to incorporates the rights under GDPR into its language.

WE WANT YOU TO BE AWARE OF YOUR PRIVACY RIGHTS. HERE ARE A FEW KEY POINTS TO REMEMBER:

• Reviewing your information. Applicable privacy laws may give you the right to review the personal information we keep about you (depending on the jurisdiction, this may be called right of access, right of portability or variations of those terms). You can request a copy of your personal information by putting in such a request.
• Updating your information. If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion or object to its processing, please contact us.

For your protection and the protection of all of our users, we may ask you to provide proof of identity before we can answer the above requests. Keep in mind, we may reject requests for certain reasons, including if the request is unlawful or if it may infringe on trade secrets or intellectual property or the privacy of another user. If you wish to receive information relating to another user, such as a copy of any messages you received from him or her through our service, the other user will have to contact our Privacy Officer to provide their written consent before the information is released. Also, we may not be able to accommodate certain requests to object to the processing of personal information, notably where such requests would not allow us to provide our service to you anymore. For instance, we cannot provide our service if we do not have your date of birth. In certain countries, including in the European Union, you have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how we process your personal information. The data protection authority you can lodge a complaint with notably may be that of your habitual residence, where you work or where we are established.

09 Residents of California

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

10 How we protect your information

We work hard to protect you from unauthorized access to or alteration, disclosure or destruction of your personal information. As with all technology companies, although we take steps to secure your information, we do not promise, and you should not expect, that your personal information will always remain secure. We regularly monitor our systems for possible vulnerabilities and attacks and regularly review our information collection, storage and processing practices to update our physical, technical and organizational security measures. We may suspend your use of all or part of the services without notice if we suspect or detect any breach of security. If you believe that your account or information is no longer secure, please notify us immediately.

11 How long we retain your information

We keep your personal information only as long as we need it for legitimate business purposes (as laid out in Section 5) and as permitted by applicable law. To protect the safety and security of our users on and off our services, we implement a safety retention window of three months following account deletion. During this period, account information will be retained although the account will of course not be visible on the services anymore. In practice, we delete or anonymize your information upon deletion of your account (following the safety retention window) or after two years of continuous inactivity, unless:

• we must keep it to comply with applicable law (for instance, some “traffic data” is kept for one year to comply with statutory data retention obligations);
• we must keep it to evidence our compliance with applicable law (for instance, records of consents to our Terms, Privacy Policy and other similar consents are kept for five years);
• there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or
• the information must be kept for our legitimate business interests, such as fraud prevention and enhancing users' safety and security. For example, information may need to be kept to prevent a user who was banned for unsafe behavior or security incidents from opening a new account.

Keep in mind that even though our systems are designed to carry out data deletion processes according to the above guidelines, we cannot promise that all data will be deleted within a specific timeframe due to technical constraints.

12 Children's privacy

Our services are restricted to users who are 15 years of age or older. We do not permit users under the age of 15 on our platform and we do not knowingly collect personal information from anyone under the age of 15. If you suspect that a user is under the age of 15, please use the reporting mechanism available through the service.
In all aspects, RELUVOTION is dedicated and makes all efforts to comply with the provisions of the GDRP, COPPA, Privacy Rights for California Minors in the Digital World, and any other relevant regulations for data collected on those under 18 years of age.
In the case where the user is aged under 16, we can and will permit collection of data, only with permission from parent or guardian, to which the user must attest when signing up. RELUVOTION uses all reasonable efforts to verify that the minor is either of the age of consent or that if under the age of consent that a parent gave that consent, and it was really the parent that consented. Furthermore, for those users under 16 years of age, their data will never be subject to automated data processing or profiling.
In the event that we learn that we have collected personal information from a child under 16, without parental consent, we will delete that information as quickly as possible.

13 Privacy policy changes

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

14 General data protection

This Privacy Policy provides mandatory information as required under Articles 13 and 14 of the European General Data Protection Regulation (GDPR) regarding the transparency of personal data processing. Chapter 3 of the GDPR, each personal data of identifiable natural person has eight rights. These are:

1. The right to be informed; This means anyone processing your personal data must make clear what they are processing, why, and who else the data may be passed to.
2. The right of access; this is your right to see what data is held about you by a Data Controller.
3. The right to rectification; the right to have your data corrected or amended if what is held is incorrect in some way.
4. The right to erasure; under certain circumstances you can ask for your personal data to be deleted. This is also called ‘the Right to be Forgotten’. This would apply if the personal data is no longer required for the purposes it was collected for, or your consent for the processing of that data has been withdrawn, or the personal data has been unlawfully processed.
5. The right to restrict processing; this gives the Data Subject the right to ask for a temporary halt to processing of personal data, such as in the case where a dispute or legal case has to be concluded, or the data is being corrected.
6. The right to data portability; a Data Subject has the right to ask for any data supplied directly to the Data Controller by him or her, to be provided in a structured, commonly used, and machinereadable format.
7. The right to object; the Data Subject has the right to object to further processing of their data which is inconsistent with the primary purpose for which it was collected, including profiling, automation, and direct marketing.
8. Rights in relation to automated decision making and profiling; Data Subjects have the right not to be subject to a decision based solely on automated processing.

This privacy policy makes good faith effort to comply with all the above rights to the full extent possible. The identity and contact detail for the Data Protection Officer within RELUVOTION is: DSU RELUVOTION, LLC
2027 VILLAGE LANE, SUITE 203
SOLVANG CA 93463 HOW TO CONTACT US If you have questions about this Privacy Policy, here’s how you can reach us: If you live in the European Union, the company that is responsible for your information under this Privacy Policy (the “data controller”) is: DSU RELUVOTION, LLC
2027 VILLAGE LANE, SUITE 203
SOLVANG CA 93463 If you live outside the European Union, the company responsible for your information is: DSU RELUVOTION, LLC
2027 VILLAGE LANE, SUITE 203
SOLVANG CA 93463