Privacy Policy

Account Data

When you create an account, you give us basic information for your account to be set up such as your phone number, email address, and date of birth.

Profile Data

When you complete your profile, you share additional details about you, such as your gender, interests, preferences, approximate location, etc. Some of this data may be considered sensitive or special in certain countries, such as details about sexual orientation, sexual life, health, racial or ethnic origins, religious beliefs or political affiliations. If you choose to provide this data, you consent to us using it as laid out in this Privacy Policy.

Content

When you use our service, you may post photos, videos, audio, text and other types of content, such as your chats with other members.

Purchase Data

When you make a purchase, we keep the details of the transaction (e.g. what you purchased, the date of the transaction, and the price). The exact data depends on the payment method you choose. When you pay directly with us (rather than through a platform such as iOS or Android), you provide your debit or credit card number or other financial info.

Marketing, Survey and Research Data

We sometimes run (i) surveys, focus groups, or market studies for research purposes and (ii) promotions, events or contests for marketing purposes. When you choose to participate, you give us information to process your entry and participation, as well as your responses to our questions and your feedback.

Third-Party Data

When you choose to share with us information about other people (for example, if you use the contact details of someone you know for a given feature or if you submit a query or report involving a member), we process this data on your behalf to complete your request.

Customer Support Data

When you contact us, you provide us with information that may be necessary to help address your enquiry. Other people may also submit queries or reports involving you. Finally, our moderation tools and teams can collect additional data as part of their investigations. Further, we are part of the Let's Be Social Inc. family of businesses. Let's Be Social Inc. considers the safety and security of members a top priority. If you were banned from another Let's Be Social Inc. service, your data may be shared with us to allow us to take necessary actions, including closing your account or preventing you from creating an account on our service.

Where legally allowed, we can also receive information about suspected or convicted bad actors from third parties as part of our efforts to ensure our members’ safety and security.

Usage Data

Using the service generates data about your activity, including how you use it (e.g., when you logged in, features you’ve been using, actions taken, information shown to you, referring webpages, ads you interacted with) and how you interact with others (e.g., searching, matching, communicating). We may also receive data related to interactions you had with our ads on third party’s websites or apps.

Technical Data

Using the service involves the collection of data from and about the device(s) you use to access our service, including hardware and software information such as IP address, device ID and type, apps settings and characteristics, app crashes, advertising IDs and identifiers associated with cookies or other technologies that may uniquely identify a device or browser. For more information about cookies, see our Cookie Policy.

Geolocation Data

If you give us permission, we can collect your geolocation (latitude and longitude) from your device. If you decline permission, features that rely on precise geolocation may not be available to you.

Face Geometry Data

You may choose to participate in certain of our features, like Selfie Verification, that involve the collection of face geometry data, which may be considered biometric data in some jurisdictions. Learn more here about our verification feature and how we process your face geometry data.

ID Data

You may provide us with a copy of your government-issued ID to help us check that you’re who you say you are.

To enable you to use our service, including:

• Creating and maintaining your account and profile on our service
• Operating and maintaining the various features on our service
• Recommending other members to you and recommending you to them
• Organizing sweepstakes and contests
• Responding to your requests and questions
• Monitoring the well functioning of our service and troubleshooting and fixing issues as needed

• Performance of our contract with you
• Your consent (where sensitive data or other type of data that requires consent is processed)

• Account Data
• Profile Data
• Content
• Purchase Data
• Marketing, Survey and Research Data
• Third Party Data
• Customer Support Data
• Social Media Data
• Usage Data
• Technical Data
• Geolocation Data

To enable your purchases on our service, including:

• Processing payments
• Offering discounts and promotions, customizing prices

• Performance of our contract with you

• Account Data
• Profile Data
• Technical Data
• Purchase Data
• Usage Data

To operate advertising and marketing campaigns, including:

• Performing and measuring the effectiveness of advertising campaigns run on our service
• Performing and measuring the effectiveness of marketing campaigns promoting our own service on third-party platforms
• Communicating with you about products and services we believe may interest you

• Consent (where required under applicable law) and otherwise our legitimate interest. It is in our legitimate interest to promote our service and to show ads to our members which are tailored to their interests, as a way to improve their experience and help fund the parts of our service which are free

• Account Data
• Profile Data
• Usage Data
• Marketing, Survey and Research Data
• Technical Data

To improve our service and create new features and services, including:

• Running focus groups, market studies and surveys
• Analyzing how our service is used
• Reviewing interactions with customer care teams to improve service quality
• Developing and improving new features and services, including through machine learning and other technologies, and testing them out
• Conducting research and publishing research papers

• Performance of our contract with you
• Our legitimate interest: It is in our legitimate interest to improve our service over time
• Consent where required under applicable law (e.g., we may process data deemed sensitive or special in certain countries to help make sure that the various communities using our service are being treated fairly and equitably and that our service remains diverse and inclusive)

• Account Data
• Profile Data
• Content
• Purchase Data
• Marketing, Survey and Research Data
• Third Party Data
• Customer Support Data
• Social Media Data
• Usage Data
• Technical Data

To keep you and other members safe on our service and across Let's Be Social Inc., including:

• Preventing, detecting and fighting against violations of our Terms, fraud and other illegal or unauthorized activities
• Developing and improving tools to prevent, detect and fight against violations of our Terms, fraud and other illegal or unauthorized activities
• Preventing recurrences, notably by preventing individuals who violate our Terms from creating a new account
• Letting individuals who submit a report know what we’ve done about it
• Verifying your identity
• Securing payments and fighting against financial fraud

For more information on safety, integrity and security generally, visit our Safety Tips and Community Guidelines.

• Performance of our contract with you
• Our legitimate interest: It is in our legitimate interest and that of our members to keep them safe
• Protection of your vital interests and that of other members
• Compliance with legal obligations that apply to us such as taking down illicit content
• Your consent (where sensitive data or other type of data that requires consent is processed)

• Account Data
• Profile Data
• Content
• Purchase Data
• Third Party Data
• Customer Support Data
• Usage Data
• Technical Data
• Face Geometry Data
• ID Data

To comply with applicable law, establish, exercise and defend legal claims & rights, including:

• Preserving data to comply – and evidence compliance – with applicable law
• Supporting investigations and defending potential or ongoing litigation, regulatory action or dispute
• Responding to lawful requests from law enforcement, courts, regulators, and other third parties
• Reporting illegal or infringing content to law enforcement, government or other authorities
• Establishing, exercising, or defending ongoing or threatened claims
• Sharing data with law enforcement or partners to combat abusive or illegal behavior

• Our legitimate interest: It is in our legitimate interest to comply with applicable law and protect ourselves, our members and others, including as part of investigations, legal proceedings and other disputes
• Protection of your vital interests and that of other members
• Compliance with legal obligations applying to us such as responding to law enforcement requests for information

None

Other members

You share data with other members when you voluntarily disclose information on the service for others to see (e.g., your public profile).

If someone submits a report involving you (such as a claim you violated our Terms of Use), we may let the reporter know what actions we took, if any, as a result of their report. The same applies if you submit a report involving another member.

• Profile Data
• Content
• Social Media Data
• Third Party Data
• Customer Support Data

Service providers/partners

We share data with vendors and partners who help us operate, promote and improve our service. They provide us services such as data hosting and maintenance, analytics, customer care, marketing, advertising, payment processing, legal support, and security operations.

Depending on the service provided by the vendor or partner, it may include:

• Account Data
• Profile Data
• Content
• Purchase Data
• Marketing, Survey and Research Data
• Third Party Data
• Customer Support Data
• Social Media Data
• Usage Data
• Technical Data
• Geolocation Data
• Face Geometry Data
• ID Data

Advertising Partners

We may publish ads about third-party advertisers’ products and services on our service, and publish ads promoting our own service on third-party sites and apps. To help improve the relevance of these ads, we provide certain info about you to third parties, including advertising partners, or allow them to collect such data from our services (such as via cookies, SDKs, or similar technologies). Some of our advertising partners enable us to transform your email address, advertising identifiers or phone number into an identifier that can’t be used to identify you personally and then use that unique identifier to either exclude you from our marketing campaigns, or to target our ads at an audience that is similar to you in terms of background, interests or app usage.

If you live in the United States, some of the activities described in this section may constitute “targeted advertising,” “sharing,” or “selling” under applicable laws. You have the right to opt-out, as described in Section 8.

• Account Data
• Profile Data
• Usage Data
• Technical Data

Affiliates

We may share data with affiliates or receive data from them for the purposes laid out in Section 6 of this policy.

The categories of data will vary based on the reason for sharing, but it may include:

• Account Data
• Profile Data
• Content
• Purchase Data
• Marketing, Survey and Research Data
• Third Party Data
• Customer Support Data
• Social Media Data
• Usage Data
• Technical Data
• Geolocation Data
• Face Geometry Data
• ID Data

Law enforcement authorities

We may disclose your data to: (i) comply with a legal process, such as a court order, subpoena or search warrant, government / law enforcement investigation or other legal requirements; (ii) assist in the prevention or detection of crime; (iii) protect the safety of any person; and (iv) establish, exercise or defend legal claims.

The categories of data shared will vary depending on the specific circumstances surrounding the request, but it often can include:

• Account data
• Profile Data
• Content
• Purchase Data
• Customer Support Data
• Third Party Data
• Social Media Data
• Usage Data
• Technical Data
• Geolocation Data
• ID Data

In the context of merger and acquisition, with our Affiliates or new owner(s)

We may transfer your data 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.

The categories of data shared will vary based on the type of corporate transaction. It may include the entire organization data or only a specific subset such as Purchase Data.

Your Rights

How to exercise it

Access, Portability or To Know

Right to be informed of the personal data we process about you and/or ask for a copy of it

You can access and review some data directly by logging into your account. You can also retrieve a copy of your data by emailing us at datarequest@welovetrust.com.

Rectification or Correction

Right to amend or update your personal data where it’s inaccurate or incomplete

You can update your data directly within the service by simply updating your profile. If you wish to rectify other data, please contact us at datarequest@welovetrust.com.

Deletion or Erasure

Right to delete personal data

You can delete some of the data you provided us directly within the service. You can also close your account by going to your Profile in the TRUST app and choosing Delete Account and we’ll delete your data as laid out in this Privacy Policy. In any event, you can always contact us at datarequest@welovetrust.com.

Objection (Opt-out) or Restriction

Right to object to us processing personal data or to request that we temporarily or permanently stop processing personal data

You can directly opt-out from certain of your personal data processing in your account settings. Otherwise you can contact us at datarequest@welovetrust.com should you wish to object to or restrict a data processing we’ve listed throughout this Privacy Policy.

Consent Withdrawal

Right to withdraw a consent you’ve given us to process your personal data for a specific purpose

You can directly withdraw consent you’ve given us either by updating your account setting or removing Device Permissions you’ve agreed to in your device settings (e.g., access to specific types of device data such as phone contacts, pictures, advertising identifiers and location services or consent to receive push notifications). When you withdraw consent, certain services may lose functionality. You can always please contact us at datarequest@welovetrust.com for more information.

Opt-out of Targeted Advertising, “Sales” and “Sharing”

If you live in the United States, you may opt out of activities that may fall under the legal definitions of “targeted advertising,” “sales,” or “sharing” under applicable laws

To opt out, please visit the “Your Privacy Choices” link in the footer of our website and in the Settings menu of the app and adjust the “Sale or Sharing of Personal Information” toggle accordingly. Authorized agents may submit opt-out requests on behalf of consumers here.