Privacy Policy
Last Revised: December 31, 2023
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Protecting your privacy is a serious matter and doing so is very important to us. Please read this Privacy Policy (the “Policy") to learn more about our Privacy Policy. This Privacy Policy (the “Policy”) describes the privacy practices applicable to your use of platforms, tools, and services including application software and sites under the hunchdating.com domain (collectively, the “Platform”) which is offered by Hunch Social, LLC (the “Company”, “our”, “we”). This Policy explains how personal data about you may be collected, used, and disclosed by us, and certain rights and choices you may have regarding your personal data. By using our Platform, you agree to the practices set forth in this Privacy Policy.
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1. Information Collection
Information you give us
You choose to give us certain information when using our services. This includes:
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When you create an account, you provide us with at least your email address and a password selected by you, as well as some basic details necessary for the Platform to work, such as your name, gender, date of birth, sexual orientation, who you’d like to connect with, and geolocation data (latitude and longitude). Where you provide such elements to us, you consent to us using it for the purposes identified and as laid out in this Privacy Policy.
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When you complete your profile, you share additional information with us, such as details on your bio as well as content such as photos and videos. To add certain content, like photos or videos, you may allow us to access your camera or photo album. Additionally, when you upload certain content, we use biometrics tracking technologies by allowing third parties to use this data to determine whether your uploaded content include face(s) and/or other impermissible features.
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When you subscribe to a paid service or make a purchase directly from us (rather than through a platform such as iOS or Android), you provide us with information related to the purchases you make and our payment processors with information such as your debit or credit card number or other financial information.
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When you participate in surveys, focus groups or market studies, you give us your insights into our products and services, responses to our questions and testimonials.
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When you choose to participate in our promotions, events or contests, we collect the information that you use to register or enter.
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If you contact our customer care team, we collect the information you give us during the interaction.
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If you share with us information about other people (for example, if you use contact details of a friend for a given feature), we process this information on your behalf in order to complete your request.
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Of course, we also process your chats with other members as well as the content you publish to operate and secure the services, and to keep our community safe.
Information we receive from others
In addition to the information you may provide us directly, we receive information about you from others, including:
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Members: Members may provide information about you as they use our services, for instance as they interact with you or if they submit a report involving you.
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Social Media: You may decide to share information with us through your social media account, for instance if you decide to create and log into your account via your social media or other account (e.g., Facebook, Google or Apple) or to upload onto our services information such as photos from one of your social media accounts (e.g., Instagram or Spotify).
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Other Partners: We may receive information about you from our partners where our ads are published on a partner’s service (in which case they may pass along details on a campaign’s success). 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.
Information generated or automatically collected when you use our services
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When you use our services, this generates technical data 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.
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Usage Information: Using the services generates data about your activity on our services, for instance how you use them (e.g., when you logged in, features you’ve been using, actions taken, information shown to you, referring webpages address and ads that you interacted with) and your interactions with other members (e.g., members you connect and interact with, and when you matched and exchanged messages with them).
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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, apps settings and characteristics, app crashes, advertising IDs (which are randomly generated numbers that you can reset by going into your device’ settings and, in some cases, disable entirely), and identifiers associated with cookies or other technologies that may uniquely identify a device or browser.
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Information collected by cookies and similar technologies: We use and may allow others to use cookies and similar technologies (e.g., web beacons, pixels, SDKs) to recognize you and/or your device(s).
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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 ours, do not currently respond to DNT signals.
2. How We Use Information
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The main reason we use your information is to deliver and improve our services. Additionally, we use your info to help keep you and our community safe, and to provide you with advertising that may be of interest to you. Read on for a more detailed explanation of the various reasons for which we use your information, together with practical examples.
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A. To administer your account and provide our services to you
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Create and manage your account
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Provide you with customer support and respond to your requests
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Communicate with you about our services
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Personalize pricing, offer discounts and other promotions, and complete your transactions
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Administer sweepstakes and contests
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B. To help you connect with other users
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Recommend you to other members and recommend other members to you
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Show members’ profiles to one another
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Enable members to search for and connect with members
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C. To provide offers and operate advertising and marketing campaigns
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Perform and measure the effectiveness of advertising campaigns on our services and marketing our services off our platform
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Communicate with you about products or services that we believe may interest you
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D. To improve our services and develop new ones
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Administer focus groups, market studies and surveys
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Review interactions with customer care teams to improve our quality of service
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Understand how members typically use the services to improve them (for instance, we may decide to change the look and feel or even substantially modify a given feature based on how members react to it)
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Develop new features and services
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E. To prevent, detect and fight fraud and other illegal or unauthorized activities
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Find and address ongoing, suspected or alleged violations of our Terms of Use, notably through the review of reports and interactions between members
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Better understand and design countermeasures against violations of our Terms of Use
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Retain data related to violations of our Terms of Use to address the violation and prevent against recurrences
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Enforce or exercise our rights, for example our rights set out in our Terms of Use
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Communicate to individuals who submit a report, including what we’ve done as a result of their submission
F. To ensure legal compliance
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Comply with legal requirements
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Assist law enforcement
To process your information as described in this Privacy Policy, we rely on the following legal bases:
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Provide our service to you: The reason we process your information for purposes A and B above is to perform the contract that you have with us. For instance, as you go about using our Platform to build meaningful connections, we use your information to maintain your account and your profile, make it viewable to other members and recommend other members to you and to otherwise provide our free and paid features to you and other members.
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Legitimate interests: We process your information for purposes C, D, and E above, based on our legitimate interest. For instance, we analyze users’ behavior on our services to continuously improve our offerings, we suggest offers we think might interest you and promote our own services, we process information to help keep our members safe and we process data where necessary to enforce our rights, assist law enforcement and enable us to defend ourselves in the event of a legal action.
Comply with applicable laws and regulations: We process your information for purpose F above where it is necessary for us to comply with applicable laws and regulations and evidence our compliance with applicable laws and regulations. For example, we retain traffic data and data about transactions in line with our accounting, tax and other statutory data retention obligations and to be able to respond to valid access requests from law enforcement. We also keep data evidencing consents members give us and decisions they may have taken to opt-out of a given feature or processing.
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Consent: If you choose to provide us with information that may be considered “special” or “sensitive” in certain jurisdictions, such as your sexual orientation, you’re consenting to our processing of that information in accordance with this Privacy Policy. From time to time, we may ask for your consent to collect specific information such as your precise geolocation or use your information for certain specific reasons. In some cases, you may withdraw your consent by adapting your settings (for instance in relation to the collection of our precise geolocation) or by deleting your content (for instance where you entered information in your profile that may be considered “special” or “sensitive”). In any case, you may withdraw your consent at any time by contacting us at the email address provided at the end of this Privacy Policy.
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3. How We Share Information
Since our goal is to help you make meaningful connections, the main sharing of members’ information is, of course, with other members. We also share some types of members’ information with service providers and partners who assist us in operating the services and, in some cases, legal authorities. Read on for more details about how your information is shared with others.
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With other members
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You share information with other members 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 stuff that you’re comfortable being visible.
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If you choose to limit the audience for all or part of your profile or for certain content or information about you, then it will be visible according to your settings.
If someone submits a report involving you (such as a claim you violated our Terms of Use), we may communicate to the reporter actions, if any, we took as a result of their report.
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With our service providers and partners
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We use vendors to help us operate, distribute, market and improve our services, such as data hosting and maintenance, analytics, customer care, marketing, advertising, payment processing and security operations. We also share information with vendors 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 vendors.
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For corporate transactions
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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.
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With law enforcement / when required by law
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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.
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To enforce legal rights
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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 members, 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.
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With your consent or at your request
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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, location 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 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.
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4. Your Rights and Choices
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We want you to be in control of your information, so we want to remind you of the following options and tools available to you:
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Access / Update tools in the service. Tools and account settings can help you access, rectify or remove information that you provided to us and that’s associated with your account directly within the service. If you have any questions on those tools and settings, please contact our customer care team for help.
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Device permissions. Mobile platforms can have permission systems for specific types of device data and notifications, such as phone contacts, pictures, location services, push notifications and advertising identifiers. You can change your settings on your device to either consent or oppose the collection or processing of the corresponding information or the display of the corresponding notifications. Of course, if you do that, certain services may lose functionality.
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Uninstall. You can stop all information collection by an app by uninstalling it using the standard uninstall process for your device. Remember that uninstalling an app does NOT close your account. To close your account, please use the corresponding functionality on the service.
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Account closure. You can close your account by using the corresponding functionality directly on the service.
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We also want you to be aware of your privacy rights. Depending on where you live, you may have the right to:
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Access/know. You may have the right to request a copy of the information we keep about you, and in certain circumstances to receive this in a portable format. You can exercise your right to access directly within the service by putting in a request.
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Delete/erase. You may request that we delete the personal information we keep about you. You can exercise your right to delete by submitting a request.
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Correct/rectify/update. You can correct most information you provided to us by editing your profile directly in the service. If you believe the information we hold about you is inaccurate, you may contact us to rectify it.
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Object/restrict. You may also have the right to object to or request that we restrict certain processing. To do so, please contact us.
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For your protection and the protection of all of our members, we may ask you to provide proof of identity before we can answer the above requests. Keep in mind, we may reject requests, including if we are unable to authenticate you, if the request is unlawful or invalid, or if it may infringe on trade secrets or intellectual property or the privacy or other rights of someone else. If you wish to receive information relating to another member, such as a copy of any messages you received from them through our service, the other member will have to contact us to provide their written consent before the information is released. We may also ask them to provide proof of identity before we can answer the request. Also, we may not be able to accommodate certain requests to object to or restrict 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 and thus cannot ensure that you are 18 years of age or older.
If you are a resident of Virginia, Colorado, or Connecticut, USA, if we deny your privacy request, you may be able to appeal by contacting us, and explicitly referencing “Privacy Request Appeal.” If you have concerns about the result of your appeal you may contact the attorney general for your state.
5. How Long We Retain Your Information
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We keep your personal information only as long as we need it for legitimate business purposes and as permitted by applicable law. If you decide to stop using our services, you can close your account and your profile will stop being visible to other members. Note that we will close your account automatically if you are inactive for a period of two years. After your account is closed, we will delete your personal information, as laid out below:
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A. To protect the safety and security of our members, we implement a safety retention window of three months following account closure, or one year following an account ban. During this period, we keep your information in the event that it might be necessary to investigate unlawful or harmful conducts. The retention of information during this safety retention window is based on our legitimate interest as well as that of potential third-party victims.
B. Once the safety retention window elapses, we delete your data and only keep limited information for specified purposes, as laid out below:
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We maintain limited data to comply with legal data retention obligations: in particular, we keep transaction data for 10 years to comply with tax and accounting legal requirements, credit card information for the duration the user may challenge the transaction and “traffic data” / logs for one year to comply with legal data retention obligations. We also keep records of consents members give us for five years to evidence our compliance with applicable law.
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We maintain limited information on the basis of our legitimate interest: we keep customer care records and supporting data as well as imprecise location of download/purchase for five years to support our customer care decisions, enforce our rights and enable us to defend ourselves in the event of a claim, information on the existence of past accounts and subscriptions, which we delete three years after the closure of your last account to ensure proper and accurate financial forecasting and reporting, profile data for one year in anticipation of potential litigation, for the establishment, exercise or defense of legal claims, and data necessary to prevent members who were banned from opening a new account, for as long as necessary to ensure the safety and vital interests of our members.
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Finally, we maintain information on the basis of our legitimate interest where there is an outstanding or potential issue, claim or dispute requiring us to keep information (in particular if we receive a valid legal subpoena or request asking us to preserve data (in which case we would need to keep the data to comply with our legal obligations) or if data would otherwise be necessary as part of legal proceedings).
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6. Data Security
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Although we employ technical and organizational controls that we believe are reasonably appropriate to protect your information, we do not guarantee that our security precautions will protect against the loss or misuse of your information. Similarly, we cannot guarantee the privacy of information you transmit over the Internet or devices or that may be collected in transit by others, including contractors that provide services to us.
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7. Third Party Sites
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The Platform may contain links to other websites and services. If you choose to click on a third party link, you will be directed to that third party’s website or service. The fact that we link to a website or service is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third party websites or services. These third parties may place their own cookies or other files on your computer, collect data or solicit personal information from you. Other websites and services follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the other websites and services you visit.
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8. No Children Allowed
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Our services are restricted to individuals who are 18 years of age or older. We do not permit individuals under the age of 18 on our platform. If you suspect that a member is under the age of 18, please use the reporting mechanism available on the service.
9. Your California Privacy Rights
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For users who are California residents, you have the following rights (in addition to those listed above) under the California Consumer Privacy Act, and you have the right to be free from unlawful discrimination for exercising your rights under the Act:
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You have the right to request that we disclose certain information to you and explain how we have collected, used and shared your personal information over the past 12 months.
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You have the right to request that we delete your personal information that we collected from you, subject to certain exceptions.
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California’s “Shine the Light” law, Civil Code section 1798.83, requires certain businesses to respond to requests from California customers asking about the businesses’ practices related to disclosing personal information to third parties for the third parties’ direct marketing purposes.
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From time to time, as part of a joint promotion with a third party, we may, if you participate in such promotion, disclose your contact information to the third party to allow them to market their products or services to you. Where this is a condition for participation in a promotion, we will always let you know before when you enter the promotion. Please follow the instructions provided to you by third parties to unsubscribe from their messages.
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In addition, under California law, operators of online services are required to disclose how they respond to “do not track” signals or other similar mechanisms that provide consumers the ability to exercise choice regarding the collection of personal information of a consumer over time and across third party online services, to the extent the operator engages in that collection. At this time, we do not track our users’ personal information over time and across third-party online services. This law also requires operators of online services to disclose whether third parties may collect personal information about their users’ online activities over time and across different online services when the users use the operator’s service. We do not knowingly permit third parties to collect personal information about an individual user’s online activities over time and across different online services when using the Platform.
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10. Using Hunch From Outside the United States
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If you are visiting Hunch from outside the United States, please be aware that your information may be transferred to, stored, and processed globally, including in the United States where our servers are located and our central database is operated. By using our services, you understand and agree that your information may be transferred to our facilities and those third parties with whom we share it for processing as described in this Privacy Policy. Where required by law, international transfers of personal information will be supported by an adequacy mechanism.
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11. Privacy Policy Changes
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Because we’re always looking for new and innovative ways to help you build meaningful connections and strive to make sure explanations about our data practices remain up-to-date, 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.
12. How to Contact Us
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If you have questions about this Privacy Policy, please contact us at privacy@hunchdating.com.