Endorsed by: Rav Shmuel Fuerst Shlita and Rav Aaron Lopiansky Shlita

Privacy Statement for www.Zuug.com and the Zugg App U.S.A only

Zuug Inc. ("Zuug") has created this Privacy Statement (Policy) in order to demonstrate our firm commitment to helping our users better understand what information we collect about them and what may happen to that information. The following discloses our information gathering and dissemination practices for the Websites and apps.

Overview

As part of the normal operation of our services we collect and, in some cases, may disclose information about you. This Privacy Statement describes the information we collect about you and what may happen to that information. By accepting this Privacy Statement and our Terms and Conditions, you expressly consent to our use and disclosure of your personal information in the manner prescribed in this Privacy Statement. This Privacy Statement is incorporated into and subject to the terms of the Zuug Terms and Conditions.

1. A Special Note About Children

Children are not eligible to use our services, and we ask that minors (under the age of 18) do not submit any personal information to us. If you are a minor, you can use this service only in conjunction with your parents or guardians.

2. Information We Collect

Our primary goal in collecting personal information is to provide you with a smooth, efficient, and customized experience. This allows us to provide services and features that most likely meet your needs and to customize our service to make your experience easier. Your profile may be available for other members and matchmakers to view. Profiles include a description and photos, likes and dislikes, individual essays and other information helpful in determining matches. We do not disclose your email address, nor do we sell it or make it available to any third party other than as outlined in more detail in this Privacy Statement.

We automatically track certain information based upon your behavior on our Websites and apps using cookies and other devices. We use this information for internal research on our members' demographics, interests, and behavior to better understand and serve you and our community. This information may include the URL that you just came from (whether this URL is on our site or not). Which URL you next go to (whether this URL is on our site or not), what browser you are using, and your IP address.

We use data collection devices such as "cookies" on certain pages of Zuug . "Cookies" are small files placed on your hard drive that assist us in providing customized services. We also offer certain features that are only available through the use of a "cookie". Cookies can also help us provide information which is targeted to your interests.

Collection of Information

Registration Information

When you download the App and create an account (“Account”), we may collect certain information (“Registration Information”) about you, such as, but not limited to:

  • Name
  • Username
  • Email address
  • Mobile number
  • Gender identity
  • Date of birth
  • Photographs
  • Location; and
  • Login information for social media accounts that you connect (this could include, for example, your Facebook account).

Once you register, you will be able to review and change this information at any time just by logging in to our sites (other than your date of birth and location (which, if you have given us access to your location in your device settings, is automatically updated based on the location of your device)). It is your responsibility to ensure that your account details are kept up to date. If your phone number changes, please ensure that you update this in your account.

For Users who are California residents, the data we may collect falls within the following categories of “personal information”, as defined by the California Consumer Privacy Act (CCPA):

  • Identifiers, such as name and location
  • Personal information, such as contact (including email and telephone number) and financial information
  • Characteristics of protected classifications (if you choose to provide them), such as age, gender identity, marital status, race, ancestry, national origin, religion, and medical conditions
  • Commercial information, such as transaction information and purchase history
  • Biometric information
  • Internet or network activity information, such as browsing history and interactions with our Sites and App
  • Geolocation data, such as mobile device location
  • Audio, electronic, visual and similar information, such as photos and videos
  • Professional or employment-related information, such as work history and prior employer
  • Non-public education information; and
  • Inferences drawn from any of the personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics

Profile Information

We recommend and encourage you (and all our members) to think carefully about the information you disclose about yourself.

Profile Verification Information (Including Biometric Information)

For safety and security and to ensure you have the best possible user experience, we require Users to verify their accounts and might ask for your phone number and, in some instances, we might also ask that you carry out photo verification. We want to make sure you are not a robot! And we also want to avoid fake accounts being created which can be used for malicious activities and cybercrime – they threaten our network and spoil things for everyone. This verification might be required by us for the prevention of fraud. You can also verify your photo on a voluntary basis (to add the blue ‘verified’ badge to your profile).

If you choose to verify your profile photo, we will scan each photo that you submit. The scan may include the use of facial recognition technology so that we can compare the photo you submit to your profile photo, to help ensure that you are who you say you are. We do not add the verification photos to your profile. We retain the scans so that we can verify you in the future and for our record-keeping purposes until we no longer need them for such purposes or for three years after your last interaction with us, whichever occurs first. After the applicable retention period expires, we take commercially reasonable steps to permanently and securely delete the scans from our systems.

Purchases Information

For safety and security and to ensure you have the best possible user experience, we require Users to verify their accounts and might ask for your phone number and, in some instances, we might also ask that you carry out photo verification. We want to make sure you are not a robot! And we also want to avoid fake accounts being created which can be used for malicious activities and cybercrime – they threaten our network and spoil things for everyone. This verification might be required by us for the prevention of fraud. You can also verify your photo on a voluntary basis.

Purchases Information

If there are any charges for services, we will process your payment information and retain this securely for the prevention of fraud and for audit/tax purposes.

Zuug uses automated decisions to prevent fraudulent payment transactions being processed as part of its anti-fraud procedures. In order to do this, our systems check payment transactions for behavior that indicates breaches of our Terms and Conditions of Use. If a transaction meets certain criteria that demonstrate that the Terms and Conditions of Use are likely to have been breached and the transaction is likely to be fraudulent, the relevant transaction may automatically be blocked. When a transaction is blocked, the user will be notified that their transaction cannot be processed and affected Users can contact our customer support to contest the decision.

Please note that if your account is blocked for any reason, any account(s) that you have on other sites/platforms/applications that belong to us, may also be blocked as part of our anti-spam and anti-fraud procedures.

Geolocation Information for Using Our Apps

If you have given us access to your location in your device settings, we will collect information about WiFi access points as well as other location information about your longitude and latitude and may save your device’s coordinates to offer certain features to you. This information helps us identify your physical location and we use it to personalize Services and make it easier for you to interact with other Users, by enabling the general locality information to be displayed to Users seeing your profile and showing you the profiles of other Users who are near you.

If you have given us access to your location, but wish to turn this off, you can do so by the following methods:

  • iPhone app — settings, privacy, location services, Name of the app you downloadeded
  • Android — settings, location, Name of the app you downloaded, permissions, location

Device Information

We may collect information about your device when you use our services including the unique device identifier, device model, and operating system, for a number of purposes, as set out in this policy. In addition, if you permit us to do so, we may access your device’s address book solely in order to add someone to your contacts.

Links

We may keep track of how you interact with links available on our sites including third party services by redirecting clicks or through other means. We may share aggregate click statistics such as how many times a particular link was clicked on.

Messages

We review the content of messages sent on sites or apps to identify topics, sentiments, and trends across our Users. We will not share the content of User messages or information we derive from them with any third party.

Success Stories, Surveys, and Other Contributions

From time to time, we run surveys for research purposes and we may contact you to find out if you would like to take part. We may also contact you to find out if you would like to provide feedback, a testimonial or take part in marketing campaigns (for example, if you let us know that you have found a match, we may contact you to ask if you would be happy to feature in advertising). Such surveys and marketing campaigns are optional and more information will be provided at the point of contact. If you do not wish to be contacted to take part in a survey or marketing campaign, please contact our Customer Support Team.

When You Contact Customer Support

If you contact our Customer Support team via our Form, we will receive your email address, and may track your IP address, as well as the information you send to us to help resolve your query. We will keep records of our communications with you, including any complaints that we receive from you about other Users (and from other Users about you) for 5 years after deletion of your account.

3. Our Use of Your Information

We use information in the files we maintain about you, and the other information we obtain from your current and past activities on Zuug to resolve disputes, troubleshoot problems and enforce our Terms and Conditions. At times, we may look across multiple members to identify problems or resolve disputes, and in particular we may examine your information to identify members multiple usernames or aliases.

You agree that we may use personally identifiable information about you to improve our marketing and promotional efforts, to analyze site usage, improve our content and product offerings, and customize our Site's content, layout, and services. These uses improve our site and better tailor it to meet your needs.

You agree that we may use your information to contact you and deliver information to you that, in some cases, are targeted to your interests, such as targeted banner advertisements, administrative notices, product offerings, and communications relevant to your use. By accepting this Privacy Statement, you expressly agree to receive this information. If you do not wish to receive these communications, we encourage you to opt out of the receipt of certain communications by email us at support@Zuug.com.

How We Use Your Data

We only collect and store data about you that we feel is absolutely necessary. We require this information to understand your needs and provide you with a better service, and in particular, but not limited to, the following reasons:

  • Deliver the products and services that you have requested so you can meet your dating goals
  • Manage your account and provide you with customer support
  • Perform research and analysis about your use of, or interest in, our services, or content
  • Communicate with you by e-mail, and/ or mobile devices about services that may be of interest to you either from us, or our other companies or third parties
  • To detect and prevent fraudulent activity on our sites and applications. We use data from all members with an internally developed fraud detection system in order to detect and eliminate bad actors from our service
  • Develop and display content and advertising tailored to your interests on our site as well as offers to join trusted partner dating sites quickly and easily through cross-registration
  • To be sure we are compliant with all legal requirements in all our operating jurisdictions and enforce our terms and conditions. This includes providing law enforcement with information they officially request from our records
  • To improve our products and services in general so you have the best possible chance to find a perfect match
  • Offer you our services and features
  • Contact you with information about the App (e.g., updates and new features)
  • Personalize the App/Sites and the content we deliver to you
  • Conduct research and analytics about how you use and interact with the App/Sites
  • To test new technologies and processes designed to enhance and improve the App/Sites
  • Resolve disputes, troubleshoot problems and to enforce our Terms & Conditions
  • Investigate fraud, protect our legal rights, and to enforce our Terms & Conditions
  • o send you information about the promotions and offers we have available (e.g., specify the types of goods/services/offers to be provided via direct marketing) by direct marketing or other modes of communication - if you’ve signed up for our communications or otherwise told us it’s OK. We will not use your information in email direct marketing unless you give us your consent during the Account creating process or via Settings in the App (you can withdraw from marketing at any time via Settings in the App or by using the opt-out mechanisms and links provided in each message); and
  • Protect our Users and third parties from harm

IMPORTANT: Your username will be associated with all activities you undertake on the Site including, without limitation, messages sent and other content or information you may determine to post or share. Your gender information helps other users find you. Your IP addresses, device data, and other use information are used by us in order to optimize our site for use. Your usage history may also be used to help our internal algorithm to recommend other Site users to you.

4. Our Disclosure of Your Information

Due to the existing regulatory environment, we cannot ensure that all of your private communications and other personally identifiable information will never be disclosed in ways not otherwise described in this Privacy Statement. By way of example (without limiting and foregoing), we may be forced to disclose information to the government, law enforcement agencies or third parties under certain circumstances, third parties may unlawfully intercept or access transmissions or private communications, or members or/and matchmakers may abuse or misuse your information that they collect from Zuug . Therefore, although we use industry standard practices to protect your privacy, we do not promise, and you should not expect, that your personally identifiable information or private communications will always remain private. Financial Information. Under some circumstances we may require some additional information, such as, but not limited to credit card details. We use this financial information, including your name, address, and other information, as well as to bill you for use of our services. We use your financial information to check your qualifications, to bill you for services and/or products, to enable you to participate in discount, rebate and similar programs in which you may elect to participate. By making a purchase, or engaging in any other kind of activity or transaction that uses financial information, on the Websites, you consent to our providing of your financial information to our service providers and to such third parties as we determine are necessary to support and process your activities and transactions, as well as to your credit card issuer for their purposes. These third parties may include the credit card companies and banking institutions used to process and support the transaction or activity. By purchasing, registering, or making reservations for, products or services of third parties offered on Zuug , or by participating in programs offered on Zuug that are administered by third parties and that require you to submit financial information in order to use them, you also consent to our providing your financial information to those third parties. Any of these various third parties may be authorized to use your financial 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, and you agree that we are not responsible or liable for any of their actions or omissions. Additionally, you agree that we may use and disclose all such information submitted to such third parties in the same manner in which we are entitled to use and disclose any other information that you submit to us.

Advertisers

We may allow advertisers on our website and/or app. The advertising companies may employ cookies and action tags (also known as single pixel gifs or web beacons) to measure advertising effectiveness. Any information that these third parties collect via cookies and action tags is completely anonymous.

External Service Providers

There may be a number of services offered by external service providers that help you use Zuug . If you choose to use these optional services, and in the course of doing so, disclose information to the external service providers, and/or grant them permission to collect information about you, then their use of your information is governed by their private policy.

Other Corporate Entities

We may share much of our data, including personally identifiable information about you, with any affiliates, subsidiaries and joint ventures that are committed to serving your online needs and related services, throughout the world. To the extent that these entities have access to your information, they will treat it at least as protectively as they treat information they obtain from their other sources. It is possible that Zuug , it's subsidiaries, joint ventures, or any combination of such, could merge with or be acquired by another business entity. Should such a combination occur, you should expect that Zuug would share some or all of your information in order to continue to provide the service. You will receive notice of such event (to the extent it occurs) and we will require that the new combined entity follow the practices disclosed in this Privacy Statement.

Legal Requests

Zuug cooperates with law enforcement inquiries, as well as other third parties to enforce laws, such as: intellectual property rights, fraud and other rights. We can (and you authorize us to) disclose any information about you to law enforcement and other government officials as we, in our sole discretion, believe necessary or appropriate, in connection with an investigation of fraud, intellectual property infringements, or other activity that is illegal or may expose us or you to legal liability.

How We Share Data and Information with Other Partners, Including Third Parties

First and foremost, by creating your profile and sharing information about yourself, you are in turn sharing that information with other users on the Site and you allow us to share that information with other users on the Site. As we cannot control what other users do with the data you share, please only add information to your profile that you are comfortable sharing with the public. In your Contact Preferences on the Site, you will find options to limit which members can and cannot send you messages.

  • Sensitive personal data like your supplied gender will help other users find you.
  • Sometimes it is necessary to share data with trusted third-party service providers and vendors to provide you better services. Some examples of this would be our payment service providers, in order to facilitate payments for Premium access, and our email validation service, which lets us know if you provided us with a valid email address. We will never sell your personal data to a third party under any circumstances. We take much care in ensuring that our few data partners follow best practices for safeguarding data, and encourage you to reach out to our customer team if you have any questions regarding this.
  • In some cases, we make your profile visible on other brands within our network of applications (our Community). These are simply brand extensions of the Site, with the same database of users on each of these other websites and applications.
  • We use internal service providers which sometimes pass your account data. Some examples of this would be our internal fraud detection system, which helps to eliminate bad actors on our network of websites and applications, and our internal ad serving system, which uses your demographic and interest data to show you relevant advertisements on the service. We also send anonymized data (encrypted email addresses) to our ad server to provide you better services and more options in finding your perfect match. In all these cases, this data is completely retained within the company and safeguarded with the same high level of care your data is on the Site.
  • If we are ever involved in a merger or sale, control of your data may transfer to a new company or website. This will be fully disclosed to you in advance if this situation occurs. You will be notified via email.
  • We reserve the right to share any and all account information with law enforcement or agencies authorized by applicable governmental authorities either in response to their written request or at our own election should we believe, in our sole discretion, that you or your account may be involved with illegal activity, or if we believe, in our sole discretion, that such disclosure is necessary to protect the rights or property of the Site, our users, and/or one or more third parties.
  • Sometimes, it may become necessary to share data if that disclosure could mitigate our liability in a lawsuit, either filed or threatened. This could also happen if we need to protect the legal rights of either ourselves or of our users, or to investigate or take action regarding perceived illegal activity or fraud.

5. Your Use of Other Members’ Information

By accepting this Privacy Statement, you agree that, with respect to other members' and matchmaker's personally identifiable information that you obtain through communication and the use of Zuug , Zuug hereby grants to you a license to use such information only for: (a) Zuug related communications that are not unsolicited commercial messages, and (b) any other purpose that such matchmaker or member expressly agrees to after adequate disclosure of the purpose(s). In all cases, you must give matchmakers or members an opportunity to remove themselves from your database and a chance to review what information you have collected about them. In addition, under no circumstances, except as defined in this Section, can you disclose personally identifiable information about another matchmaker or member to any third party without our consent and the consent of such other member after adequate disclosure. Zuug does not tolerate spam. Therefore, without limiting the foregoing, you are not licensed to add a matchmaker or member, to your mail list (email or physical mail) without their express written consent after adequate disclosure. To report spam from other Zuug users, please email support@Zuug.com.

6. Accessing, Reviewing, and Changing Your Profile

Following registration, you can review and change the information you submitted during registration. You can also change your registration information such as: address, city, state, zip code, country, phone number, profile, likes and dislikes, essays and search criteria. Upon your written request, we will suspend your data from our active databases. Such information will be suspended as soon as reasonably possible in accordance with our suspension policy and applicable law.

We will retain our files information you have requested to remove in order in some circumstances, such as to resolve disputes, troubleshoot problems and enforce our terms and conditions. Further, such prior information is never completely removed from our databases due to technical and legal constraints, including stored 'back up' systems. Therefore, you should not expect that all of your personally identifiable information will be completely removed from our databases in response to your requests. All member’s information, including private one, can be updated or deleted by the member at any time.

7. Control of Your Password

You are responsible for all actions taken with your username and password, including fees. Therefore we do not recommend that you disclose your Zuug password or username to any third parties. If you choose to share your username and password or your information with third parties to provide you additional services, you are responsible for all actions taken with your username and password and therefore should review that third party's Privacy Statement. If you lose control of your password, you may lose substantial control over your personally identifiable information and may be subject to legally binding actions taken on your behalf. Therefore, if your password has been compromised for any reason, you should immediately change your password.

8. Other Information Collectors

Except as otherwise expressly included in this Privacy Statement, this document only addresses the use and disclosure of information we collect from you. To the extent that you disclose your information to other parties, whether they are on Zuug or on other sites throughout the Internet, different rules may apply to their use or disclosure of the information you disclose to them. To the extent that we use third party advertisers, they adhere to their own privacy policies. Since Zuug does not control the privacy policies of the third parties, you are subject to ask questions before you disclose your personal information to others.

9. Security

Zuug uses industry standard practices to safeguard the confidentiality of your personal identifiable information. Zuug treats data as an asset that must be protected against loss and unauthorized access. We employ many different security techniques to protect such data from unauthorized access by members inside and outside the company. However, "perfect security" does not exist on the Internet.

10. Notice

We may change this Privacy Statement from time to time based on your comments and our need to accurately reflect our data collection and disclosure practices. All changes to this policy are effective after we provide you with at least (30) days' notice of changes. We provide you with (30) days' notice to allow you the opportunity to notify Zuug if you do not agree to such changes.

Updated 12/26/2024