Privacy Policy

Effective Date: October 1, 2025
Last Updated: September 29, 2025

Soulmatch LLC ("we," "us," or "our"), a California limited liability company registered and located in Santa Clara, California, is committed to protecting your privacy and safeguarding the personal information you share with us. This Privacy Policy explains our practices regarding the collection, use, disclosure, protection, and processing of your information when you visit our Site (https://www.soulmatchofficial.com), apply for membership, use our Service, or interact with us in any way.

This Policy complies with the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA/CPRA, Cal. Civ. Code § 1798.100 et seq.), California Online Privacy Protection Act (CalOPPA, Cal. Bus. & Prof. Code § 22575 et seq.), and other applicable U.S. laws. It is incorporated into our Terms of Use.

By accessing the Site or using the Service, you consent to this Privacy Policy. If you do not agree, please do not use the Site or Service.

1. Information We Collect
We collect Personal Information (any information that identifies, relates to, describes, or is capable of being associated with you) and Non-Personal Information to provide, improve, and secure our premium matchmaking experience. Collection occurs through direct submissions (e.g., forms, profiles), automated technologies, and third-party sources (e.g., payment processors).

1.1 Categories of Personal Information (as Defined Under CCPA)
In the past 12 months, we have collected the following categories:

Identifiers: Name, email address, phone number, postal address, IP address, device ID.
Personal Characteristics (Protected Classifications under California Law): Age, gender, marital status, location, ethnicity (if voluntarily provided for matching).
Commercial Information: Payment and billing details (e.g., credit card info, transaction history), subscription preferences.
Internet or Network Activity: Browsing history on our Site, session activity, click patterns, referring/exit pages, URLs.
Geolocation Data: Approximate location (e.g., Bay Area residency verification).
Professional or Employment Information: Job title, industry, education, professional details shared in profiles.
Sensory Data: Photos, audio/video from coaching sessions (with consent).
Inferences: Derived profiles based on your preferences, feedback, and interactions (e.g., compatibility scores).
Sensitive Personal Information: With explicit consent, details such as relationship preferences that may reveal racial/ethnic origin, religious beliefs, health, or sexual orientation (used solely for matching).
We do not collect financial account details beyond what's needed for payments, which are handled by secure third-party processors.

1.2 Non-Personal Information
Device, browser, and operating system type.
Aggregated usage trends, session data.
Cookies, web beacons, pixels, and similar technologies for analytics, personalization, and security.
1.3 Sources of Information
Directly from you (e.g., onboarding forms, profiles, surveys, feedback).
Automatically via technologies (e.g., cookies).
From third parties (e.g., payment processors, CRM tools for service management).
We do not knowingly collect information from children under 18, in compliance with the Children's Online Privacy Protection Act (COPPA). If we discover such collection, we will delete it immediately and terminate the account.

2. How We Use Your Information
We use your information for legitimate business purposes, including:

Providing matchmaking services, such as curated introductions, concierge support, date planning, and compatibility matching via our Human + AI process.
Managing subscriptions, billing, membership terms, and payments.
Delivering coaching, feedback, personalized relationship insights, and profile refinements.
Communicating service updates, waitlist notifications, promotional offers (with opt-out options), and service-related messages.
Maintaining the integrity, safety, and exclusivity of our Bay Area community (e.g., verifying eligibility, preventing fraud).
Improving the Service through analytics, research, and trend analysis (e.g., refining algorithms).
Complying with legal obligations, responding to requests from authorities, or enforcing our Terms.
With consent, using sensitive information for matching purposes.
We use inferences to enhance matching accuracy but do not use automated decision-making that produces legal or significant effects without human oversight.

We do not use your information for purposes incompatible with those disclosed without notice and consent.

3. Sharing of Information
We share your information only as necessary and do not "sell" or "share" it as defined under CCPA (e.g., for cross-context behavioral advertising). In the past 12 months, we have disclosed the following categories for business purposes:

Service Providers: Trusted vendors (e.g., payment processors like Stripe, email platforms like SendGrid, CRM systems) who assist with operations, bound by data protection agreements. Categories shared: All listed in Section 1.1.
Potential Matches: With your explicit consent, limited profile details (e.g., first name, photos, preferences) for introductions.
Legal Compliance: To comply with laws, subpoenas, court orders, or government requests (e.g., under California Government Code).
Business Transfers: In connection with a merger, acquisition, or sale of assets, with notice and opt-out where required.
Aggregated Data: Anonymized or de-identified data for research or analytics.
We require recipients to protect your data and use it only for the specified purpose.

4. Security of Your Information
We implement industry-standard security measures to protect your information, including:

Encryption (e.g., SSL/TLS for data in transit, AES for data at rest).
Secure servers and firewalls.
Access controls, employee training, and limited internal access on a need-to-know basis.
Regular security audits and vulnerability testing.
Despite these measures, no system is 100% secure. We cannot guarantee absolute protection against unauthorized access, breaches, or loss. By using the Service, you acknowledge these inherent risks. In the event of a breach, we will notify affected individuals as required by law (e.g., Cal. Civ. Code § 1798.82).

Report any suspected security issues to [email protected].

5. Your Rights and Choices
5.1 CCPA Rights for California Residents

If you are a California resident, you have the following rights regarding your Personal Information (exercisable twice per 12 months, free of charge):

Right to Know/Access: Request details on categories collected, sources, purposes, sharing, and specific pieces of information.
Right to Delete: Request deletion, subject to exceptions (e.g., completing transactions, legal obligations, active memberships).
Right to Correct: Request correction of inaccurate information.
Right to Opt-Out of Sale/Sharing: We do not sell or share, but you may opt-out if we do in the future.
Right to Limit Use of Sensitive Personal Information: Limit use to what's necessary for the Service.
Right to Non-Discrimination: We will not discriminate (e.g., deny services, charge differently) for exercising rights.
To exercise rights, submit a verifiable consumer request via email to [email protected] or through our Site's request form. Include "CCPA Request" in the subject and provide sufficient details to verify your identity (e.g., email, phone). We will respond within 45 days (extendable by 45 days with notice). Authorized agents may submit on your behalf with proof of authorization.
We verify requests by matching provided information to our records. For sensitive requests (e.g., access to specific data), we may require additional verification.

5.2 Other Choices
Opt-Out of Marketing: Unsubscribe from non-essential emails (e.g., promotions) via links in emails or by contacting us. We may still send service-related communications.
Cookies and Tracking: Manage preferences via your browser settings (e.g., disable cookies), but this may limit Site functionality. We do not respond to Do Not Track (DNT) signals, as no uniform standard exists.
Account Updates: Access and update your profile information via the member portal or by contacting us.
Data Portability: Request your data in a portable format where feasible.

6. Cookies and Tracking Technologies
We use cookies, pixels, and similar technologies for:
Essential functions (e.g., session management).

Performance and analytics (e.g., usage trends).
Personalization (e.g., remembering preferences).
Security (e.g., fraud detection).
Categories: First-party cookies (set by us) and third-party (e.g., Google Analytics for aggregated insights). You can control cookies via browser settings or tools like the NAI opt-out. Disabling may impair functionality.

Under CalOPPA, this Policy discloses our practices.

7. Children's Privacy
The Service is for adults 18+ only. We do not knowingly collect data from minors under 18. If you believe we have, contact us at [email protected] for immediate deletion.

8. Third-Party Links and Services
The Site may link to third-party websites or integrate services (e.g., payment gateways). We are not responsible for their privacy practices. Review their policies before engaging. We select reputable partners but disclaim liability for their actions.

9. International Data Transfers
All data is processed and stored in the United States. If transferred internationally (e.g., to service providers), we ensure adequate protections through contracts or other mechanisms.

10. Data Retention
We retain Personal Information as long as necessary for the purposes described (e.g., during your active membership plus 6 months for disputes). Financial records are kept for 7 years per California tax law. De-identified data may be retained indefinitely. Upon request or term end, we delete or anonymize data subject to legal requirements.

11. Changes to This Policy
We may update this Policy to reflect changes in practices or laws. Material changes (e.g., new data uses, sharing) will be notified via email or Site posting at least 30 days in advance. Continued use constitutes acceptance. Review periodically.

12. Contact Us
For questions, requests, or CCPA inquiries:
Email: [email protected]
Address: 4701 Patrick Henry Drive, Santa Clara, California 95054

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