Meetville. Privacy Policy

1.1 Policy Overview

This Privacy Policy ("Policy") describes how Sequoia Network, Inc., a Delaware corporation ("Company," "we," "us," or "our"), operating the Meetville platform ("Meetville," "Platform," or "Services") at meetville.com, collects, uses, discloses, and protects personal information obtained through our online dating and social discovery platform accessible at meetville.com and associated mobile and web applications.

This Policy applies to all users of the Meetville Platform, including individuals who register for accounts, create profiles, utilize our Services, or otherwise interact with our websites, applications, events, advertisements, or communications. By accessing or using the Services, you acknowledge that you have read, understood, and agree to be bound by this Policy and consent to the collection, use, and disclosure practices described herein.

Sequoia Network, Inc. acts as the data controller (or "business" under California law) for personal information collected through the Services, determining the purposes and means of processing personal data as described herein.

Consumer Service for Adults Only: The Services are designed exclusively for individuals who are eighteen (18) years of age or older. Users represent and warrant that they are at least 18 years of age and are legally permitted to use the Services in their jurisdiction of residence.

1.2 Where This Policy Applies

This Privacy Policy applies to all websites, mobile applications, web applications, events, promotional activities, customer support channels, and other services that we operate as Meetville at meetville.com. For simplicity, we refer to all of these collectively as the "Services" throughout this Policy.

If a particular service or feature we offer requires its own separate privacy policy or supplemental privacy notice, that policy or notice will be made available to you at the point of collection, and that policy — not this Privacy Policy — will govern the processing described within it.

1.3 Quick Summary

The Meetville Platform provides online dating, matchmaking, messaging, and social discovery services to adult individuals. To deliver these Services, we collect and process:

• Account Information: Login credentials, email address, phone number, date of birth, and gender of registered users
• Profile Data: Photographs, videos, biographical details, interests, lifestyle information, relationship preferences, and other content you choose to publish on your profile
• Communications Content: Messages, chats, and other communications you exchange with other users through the Services
• Location Data: Approximate location derived from IP address and, where you grant permission, precise geolocation from your device
• Usage and Technical Data: Technical and behavioral information regarding your interaction with the Platform, including device identifiers, access logs, and feature utilization
• Payment Data: Billing contact information and subscription records (complete payment card numbers are handled exclusively by our payment processors and are never stored by us)
• Third-Party Data: Information from social authentication providers, advertising partners, other users, and safety and anti-fraud partners

We use this information to operate the Services, recommend potential matches, enable communication between users, process payments, prevent fraud and abuse, protect the safety of our community, serve relevant advertising, and comply with legal obligations.

We implement commercially reasonable security measures including encryption, access controls, and regular security assessments to protect your information. We do not sell personal information to third parties for monetary consideration. Data is shared only with service providers necessary for Platform operation, with other users as inherent to the nature of a social discovery service, as required by applicable law, or with your explicit authorization.

For detailed information regarding our data practices, please review the complete sections below.

1.4 IMPORTANT DISCLAIMER AND ASSUMPTION OF RISK

USER ACKNOWLEDGMENT AND ASSUMPTION OF RISKS: BY ACCESSING OR USING THE MEETVILLE PLATFORM, YOU EXPRESSLY ACKNOWLEDGE, UNDERSTAND, AND AGREE TO THE FOLLOWING:

PUBLIC NATURE OF PROFILE CONTENT: INFORMATION YOU VOLUNTARILY PUBLISH ON YOUR PROFILE, INCLUDING PHOTOGRAPHS, VIDEOS, BIOGRAPHICAL DETAILS, AND OTHER CONTENT, IS VISIBLE TO OTHER USERS OF THE SERVICES. ONCE YOU SHARE INFORMATION WITH ANOTHER USER, NEITHER YOU NOR SEQUOIA NETWORK, INC. CAN CONTROL WHAT THAT USER DOES WITH IT. YOU SHOULD SHARE ONLY INFORMATION YOU ARE COMFORTABLE HAVING VIEWED, COPIED, OR REDISTRIBUTED BY OTHERS.

NO VERIFICATION OF OTHER USERS: SEQUOIA NETWORK, INC. DOES NOT ROUTINELY CONDUCT CRIMINAL BACKGROUND CHECKS, IDENTITY VERIFICATION, OR OTHER SCREENING OF ALL USERS. WHILE WE OPERATE MODERATION AND ANTI-FRAUD SYSTEMS, WE DO NOT WARRANT, REPRESENT, OR GUARANTEE THE IDENTITY, AGE, INTENTIONS, CHARACTER, TRUTHFULNESS, OR CONDUCT OF ANY USER OF THE SERVICES. INFORMATION PROVIDED BY OTHER USERS MAY BE INACCURATE, INCOMPLETE, OR INTENTIONALLY FALSE.

NO GUARANTEE OF ACCURACY OR OUTCOMES: SEQUOIA NETWORK, INC. DOES NOT WARRANT THE ACCURACY, COMPLETENESS, OR RELIABILITY OF ANY MATCH RECOMMENDATIONS, COMPATIBILITY INDICATORS, SEARCH RESULTS, OR OTHER OUTPUTS GENERATED BY THE PLATFORM. THE PLATFORM DOES NOT GUARANTEE THAT YOU WILL FORM ANY RELATIONSHIP, CONNECTION, OR MATCH.

USER RESPONSIBILITY: YOU BEAR SOLE AND EXCLUSIVE RESPONSIBILITY FOR:

• YOUR DECISIONS TO COMMUNICATE WITH, MEET, OR OTHERWISE INTERACT WITH OTHER USERS, ONLINE OR IN PERSON
• THE ACCURACY AND LEGALITY OF ALL CONTENT YOU SUBMIT, PUBLISH, OR TRANSMIT THROUGH THE SERVICES
• THE INFORMATION YOU CHOOSE TO DISCLOSE PUBLICLY OR TO OTHER USERS
• YOUR OWN PERSONAL SAFETY, INCLUDING EXERCISING APPROPRIATE CAUTION AND FOLLOWING SAFETY PRACTICES WHEN ARRANGING OR ATTENDING IN-PERSON MEETINGS
• SECURING YOUR ACCOUNT CREDENTIALS AND DEVICES

ASSUMPTION OF RISKS: YOU EXPRESSLY ASSUME ALL RISKS ASSOCIATED WITH USE OF THE PLATFORM, INCLUDING BUT NOT LIMITED TO: EXPOSURE TO MISLEADING, FRAUDULENT, OFFENSIVE, OR HARMFUL USERS OR CONTENT; ROMANCE FRAUD, SCAMS, OR FINANCIAL EXPLOITATION ATTEMPTED BY OTHER USERS; UNAUTHORIZED COPYING OR REDISTRIBUTION OF CONTENT YOU PUBLISH; REPUTATIONAL HARM; EMOTIONAL DISTRESS; AND ANY OTHER DAMAGES OR ADVERSE CONSEQUENCES ARISING FROM INTERACTIONS INITIATED THROUGH THE SERVICES.

INDEPENDENT JUDGMENT REQUIRED: THE PLATFORM IS AN INTRODUCTION TOOL ONLY. IT DOES NOT REPLACE YOUR OWN JUDGMENT, DUE DILIGENCE, OR PERSONAL SAFETY PRECAUTIONS.

For purposes of this Policy, the following terms have the meanings set forth below:

"Personal Data" or "Personal Information" means any information relating to an identified or identifiable natural person, including but not limited to name, email address, telephone number, identification numbers, photographs, location data, online identifiers, or factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that person. This term is synonymous with "personal information" as defined under the California Consumer Privacy Act (CCPA) and "personal data" as defined under the General Data Protection Regulation (GDPR).

"Processing" means any operation or set of operations performed on Personal Data, whether by automated means or otherwise, including collection, recording, organization, structuring, storage, adaptation, alteration, retrieval, consultation, use, disclosure by transmission, dissemination, alignment, combination, restriction, erasure, or destruction.

"Data Controller" means the entity that determines the purposes and means of Processing Personal Data. Sequoia Network, Inc. serves as the Data Controller (or "business" under CCPA terminology) for Personal Data collected through the Services.

"Data Processor" means an entity that Processes Personal Data on behalf of the Data Controller pursuant to documented instructions (or "service provider" or "contractor" under CCPA terminology).

"Data Subject" means an identified or identifiable natural person whose Personal Data is Processed (or "consumer" under CCPA terminology).

"User," "Member," or "you" means any individual who accesses, registers for, or uses the Services.

"Services" means the Meetville online dating and social discovery platform, including the website located at meetville.com, mobile applications, web application interfaces, integrations, application programming interfaces (APIs), events, and all associated features and functionality provided by Sequoia Network, Inc. as the Meetville platform at meetville.com.

"Third-Party Service Providers," "Subprocessors," or "Service Providers" means entities engaged by us to perform functions on our behalf, including but not limited to cloud hosting, data analytics, payment processing, content moderation, fraud prevention, customer support services, and communications infrastructure.

"Sensitive Personal Information" means Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data processed for unique identification purposes, health data, data concerning sex life or sexual orientation, Social Security numbers, driver's license numbers, passport numbers, financial account credentials, or precise geolocation data, as defined under applicable privacy laws including the California Privacy Rights Act (CPRA) and GDPR special categories of personal data (Article 9).

"Content" means photographs, videos, audio recordings, text, messages, profile descriptions, and any other material that Users submit, publish, transmit, or otherwise make available through the Services.

"Profile Data" means the information a User publishes or makes available on their Meetville profile for viewing by other Users.

"Insights and Inferences" means conclusions, predictions, characterizations, scores, or other derived information generated by us from your interactions with the Services and the information and Content you provide, reflecting for example your preferences, characteristics, predispositions, behavior, and attitudes.

3.1 Categories of Data Collected

We collect and Process the following categories of Personal Information in connection with providing the Services:

3.1.1 Account and Registration Data

When you create an account or register to use the Services, we collect:

• Email address
• Telephone number (where provided or required for registration or verification)
• Account password (cryptographically hashed using industry-standard algorithms; plaintext passwords are never stored)
• Date of birth (used to verify that you meet the minimum age requirement of 18 years and to determine age-based match preferences)
• Gender and gender identity
• Display name or username
• Account preferences and configuration settings
• Subscription plan selection and account tier status
• Billing contact information

3.1.2 Profile Data and User Content

When you complete your profile and use the Services, you share additional details about yourself, which may include:

• Photographs and profile images
• Videos and audio content
• Biographical descriptions and self-authored text
• Interests, hobbies, and lifestyle information
• Relationship preferences, intentions, and the types of people you would like to meet
• Approximate location or city of residence
• Education, occupation, and employment information
• Height, physical description, and appearance details
• Languages spoken
• Relationship status and family information (for example, whether you have children)
• Habits and lifestyle indicators (for example, smoking or drinking preferences)
• Answers to profile questions, prompts, quizzes, or compatibility questionnaires
• Links to or content imported from connected social media accounts

Sensitive Data Notice: Some of the information you choose to provide may be considered "special category" data under the GDPR or "sensitive personal information" under United States privacy laws — for example, details revealing your sexual orientation, sexual life, religious or philosophical beliefs, political opinions, racial or ethnic origin, or health information. Providing this information is entirely voluntary. If you choose to provide it, you explicitly consent to our Processing of that information as described in this Policy. You may withdraw this consent at any time by removing the information from your profile or by contacting us at [email protected].

3.1.3 Communications and Interaction Data

When you communicate through the Services, we collect and process:

• Messages, chats, and other communications exchanged with other Users
• Media shared within conversations, including images, videos, voice messages, and links
• Interaction metadata: whom you contact, the timing and frequency of exchanges, message volumes, and response patterns
• Likes, matches, swipes, favorites, blocks, and similar interaction signals
• Search queries and filter criteria you apply within the Services
• Reports you submit regarding other Users, and reports other Users submit regarding you

3.1.4 Purchase and Transaction Data

When you make a purchase, subscribe to a paid service, or request a refund, we collect:

• Records of the transaction (what you purchased, transaction date, price, currency, and applicable taxes)
• Subscription plan selections, upgrades, downgrades, renewals, and cancellations
• Billing contact details and billing address
• Payment method type and tokenized payment references
• Refund requests, chargebacks, and dispute records
• Where you pay directly with us rather than through a platform such as Apple App Store or Google Play, you provide your debit or credit card number or other financial information directly to our payment processor

The exact data collected depends on the payment method you select and the platform through which the purchase is made.

3.1.5 Marketing, Survey, Research, and Event Data

We periodically conduct (i) surveys, focus groups, and market studies for research purposes, and (ii) promotions, contests, sweepstakes, and events for marketing purposes. When you choose to participate, we collect:

• Registration and entry information
• Your responses to survey and research questions
• Feedback, testimonials, product satisfaction ratings, and feature requests
• Event attendance, participation, and interaction records
• Prize fulfillment and eligibility verification information

3.1.6 Third-Party Data

Data from Other Users: Other Users may provide information about you as they use the Services. For example, we receive information about you when another User submits a report, complaint, or query involving you, or when another User chooses to share content or information that concerns you.

Social Media and Social Authentication Data: You may choose to create and log into your account using credentials from third-party platforms (for example, Facebook, Google, Apple, or LinkedIn), or to import content such as photographs from those platforms. When you do so, we receive the profile information you authorize the third-party platform to share, which may include your name, email address, profile photograph, date of birth, gender, friend or connection lists (where authorized), and other profile attributes you consent to share through the platform's authorization flow.

Advertising and Marketing Partners: We receive information from partners who distribute or assist us in advertising the Services, including data regarding campaign performance, attribution, conversion events, and interactions you have had with our advertisements on third-party websites and applications.

Safety, Fraud Prevention, and Anti-Abuse Partners: Where legally permitted, we receive information about suspected or confirmed bad actors from third parties, industry partners, and companies facing similar threats, as part of our efforts to protect the safety and security of our Users.

3.1.7 Usage and Technical Data

We automatically collect certain technical information when you access or use the Services through standard server logging, application telemetry, and tracking technologies:

• Internet Protocol (IP) addresses (used for approximate geographic location, security analysis, and fraud prevention)
• Device identifiers and technical characteristics (device type, manufacturer, model, operating system type and version, screen resolution, hardware specifications)
• Advertising identifiers, including Google Advertising ID (AAID) and Apple Identifier for Advertisers (IDFA), which are resettable through your device settings
• Browser type, version, and language preference settings
• Time zone settings and locale
• Mobile network and wireless connection information, including service provider and signal characteristics
• Device sensor data, where relevant to feature functionality (for example, accelerometer, gyroscope, or compass data used for motion-based features or fraud detection)
• Referral sources and URLs (websites or services from which you navigate to the Platform)
• Clickstream data and navigation paths (pages viewed, features accessed, sequence of interactions within the Platform)
• Timestamps of Platform interactions (date and time of login, feature usage, session duration)
• Session identifiers and authentication tokens
• Feature utilization metrics (which features are accessed, frequency of use, interaction patterns)
• Advertisements displayed to you and advertisements with which you interact
• Error logs, exception reports, crash reports, and diagnostic data generated during Platform operation
• Performance metrics (page load times, API response times, system resource utilization)
• Cross-device linkage signals used to provide a consistent experience across devices you use to access the Services

3.1.8 Location Data

Approximate Location: We derive approximate geographic location (country, state or region, and city level) from your IP address for the purposes of localizing content, complying with jurisdictional legal requirements, detecting fraud, and providing distance-based match recommendations.

Precise Geolocation: If you grant permission through your device settings, we collect precise geolocation data (latitude and longitude) from your device through GPS, Bluetooth, Wi-Fi, or cellular signals. Precise geolocation is used to show you Users near you, calculate distance between Users, and enable location-dependent features.

Collection of geolocation data may occur in the background even when you are not actively using the Services, where the permission you granted expressly permits such collection and where such background collection is necessary for a feature you have enabled. If you decline or revoke this permission, we will not collect precise geolocation, and features that depend on it will be unavailable or degraded. You may revoke this permission at any time through your device operating system settings.

3.1.9 Camera, Photo Library, and Contacts Access

Certain features require access to device capabilities and data. We request these permissions individually, and you may grant or decline each:

• Camera and microphone: to capture photographs, videos, or audio for your profile, verification features, or in-conversation media
• Photo library: to allow you to select and upload existing images or videos
• Contacts or phonebook: where you elect to use a feature that requires it (for example, inviting a contact or excluding known contacts from your recommendations). Where you provide contact information about other individuals, we process that information on your behalf solely to complete your request
• Push notifications: to deliver alerts regarding messages, matches, account activity, and service updates

You may revoke any of these permissions at any time through your device operating system settings. Revoking a permission may cause the corresponding feature to lose functionality.

3.1.10 Verification and Identity Data

Photo and Face Verification Data: You may choose to participate in optional verification features that involve capturing a live photograph or short video for comparison against your profile images. Where such a feature analyzes facial geometry, the resulting data may be considered biometric data in certain jurisdictions. Where required by applicable law, we obtain your explicit consent before collecting such data, we use it solely to confirm that you are the person shown in your profile photographs and to detect impersonation and fraud, and we do not use it for advertising, profiling, or sale. Facial geometry data generated for verification purposes is deleted promptly following completion of the verification process, and in any event within thirty (30) days, unless continued retention is necessary to comply with an applicable legal obligation, to investigate a security or safety incident, or to establish, exercise, or defend legal claims.

Government-Issued Identification: You may choose, or we may request in specific circumstances (for example, following a safety report, a suspected account compromise, an age-verification requirement, or a data subject rights request), to provide a copy of a government-issued identification document to verify your identity or age. We use identification documents solely for verification purposes and retain them only as long as necessary for that purpose and for related legal, safety, and dispute-resolution obligations.

3.1.11 Customer Support and Moderation Data

When you communicate with Sequoia Network, Inc., or when your account is subject to moderation review, we collect and retain:

• Customer support ticket contents, including issue descriptions, troubleshooting steps, and resolution notes
• Email correspondence sent to or received from Company email addresses ([email protected] or other designated addresses)
• In-Platform chat transcripts and support messaging history
• Call recordings and monitoring records, where support interactions are recorded for quality assurance and training purposes and where permitted by applicable law and disclosed to you at the time of the interaction
• User feedback, product satisfaction surveys, and feature requests
• Documentation, screenshots, log files, and diagnostic information you voluntarily submit in connection with support requests
• Reports of misconduct, Terms violations, or safety concerns submitted by you or about you
• Moderation determinations, warnings, content removals, restrictions, suspensions, and bans, together with the supporting evidence and reasoning
• Appeal submissions and appeal outcomes

3.1.12 Insights and Inferences

Using the Services involves the generation of insights and inferences derived from your interactions and the information and Content you provide. These reflect, for example, your preferences, characteristics, predispositions, behavior, and attitudes, and are used primarily to generate match recommendations, personalize your experience, detect fraudulent or abusive behavior, and improve the Services.

3.2 Methods of Collection

Personal Information is collected through the following technical and operational methods:

Direct Provision by Users: Information that you voluntarily and actively provide when creating an account, completing registration forms, building or editing your profile, configuring settings, communicating with other Users, submitting support requests, participating in surveys or promotions, or otherwise communicating with us through available channels.

Automated Collection During Service Use: Information generated automatically as you interact with the Services, including access logs, usage telemetry, device and network data, and interaction records.

Automated Collection via Authorized Integrations: Information obtained through OAuth 2.0 or similar secure authorization protocols connecting the Platform to third-party services you elect to link, including social authentication providers (for example, Facebook, Google, Apple, or LinkedIn), where you authorize the sharing of specified profile attributes.

Cookies and Similar Tracking Technologies: Information collected through first-party and third-party cookies, web beacons, pixel tags, software development kits (SDKs), local storage, and similar tracking technologies embedded in our website and application interfaces. Detailed information regarding our use of cookies is provided in Section 11.

Third-Party Analytics, Advertising, and Attribution Services: Information collected through analytics and advertising platforms which employ cookies, SDKs, and JavaScript-based tracking to analyze Platform usage patterns, user behavior, performance metrics, campaign attribution, and advertising effectiveness.

Data from Other Users and Third Parties: Information provided to us about you by other Users, social platforms, advertising partners, and safety and anti-fraud partners, as described in Section 3.1.6.

Inference and Derivation: Certain information is derived or inferred from other data sources, including compatibility analysis, recommendation scoring, risk assessments, and behavioral signals generated through algorithmic analysis and machine learning models.

3.3 Data We Explicitly Do Not Collect

To provide transparency regarding the scope and limitations of our data collection practices, we explicitly do not collect, store, process, or maintain access to the following categories of information:

• Banking or financial institution login credentials, passwords, PINs, or security questions
• Complete credit card numbers, CVV/CVC security codes, or magnetic stripe data — payment processing is conducted exclusively by third-party PCI DSS certified payment processors, and complete payment card numbers are never transmitted to or stored by Sequoia Network, Inc.
• Social Security Numbers, Taxpayer Identification Numbers, or national identification numbers, except where a government-issued identification document is voluntarily submitted for identity or age verification purposes under Section 3.1.10
• Health information, medical records, insurance information, or protected health information (PHI) as defined under HIPAA, except to the extent you voluntarily publish health-related details on your own profile
• Genetic data, DNA profiles, fingerprints, retinal scans, or voiceprints
• Contents of files, documents, or data stored in connected cloud storage services (Dropbox, Google Drive, OneDrive, and similar)
• Contents of your device communications outside the Services, including SMS messages, emails, or third-party messaging applications
• Continuous background location tracking beyond the scope of permissions you have expressly granted
• Information regarding individuals under 18 years of age — the Services are not directed to minors, and we do not knowingly collect their information (see Section 13)

3.4 Do Not Track Signals

Some web browsers offer a "Do Not Track" ("DNT") feature that signals to websites that a user does not wish to have their online activity tracked. There is currently no uniform industry or legal standard for interpreting or responding to DNT signals. For this reason, and consistent with prevailing industry practice, the Meetville Platform does not currently respond to DNT browser signals. We do honor recognized opt-out preference signals, including Global Privacy Control (GPC), where required by applicable law, as described in Section 10.

4.1 GDPR Legal Bases (EEA, UK, and Swiss Users)

For users located in the European Economic Area (EEA), United Kingdom, or Switzerland, we Process Personal Data only where we have established a lawful basis under the General Data Protection Regulation (GDPR), UK GDPR, or the Swiss Federal Act on Data Protection (FADP). Our legal bases for Processing include:

4.1.1 Performance of Contract (GDPR Article 6(1)(b))

Processing is necessary for the performance of our contractual obligations to you under the Terms of Use, or to take steps at your request prior to entering into a contract. This legal basis covers:

• Creating and maintaining your account and profile
• Making your profile viewable to other Users in accordance with your settings
• Generating and delivering match recommendations
• Enabling messaging and other communication between Users
• Providing access to Platform features, functionality, and integrations
• Processing billing transactions and managing subscription payments
• Verifying that you meet the minimum age requirement
• Delivering customer support, technical assistance, and troubleshooting services
• Communicating service-related information, system status updates, and notifications essential for Platform operation
• Enforcing our Terms of Use and usage policies

4.1.2 Legitimate Interests (GDPR Article 6(1)(f))

Processing is necessary for our legitimate business interests or those of third parties, except where such interests are overridden by your fundamental rights and freedoms requiring protection of Personal Data. Our legitimate interests include:

• Preventing fraud, romance scams, unauthorized access, security breaches, and cyber threats, and protecting the integrity of the Platform
• Protecting the safety of Users, including detecting, investigating, and acting upon harassment, abuse, impersonation, spam, and other harmful conduct on and off the Platform
• Preventing individuals who have been banned for unsafe or abusive behavior from creating new accounts
• Ensuring network and information security through monitoring, logging, and threat detection systems
• Improving Platform functionality, performance, user experience, and match quality through analysis of usage patterns
• Conducting internal business analytics, product development research, and market analysis
• Linking devices and browsers you use to provide a consistent cross-device experience
• Sending you notifications encouraging engagement with the Services (for example, that you have received a new message), taking into account the benefit to you
• Promoting our Services in a measured and proportionate manner, including through marketing communications and reasonably targeted advertising, where consent is not otherwise required
• Enforcing our Terms of Use and other legal agreements
• Exercising or defending against legal claims, litigation, or disputes
• Facilitating efficient business operations, administration, and corporate governance

We have conducted legitimate interest assessments (balancing tests) to ensure that our Processing activities do not disproportionately impact your fundamental rights and freedoms. Where Processing relies on legitimate interests, you have the right to object as described in Section 10.

4.1.3 Consent (GDPR Article 6(1)(a)) and Explicit Consent (Article 9(2)(a))

Where required by applicable law or where we do not rely on another legal basis, Processing is based on your explicit, informed, freely given, and specific consent. This includes:

• Processing of special categories of Personal Data (GDPR Article 9), including data revealing sexual orientation, sexual life, religious or philosophical beliefs, political opinions, racial or ethnic origin, or health, where you voluntarily provide such data on your profile or elsewhere in the Services
• Collection of precise geolocation data from your device
• Collection and processing of facial geometry or other biometric data in connection with optional verification features, where such consent is required
• Access to your device camera, microphone, photo library, and contacts
• Marketing communications, promotional materials, and newsletters, where not covered by legitimate interest provisions
• Non-essential cookies and tracking technologies used for analytics, advertising, or personalization beyond core Platform functionality
• Optional data sharing with third-party service providers beyond those strictly necessary for Service delivery

You have the absolute right to withdraw consent at any time without affecting the lawfulness of Processing conducted prior to withdrawal. Withdrawal of consent does not affect our ability to Process Personal Data based on alternative lawful grounds such as contract performance or legitimate interests. To withdraw consent, adjust your account or device settings, remove the relevant content from your profile, or contact us at [email protected].

4.1.4 Legal Obligations (GDPR Article 6(1)(c))

Processing is necessary to comply with legal obligations to which Sequoia Network, Inc. is subject, including:

• Tax reporting, record-keeping, and documentation obligations under applicable revenue laws
• Responding to lawful requests, legal process, court orders, subpoenas, or warrants from law enforcement agencies, regulatory authorities, or judicial bodies
• Compliance with data protection laws, including data subject access request obligations
• Age verification and prevention of access by minors
• Removal of illegal content and reporting obligations under applicable online safety and content regulations
• Preservation of data pursuant to litigation holds or regulatory investigations

4.1.5 Vital Interests (GDPR Article 6(1)(d)) and Substantial Public Interest (Article 9(2)(g))

Processing may be necessary to protect the vital interests of you or another natural person — for example, where we receive credible information indicating a risk to a person's life or physical safety. Processing of special categories of data may also be carried out where necessary for reasons of substantial public interest, including the prevention, detection, and investigation of unlawful acts and cooperation with law enforcement authorities on such matters.

4.2 CCPA/CPRA Legal Framework (California Residents)

For California residents whose Personal Information we Process, we comply with the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA). Under this framework:

Business Purpose: We collect and Process Personal Information for legitimate business purposes including providing the Services, detecting security incidents, debugging, short-term transient use, performing services on behalf of the business, undertaking internal research, and verifying service quality.

Commercial Purpose: We may use Personal Information for our commercial purposes such as auditing interactions, detecting fraud, improving the Services, and undertaking activities to maintain and improve service quality.

No Sale of Personal Information: Sequoia Network, Inc. does not sell Personal Information in exchange for monetary consideration. Certain disclosures to advertising partners for cross-context behavioral advertising may nonetheless fall within the broad statutory definitions of "sale" or "sharing" under CCPA/CPRA. Where that is the case, we provide an opt-out mechanism as described in Section 10.2.5.

Sensitive Personal Information: We limit our use and disclosure of Sensitive Personal Information to the purposes permitted under CPRA Section 1798.121, and we provide a right to limit such use where required.

Service Provider Relationships: Third parties that receive Personal Information from us are engaged as service providers or contractors under written agreements restricting their use of such information to providing specified services.

4.3 Other Jurisdictions

Where the privacy laws of other jurisdictions apply to our Processing — including but not limited to Brazil (LGPD), Canada (PIPEDA), Australia (Privacy Act), Japan (APPI), and applicable United States state privacy laws — we Process Personal Data in accordance with the lawful bases and requirements established by those laws.

We Process Personal Information collected through the Services for the following business purposes necessary to deliver dating and social discovery functionality and maintain Platform operations:

5.1 Core Service Delivery

Account Administration and Service Provision:

• Creating, maintaining, and terminating your account and profile
• Operating and maintaining Platform features and functionality
• Verifying that you meet the minimum age requirement of 18 years
• Responding to your requests, inquiries, and support tickets
• Completing your transactions and managing billing and order administration
• Monitoring the proper functioning of the Services, troubleshooting, and remediating defects

Matching, Recommendation, and Discovery:

• Analyzing your profile, stated preferences, interaction behavior, and location to recommend other Users who may be relevant to you
• Recommending your profile to other Users
• Displaying Users' profiles to one another in accordance with visibility settings
• Ranking, filtering, and ordering search results and recommendation feeds
• Calculating distance, compatibility indicators, and similar match signals

DISCLAIMER: Match recommendations are algorithmic suggestions only. They do not constitute a representation, warranty, or endorsement regarding the identity, character, intentions, safety, or suitability of any User.

Communication Between Users:

• Transmitting, delivering, storing, and displaying messages and media exchanged between Users
• Operating features that notify Users of matches, messages, and interactions
• Applying content moderation and safety filtering to communications, as described in Section 5.3

Cross-Device Consistency:

• Linking the devices and browsers you use so that you receive a consistent experience across them, including through the use of partial or full IP address, browser characteristics, device identifiers, and authentication state

5.2 Platform Operations and Account Management

Authentication, Authorization, and Access Control:

• Verification and validation of user identity through email-based authentication, cryptographic password validation, one-time codes, and passwordless authentication mechanisms
• Social authentication via third-party OAuth providers, allowing you to sign in using existing credentials and to share authorized profile attributes with the Platform
• Creation, maintenance, and termination of authenticated user sessions with appropriate security controls and timeout policies
• Support for multi-factor authentication (MFA) mechanisms enhancing account security beyond password-only authentication
• Account recovery and credential reset processes

Subscription Billing and Payment Administration:

• Processing of one-time and recurring subscription payments through designated third-party payment processors
• Generation, delivery, and archival of invoices, payment receipts, and billing statements
• Administration of subscription plan modifications including upgrades, downgrades, renewals, and cancellations
• Processing of refund requests in accordance with applicable terms and platform rules
• Detection and prevention of payment fraud and chargeback abuse
• Maintenance of billing history and payment records satisfying accounting, audit, and tax compliance requirements
• Offering discounts, promotions, and customized pricing, where and as legally permissible

Customer Support and User Assistance:

• Receipt, triage, and resolution of support inquiries submitted through email, in-Platform messaging, or designated support channels
• Diagnosis and remediation of technical issues, software defects, and functionality impairments
• Investigation and resolution of account discrepancies, billing disputes, and access problems
• Delivery of onboarding guidance and assistance regarding effective Platform utilization
• Monitoring or recording of support interactions for quality assurance and training purposes, where permitted by applicable law

5.3 Safety, Security, Moderation, and Fraud Prevention

Content Moderation and Community Safety:

• Automated and human review of profiles, photographs, videos, and messages to detect and act upon content violating our Terms of Use or Community Guidelines
• Detection and prevention of harassment, abuse, hate speech, sexual exploitation, non-consensual intimate imagery, spam, and unlawful content
• Investigation of reports submitted by Users regarding other Users
• Application of warnings, content removals, feature restrictions, account suspensions, and permanent bans
• Notification to a reporting User of the actions taken in response to their report, and notification to Users who have interacted with an account that was subsequently banned, where appropriate and legally permitted

Fraud, Scam, and Abuse Prevention:

• Detection and prevention of romance fraud, financial scams, catfishing, impersonation, and bot or automated account activity
• Continuous automated monitoring of authentication attempts, registration patterns, and Platform interactions to detect anomalous behavior indicative of unauthorized access or account compromise
• Implementation of controls designed to prevent, detect, and respond to brute force attacks, credential stuffing, account takeover attempts, and other malicious activity
• Retention of data related to fraudulent activity to prevent recurrence, including preventing banned Users from creating new accounts
• Sharing of IP address, device data, and abuse signals with third-party fraud prevention providers where an account has been terminated for fraud or conduct damaging to the Services or its Users

Cross-Platform Safety Coordination: Where legally permitted, we may share information regarding confirmed bad actors with, and receive such information from, affiliated services and industry partners facing similar threats, for the purpose of preventing individuals who have engaged in serious misconduct on one platform from causing harm on another.

Security Monitoring:

• Investigation of reported or detected security incidents and implementation of containment, remediation, and corrective measures
• Maintenance of audit logs recording access to sensitive data, administrative actions, and security-relevant events for forensic analysis and compliance verification
• Operation of intrusion detection and prevention systems monitoring network traffic and application behavior

Regulatory Compliance and Legal Obligations:

• Retention of records as required under applicable laws
• Processing of data subject rights requests including access, deletion, correction, portability, and objection requests under GDPR, CCPA/CPRA, and other applicable privacy laws
• Cooperation with lawful requests for information from law enforcement agencies, regulatory authorities, or judicial bodies when accompanied by appropriate legal process
• Creation and maintenance of documentation and evidence necessary to demonstrate compliance with data protection obligations

5.4 Advertising, Marketing, and Personalization

Advertising on Our Services:

• Displaying advertisements for third-party products and services within the Services
• Measuring the delivery, reach, and effectiveness of advertising campaigns
• Personalizing advertisements based on your profile attributes, inferred interests, and usage behavior, subject to your settings and applicable consent requirements

Marketing Our Services:

• Promoting the Services on third-party websites, applications, and social platforms
• Measuring the effectiveness of acquisition and retention campaigns
• Communicating with you by email, push notification, SMS, telephone, social media, or in-app messaging about products, features, offers, or services we believe may interest you
• Administering sweepstakes, contests, discounts, and other promotional offers
• Constructing similar-audience or exclusion audiences using hashed, non-human-readable identifiers provided to advertising partners

Opt-Out Rights: You may opt out of non-essential marketing communications at any time by adjusting your notification settings, clicking the unsubscribe link provided in email communications, adjusting your device push notification settings, or contacting [email protected]. Opting out does not affect delivery of transactional, service-essential, safety-related, or legally required communications necessary for Platform operation and contractual obligations.

5.5 Product Development, Research, and Analytics

• Analysis of usage patterns to identify unmet user needs, workflow inefficiencies, and opportunities for new Platform capabilities
• Administration of focus groups, surveys, market studies, and user research
• Evaluation of feature adoption rates, engagement patterns, and user feedback to prioritize product development and resource allocation
• Development, training, evaluation, and improvement of machine learning models designed to improve recommendation relevance, content moderation accuracy, fraud detection, and Platform safety
• Experimentation with new algorithms, features, interface designs, and analytical methodologies, including A/B testing and staged feature rollouts
• Conducting research and, where appropriate, publishing research findings

Important Limitation: Research and analytics activities that are not necessary for the direct operation of the Services are conducted, wherever technically feasible, using either (i) anonymized data from which individual identification is not reasonably possible, or (ii) aggregated data presented at sufficient scale to prevent reverse identification of specific individuals.

5.6 Transactional and Service-Essential Communications

• Account creation confirmations, password reset communications, and authentication-related notifications
• Billing statements, payment confirmations, failed payment notifications, and subscription renewal notices
• Service availability notifications including planned maintenance windows, unplanned outages, and restoration updates
• Notifications regarding new messages, matches, and interactions, subject to your notification settings
• Security notifications regarding suspicious account activity, required security actions, policy violations, or threats relevant to your account
• Notices of material changes to this Privacy Policy, the Terms of Use, or other governing documents

We disclose Personal Information to third parties only in the circumstances described in this section. Sequoia Network, Inc. does not sell Personal Information for monetary consideration.

6.1 With Other Users

Because Meetville is a social discovery service, sharing information with other Users is inherent to the operation of the Services.

Profile Visibility: You share information with other Users when you voluntarily disclose information on the Services, including through your public profile. This includes Profile Data, photographs, videos, and other Content you publish, as well as certain derived signals such as approximate distance from another User.

Communications: Messages and media you send to another User are delivered to and stored for that User.

Reports and Moderation Outcomes: If another User submits a report involving you, we may inform the reporting User of the actions we took, if any, in response. The same applies if you submit a report involving another User.

Data Access Requests by Other Users: If another User exercises their right to obtain a copy of their personal data, that copy may include messages you sent to them, as those messages constitute their personal data as well as yours.

Sharing Functionality: Where the Services provide functionality allowing profiles or content to be shared outside the Platform, Users may choose to share your profile information with people outside the Services, and you may do the same with theirs.

IMPORTANT: Please exercise care regarding the information you publish. Neither you nor Sequoia Network, Inc. can control what other Users do with information once you have shared it with them. Content may be screenshotted, copied, or redistributed by recipients outside our control.

6.2 Service Providers and Subprocessors

We engage third-party service providers to perform specific functions supporting Platform operations and Service delivery. These entities act as data processors (GDPR terminology), service providers or contractors (CCPA/CPRA terminology), or subprocessors, and are contractually bound to:

• Process Personal Information only pursuant to our documented instructions and for specified purposes
• Implement and maintain appropriate technical and organizational security measures
• Maintain confidentiality of all Personal Information received
• Not use or disclose Personal Information for purposes other than performing contracted services
• Comply with applicable data protection laws and cooperate with regulatory authorities
• Return or securely delete Personal Information upon termination of services as directed

We conduct a vetting process before engaging any service provider or partner, and all service providers and partners are subject to confidentiality obligations.

Categories of service providers we engage include:

6.2.1 Cloud Infrastructure and Computing Services

Services: Cloud computing infrastructure, data storage, database hosting, content delivery networks, media processing and transcoding, network infrastructure, and related technical services

Data Disclosed: All categories of Personal Information described in Section 3 may be stored within cloud infrastructure operated by these providers

Data Location: Primary storage in United States data center regions, with content delivery infrastructure operating globally

Security: Data encrypted at rest using industry-standard algorithms, encrypted in transit using TLS, isolated architecture, and regular third-party security assessments

6.2.2 Payment Processing Services

Services: Payment processing, subscription billing management, fraud detection, payment method tokenization, invoicing, and related financial services

Data Disclosed: Billing contact information, payment method details (complete credit and debit card numbers are collected directly by the payment processor and are never transmitted to or stored by Sequoia Network, Inc.), subscription plan selections, billing history, and invoice records

PCI Compliance: We engage payment processors certified as PCI DSS Level 1 Service Providers. Because Sequoia Network, Inc. does not receive, transmit, or store complete payment card numbers, cardholder data exposure is minimized.

Where you purchase a subscription through the Apple App Store or Google Play Store, the applicable platform operator processes the transaction under its own terms and privacy policy, and we receive only transaction confirmation and entitlement data.

6.2.3 Content Moderation, Trust and Safety, and Fraud Prevention Providers

Services: Human and automated moderation of profiles, images, video, and messages; detection of prohibited content; identity and age verification; anti-spam and anti-bot protection; romance-fraud detection; device fingerprinting for abuse prevention

Data Disclosed: Profile Data, Content, communications flagged for review, device and technical data, IP addresses, reports, and moderation history

6.2.4 Analytics, Attribution, and Advertising Services

Services: Product analytics, event tracking, session analysis, crash reporting, marketing attribution, campaign measurement, audience construction, advertising delivery, and retargeting

Data Disclosed: Usage data, technical information, pseudonymous and hashed identifiers, advertising identifiers, aggregated behavioral patterns, performance metrics, conversion events, and advertising interaction data

Minimization Measures: We implement IP address truncation or anonymization where supported, pseudonymous user identifiers, hashed identifiers for audience matching, and data retention limits to minimize personal data exposure through analytics and advertising platforms.

6.2.5 Communications and Customer Support Services

Services: Transactional and marketing email delivery, SMS and push notification delivery, in-app messaging, customer support ticketing, and helpdesk operations

Data Disclosed: Account Data, contact details, notification preferences, support correspondence, and delivery and engagement metrics

Each service provider processes Personal Information in accordance with its own privacy policy in addition to our contractual instructions. A current list of subprocessors is available upon request to [email protected].

6.3 Legal Disclosures and Law Enforcement

We may disclose Personal Information where we reasonably believe disclosure is necessary to:

Legal Process Compliance:

• Respond to subpoenas, court orders, search warrants, national security letters, or other lawful requests issued by courts, government agencies, or law enforcement authorities with appropriate jurisdiction
• Comply with legal obligations to which Sequoia Network, Inc. is subject, including regulatory reporting requirements, tax obligations, and statutory mandates

Protection of Rights and Safety:

• Protect the rights, property, safety, or security of Sequoia Network, Inc., our Users, employees, or the public
• Assist in the prevention or detection of crime, subject in each case to applicable law
• Investigate, prevent, or take action regarding suspected or actual illegal activities, fraud, security threats, or violations of the Terms of Use
• Establish, exercise, or defend legal claims in litigation, arbitration, or regulatory proceedings
• Mitigate our liability in an actual or threatened legal proceeding

Notice Where Permitted: Where legally permissible and operationally practicable, we attempt to provide affected Users with notice prior to disclosure of their Personal Information in response to legal process. However, we may be prohibited from providing such notice where a court order or legal process explicitly prohibits notification, where notification would obstruct an investigation or threaten safety, or where emergency circumstances require immediate action.

6.4 Business Transfers

In connection with significant business transactions, Personal Information may be disclosed to or acquired by third parties.

Transaction Types: Merger with or acquisition by another company; sale of all or substantially all Company assets; corporate restructuring, reorganization, or consolidation; financing, investment, or similar corporate transactions; bankruptcy, receivership, or insolvency proceedings.

Due Diligence: Personal Information may be shared with prospective acquirers, investors, or transaction parties during due diligence phases, subject to confidentiality agreements restricting use of such information to transaction evaluation purposes.

Successor Obligations: Personal Information transferred in connection with business transactions remains subject to this Privacy Policy until you receive notice of changed practices from the successor entity. We contractually require successor entities to honor existing privacy commitments, though such requirements may be limited or modified by bankruptcy court orders or governing transaction agreements.

6.5 Anonymized and Aggregate Data

We may create statistical, aggregate, de-identified, or anonymized data derived from Personal Information by removing or modifying identifying elements such that the resulting data cannot reasonably be used to identify specific individuals. Properly anonymized data is not considered Personal Information under applicable privacy laws.

Permitted Uses: We may use and disclose anonymized or aggregate data for any lawful business purpose, including industry trend reports and market analysis; academic or commercial research regarding relationships, social behavior, and online dating; marketing materials demonstrating Platform value and typical outcomes; and product development and machine learning model training.

Anonymization Standards: We employ technical measures designed to ensure anonymization is irreversible and that re-identification is not reasonably possible using available means, including data aggregation, generalization, suppression of outliers, and removal of unique identifiers.

No Re-identification: We do not attempt to re-identify anonymized data and contractually prohibit third parties receiving anonymized data from attempting re-identification.

We may also share personal information in hashed, non-human-readable form with advertising and analytics partners for the purposes described in Section 5.4.

6.6 User-Authorized Disclosures

We may disclose Personal Information to third parties when you explicitly authorize or direct such disclosure, including:

• Social Platform Integrations: Sharing data necessary to enable integrations you connect, such as posting content to a linked social account
• Data Exports: Providing data in response to your export or portability requests
• Sharing Features: Sharing your profile or content with third parties at your direction through in-Platform sharing functionality

Authorization may be withdrawn at any time by disconnecting the relevant integration, adjusting your settings, or contacting [email protected].

6.7 Statement Regarding Sale and Sharing of Personal Information

No Monetary Exchange: We do not exchange, rent, lease, or otherwise provide Personal Information to third parties for monetary consideration.

No Data Brokerage: We do not engage in data brokerage activities, do not provide Personal Information to marketing list compilers, and do not sell User profiles or contact information.

Cross-Context Behavioral Advertising: Certain disclosures of pseudonymous identifiers and usage data to advertising partners for the purpose of delivering personalized advertising may constitute a "sale" or "sharing" under the broad definitions of certain United States state privacy laws. Where applicable, we provide an opt-out mechanism through the "Your Privacy Choices" control in our website footer and application settings, and we honor recognized opt-out preference signals such as Global Privacy Control (GPC). See Section 10.2.5.

Sensitive Personal Information: We do not use or disclose Sensitive Personal Information for purposes other than those permitted under CPRA Section 1798.121 and analogous provisions of other applicable laws.

7.1 Cross-Border Data Processing

Sequoia Network, Inc. is headquartered in the United States, and our primary data processing operations are conducted within the United States. Personal Information collected through the Services is transferred to, stored in, and processed in the United States and potentially other jurisdictions where our service providers maintain operations.

Primary Processing Location: Personal Information is primarily stored and processed in data center facilities located within the United States operated by third-party cloud infrastructure providers engaged by us.

Global Service Provider Infrastructure: Certain service providers identified in Section 6 operate multi-jurisdictional infrastructure and may process Personal Information across various geographic locations as part of their ordinary service delivery operations.

Jurisdictional Differences: The United States and other jurisdictions where Personal Information may be processed may not provide the same level of data protection as the laws of your country or region of residence. In particular, United States government authorities may have broader surveillance and data access powers than authorities in other jurisdictions.

7.2 European Economic Area, United Kingdom, and Switzerland

For individuals located in the European Economic Area (EEA), United Kingdom, or Switzerland, we implement legally recognized transfer mechanisms and appropriate safeguards for Personal Information transferred from these regions to the United States or other third countries.

7.2.1 Legal Transfer Mechanisms

Adequacy Decisions: Where a transfer is made to a country benefiting from an adequacy decision issued by the European Commission or other competent authority, we rely on that adequacy decision.

Standard Contractual Clauses (Primary Mechanism): We rely on Standard Contractual Clauses (SCCs) as our primary legal mechanism for transferring Personal Information from the EEA, UK, or Switzerland to jurisdictions not subject to adequacy decisions under GDPR Article 45.

• European Commission SCCs: For transfers from the EEA, we implement the Standard Contractual Clauses for the transfer of personal data to third countries pursuant to Regulation (EU) 2016/679 (European Commission Implementing Decision (EU) 2021/914 of 4 June 2021).
• UK International Data Transfer Agreement: For transfers from the United Kingdom, we implement either (i) the UK International Data Transfer Agreement (IDTA) issued by the UK Information Commissioner's Office, or (ii) the UK Addendum to the EU Standard Contractual Clauses, as appropriate to the specific transfer arrangement.
• Swiss Data Transfer Provisions: For transfers from Switzerland, we implement the European Commission SCCs as modified and approved by the Swiss Federal Data Protection and Information Commissioner (FDPIC) for compliance with the Swiss Federal Act on Data Protection (FADP).

Data Processing Agreements: Where applicable, business partners and enterprise counterparties located in the EEA, UK, or Switzerland may execute our Data Processing Agreement (DPA), which incorporates applicable Standard Contractual Clauses and establishes the respective data protection obligations of parties. The DPA is available upon request to [email protected].

7.2.2 Supplementary Security Measures

In addition to implementing Standard Contractual Clauses, we apply supplementary technical and organizational measures to ensure appropriate protection for Personal Information transferred internationally, in accordance with recommendations from the European Data Protection Board (EDPB):

Strong Encryption: Personal Information is encrypted both during transmission (using TLS with strong cipher suites) and at rest (using encryption algorithms meeting industry standards). Encryption keys are managed through secure key management systems with restricted access controls.

Access Restrictions: Access to Personal Information is restricted to authorized personnel who require such access to perform their designated job functions, governed by role-based access control policies implementing the principle of least privilege.

Contractual Protections: Service providers processing Personal Information on our behalf are contractually obligated to implement appropriate security measures, limit processing to documented instructions, maintain confidentiality, and comply with applicable data protection requirements.

Data Minimization in Transfer: We transfer only the categories and volumes of Personal Information necessary to accomplish specified legitimate purposes.

Government Request Handling: We maintain procedures for reviewing the lawfulness of government requests for data, challenging overbroad or unlawful requests where legally permissible, and disclosing only the minimum data legally required.

7.3 International Transfer Risk Acknowledgment

Explicit Acknowledgment: By creating an account and using the Services, you acknowledge that:

• Personal Information will be transferred to and processed in the United States
• The United States may not provide equivalent data protection to your jurisdiction of residence
• United States government authorities may have legal powers to access Personal Information under circumstances that may not exist in other jurisdictions
• Despite implementation of Standard Contractual Clauses and supplementary safeguards, cross-border transfers inherently carry risks that differ from purely domestic processing

Not Consent for GDPR Purposes: This acknowledgment constitutes your informed understanding of cross-border transfer risks. For EEA, UK, and Swiss individuals, this acknowledgment does not constitute "consent" under GDPR Article 49(1)(a) as our legal basis for transfers. We rely on Standard Contractual Clauses described in Section 7.2.1 as our transfer mechanism for such individuals.

Right to Object: You may object to international transfers of your Personal Information. However, because our Platform infrastructure is deployed primarily in the United States, objection to international transfers may result in our inability to provide the Services to you. Contact [email protected] to discuss concerns regarding international transfers.

Sequoia Network, Inc. implements technical, administrative, and physical security measures designed to protect Personal Information from unauthorized access, use, disclosure, alteration, or destruction. While we employ security practices appropriate to the sensitivity of information processed and consistent with industry standards, no security system is impenetrable, and we cannot guarantee absolute security of Personal Information.

8.1 Technical Security Measures

8.1.1 Encryption and Cryptography

Encryption at Rest: Personal Information stored in production databases, media storage systems, and backup infrastructure is encrypted using industry-standard encryption algorithms. Encryption protects data confidentiality in the event of unauthorized physical access to storage media or improper data disposal.

Encryption in Transit: All transmission of Personal Information between end-user devices and our Platform, between Platform components, and between our Platform and integrated third-party services is protected using Transport Layer Security (TLS) encryption or equivalent cryptographic protocols. We do not support outdated or deprecated protocols known to have security vulnerabilities.

Cryptographic Key Management: Encryption keys are managed using dedicated key management services provided by our cloud infrastructure providers, with access restricted to authorized systems and personnel. Key management practices include logical separation of keys from encrypted data, regular key rotation where operationally feasible, and comprehensive audit logging of key access and usage.

Password Hashing: User passwords are never stored in recoverable plaintext form. Passwords are processed using cryptographic hash functions with computational complexity designed to resist brute-force attacks, rainbow table attacks, and other password recovery techniques. Each password is hashed with a unique cryptographic salt preventing identical passwords from producing identical hash values.

8.1.2 Network and Infrastructure Security

Network Access Controls: Platform infrastructure is protected by network firewalls and access control lists restricting inbound and outbound network traffic to authorized protocols, ports, and source addresses. Default-deny policies block unauthorized network communications.

Network Monitoring: We employ monitoring systems that analyze network traffic patterns, system logs, and authentication events to identify anomalous behavior potentially indicating security incidents, unauthorized access attempts, or system compromises.

DDoS Protection: Our cloud infrastructure providers implement Distributed Denial of Service (DDoS) protection mechanisms designed to detect and mitigate volumetric attacks, protocol attacks, and application-layer attacks targeting service availability.

Vulnerability Management: We conduct periodic vulnerability assessments of infrastructure and application code to identify known security vulnerabilities. Identified vulnerabilities are prioritized for remediation based on severity, exploitability, and potential impact.

Rate Limiting and Abuse Controls: We apply rate limiting, bot detection, and behavioral controls to registration, authentication, messaging, and other high-risk endpoints.

8.2 Administrative and Organizational Measures

• Role-based access control implementing the principle of least privilege
• Access review and revocation procedures upon role change or personnel departure
• Confidentiality obligations binding employees, contractors, and service providers
• Security awareness training for personnel with access to Personal Information
• Documented incident response procedures
• Periodic review of information collection, storage, and processing practices

8.3 Account Suspension for Suspected Compromise

We may suspend your use of all or part of the Services without prior notice if we suspect or detect a breach of security affecting your account or the Platform. If you believe that your account or information is no longer secure, notify us immediately by email at [email protected].

8.4 Security Disclaimer

NO GUARANTEE OF SECURITY: DESPITE IMPLEMENTATION OF THE SECURITY MEASURES DESCRIBED IN THIS SECTION, SEQUOIA NETWORK, INC. CANNOT AND DOES NOT GUARANTEE THAT PERSONAL INFORMATION WILL BE COMPLETELY SECURE FROM UNAUTHORIZED ACCESS, INTERCEPTION, ALTERATION, OR DESTRUCTION. NO METHOD OF TRANSMISSION OVER THE INTERNET OR METHOD OF ELECTRONIC STORAGE IS COMPLETELY SECURE.

USER ACKNOWLEDGMENT: BY USING THE SERVICES, YOU ACKNOWLEDGE AND ACCEPT THE INHERENT RISKS ASSOCIATED WITH ELECTRONIC DATA TRANSMISSION AND STORAGE. YOU AGREE THAT SEQUOIA NETWORK, INC. SHALL NOT BE LIABLE FOR ANY UNAUTHORIZED ACCESS TO, INTERCEPTION OF, OR ALTERATION OF PERSONAL INFORMATION, EXCEPT TO THE EXTENT SUCH LIABILITY CANNOT BE EXCLUDED UNDER APPLICABLE LAW.

9.1 Retention Principles

We retain Personal Information only for as long as necessary to fulfill the purposes for which it was collected, satisfy legal and regulatory retention requirements, and support legitimate business operations. Retention periods vary based on data category, applicable legal requirements, and ongoing business necessity.

9.2 Account Closure and Safety Retention Window

If you decide to stop using the Services, you may delete your account through the account settings interface or by contacting [email protected]. Upon deletion, your profile will no longer be visible to other Users.

Safety Retention Window: To protect the safety and security of our Users on and off the Services, we implement a safety retention window of six (6) months following account deletion. During this period, certain account information is retained to enable investigation of unlawful or harmful conduct that may come to light after account closure. Retention during this window is based on our legitimate interests and those of potential third-party victims.

Extended Window Following Ban: Where an account is closed as a result of a ban for violation of our Terms of Use or Community Guidelines, the safety retention window is extended to twelve (12) months following the ban.

Inactive Accounts: We may close your account automatically following a prolonged period of continuous inactivity. An account is considered inactive when the User has not accessed or interacted with the Services and the application has not established contact with our servers. Accounts holding an active paid subscription are not treated as inactive during the subscription term. Following automatic closure, the retention provisions of this Section apply.

9.3 Retention Periods by Data Category

9.3.1 Account and Profile Data

Active Accounts: Account and Profile Data are retained for the duration of the relationship while the account remains active.

Closed Accounts: Following account deletion and expiry of the applicable safety retention window, account and profile data are deleted or anonymized, subject to the exceptions in Section 9.5. Profile data may be retained for up to one (1) year in anticipation of potential litigation and for the establishment, exercise, or defense of legal claims.

9.3.2 User Content and Communications

Active Accounts: Messages and Content are retained for the duration of the account relationship to allow you and your correspondents to access your conversation history.

Following Deletion: Content and communications are deleted or anonymized following account deletion and expiry of the safety retention window. Note that messages you sent to another User form part of that User's conversation history and may remain visible to that User.

Content Associated with Banned Accounts: User-generated content associated with a banned account is retained for two (2) years to support enforcement, appeal handling, repeat-offender detection, and defense of legal claims.

9.3.3 Billing and Financial Records

Transaction Records: Records of subscription payments, invoices, billing statements, and payment history are retained for seven (7) years from the transaction date to satisfy tax documentation requirements, support financial audits, and enable dispute resolution.

Payment Methods: Tokenized payment method references are retained for the duration of the relationship plus twelve (12) months following termination. Complete payment card numbers are never stored by Sequoia Network, Inc.

Refunds and Chargebacks: Refund and chargeback records are retained for the duration necessary to resolve disputes and for the applicable statutory limitation period.

9.3.4 Security, Audit, and Traffic Data

Security and Audit Logs: Access logs recording authentication events, administrative actions, security events, and data access patterns are retained for a minimum of twelve (12) months and a maximum of twenty-four (24) months unless longer retention is required for security investigations, legal proceedings, or regulatory examinations.

Traffic Data: Certain "traffic data" is retained for one (1) year to comply with statutory data retention obligations in applicable jurisdictions.

Consent Records: Records of consents provided to our Terms of Use, Privacy Policy, cookie preferences, and similar consents are retained for five (5) years to demonstrate compliance with applicable law.

9.3.5 Safety, Moderation, and Anti-Abuse Data

Moderation and Enforcement Records: Records of reports, investigations, warnings, content removals, restrictions, suspensions, and bans, together with supporting evidence, are retained for two (2) years following the enforcement action, or longer where necessary for repeat-offender prevention or ongoing legal proceedings.

Ban Evasion Prevention Data: Data necessary to prevent Users who were banned for unsafe behavior, fraud, or serious Terms violations from creating new accounts — including device identifiers, IP addresses, and hashed contact identifiers — is retained for as long as necessary to ensure the safety and vital interests of our Users. Where an account was terminated for fraud or conduct materially damaging to the Services or its Users, IP address and device data may be retained indefinitely for the protection of the Services and our User community.

9.3.6 Customer Support Data

Customer support correspondence, tickets, and supporting records are retained for up to six (6) years from the date of communication, to enable us to address subsequent queries, support our decisions, enforce our rights, and defend against claims.

9.3.7 Verification Data

Facial Geometry Data: Deleted within thirty (30) days of the verification process, unless continued retention is necessary to comply with an applicable legal obligation, to investigate a safety or security incident, or to establish, exercise, or defend legal claims.

Government-Issued Identification: Retained only as long as necessary to complete verification and to satisfy related legal, safety, and dispute-resolution obligations, and in any event deleted promptly following completion of the verification purpose unless a legal obligation requires longer retention.

9.3.8 Technical and Usage Data

Application Logs: Technical logs recording system operations, user interactions, feature usage, error conditions, and performance metrics are retained for ninety (90) days unless extended retention is necessary for debugging critical issues, security investigations, or performance optimization initiatives.

Anonymized Analytics: Usage statistics, feature adoption metrics, and behavioral patterns that have been properly anonymized such that re-identification is not reasonably possible may be retained indefinitely for product development, business intelligence, and research purposes. This data is not attributable to an individual once the profile has been deleted.

9.4 Data Deletion Methods and Procedures

9.4.1 Automated Deletion Systems

Scheduled Deletion Processes: Automated deletion jobs execute on regular schedules to identify Personal Information exceeding defined retention periods and queue such information for secure deletion.

Deletion Verification: Deletion operations are logged with sufficient detail to verify successful completion, including record counts, categories of data deleted, deletion timestamps, and confirmation of completion status.

Technical Constraints: Although our systems are designed to carry out deletion in accordance with these guidelines, we cannot guarantee that all data, including data held in backup or replication systems, will be deleted within a specific time frame. Backup media are overwritten on rolling schedules, and data contained within them is deleted in the ordinary course of that rotation.

9.4.2 Manual Deletion Requests

Submission Methods: You may request deletion of your Personal Information through:

• The account settings interface, where self-service deletion is available
• Email request to [email protected] with subject line "Data Deletion Request"
• Written request to Sequoia Network, Inc. referencing this Privacy Policy

Processing Timeline: Deletion requests are processed within the following timeframes:

• GDPR Requests (EEA/UK/Swiss residents): Thirty (30) days from receipt and successful identity verification, extendable to sixty (60) days for complex requests with notice of extension
• CCPA Requests (California residents): Forty-five (45) days from receipt and successful identity verification, extendable by an additional forty-five (45) days for complex requests with notice of extension
• Other Jurisdictions: Sixty (60) days from receipt and successful identity verification unless a shorter timeframe is required by applicable law

9.5 Exceptions to Deletion and Extended Retention

Notwithstanding the retention periods in Section 9.3 and deletion requests under Section 9.4.2, we may retain Personal Information for longer periods or decline deletion where:

• Applicable statutes, regulations, or rules require retention
• Information is subject to pending litigation, arbitration, government investigations, or regulatory examinations
• Retention is necessary to detect, prevent, or investigate fraud, abuse of the Services, or violations of the Terms of Use, including preventing banned Users from creating new accounts
• Information is necessary to establish, exercise, or defend legal claims during applicable statute of limitations periods
• Retention is necessary to protect the vital interests of any person
• Deletion would infringe the rights of another User, including where the data also constitutes that User's personal data

Depending on your jurisdiction of residence, you may have legal rights regarding Personal Information we Process about you. This Section describes rights available under major data protection frameworks. The specific rights available to you depend on applicable law in your jurisdiction.

10.1 Rights Under the General Data Protection Regulation (GDPR)

Individuals located in the European Economic Area (EEA), United Kingdom, or Switzerland have the following rights under the GDPR, UK GDPR, or Swiss Federal Act on Data Protection:

10.1.1 Right of Access. You have the right to obtain confirmation whether we Process your Personal Data and, where we do, to access such Personal Data along with supplementary information including processing purposes, data categories, recipients, retention periods, and information source.

10.1.2 Right to Rectification. You have the right to obtain correction of inaccurate Personal Data and completion of incomplete Personal Data concerning you.

10.1.3 Right to Erasure. Subject to certain exceptions, you have the right to obtain erasure of Personal Data where processing is no longer necessary, you withdraw consent, you object to processing, processing is unlawful, or erasure is required for legal compliance.

10.1.4 Right to Restriction. You have the right to obtain restriction of processing where you contest accuracy, processing is unlawful but you oppose erasure, we no longer need the data but you require it for legal claims, or you have objected pending verification.

10.1.5 Right to Data Portability. You have the right to receive Personal Data you provided to us in a structured, commonly used, machine-readable format, and to transmit such data to another controller where processing is based on consent or contract and carried out by automated means.

10.1.6 Right to Object. You have the right to object to processing based on legitimate interests, including profiling, on grounds relating to your particular situation. We must cease processing unless we demonstrate compelling legitimate grounds overriding your interests, rights, and freedoms, or processing is necessary for legal claims. You have an unconditional right to object to processing of your Personal Data for direct marketing purposes at any time.

10.1.7 Right to Withdraw Consent. Where processing is based on consent, you may withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.

10.1.8 Rights Related to Automated Decision-Making. You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you, except in circumstances permitted by law. See Section 14.

10.1.9 Right to Lodge a Complaint. You have the right to lodge a complaint with a supervisory authority, as described in Section 20.

10.2 Rights Under California Consumer Privacy Act (CCPA/CPRA)

California residents have the following rights under the CCPA as amended by the CPRA:

10.2.1 Right to Know. You have the right to request disclosure, for the twelve-month period preceding your request, of: the categories of Personal Information we have collected about you; the categories of sources from which the information was collected; the business or commercial purposes for collecting, selling, or sharing the information; the categories of third parties to whom we disclose the information; and the specific pieces of Personal Information we have collected about you. You may exercise this right free of charge up to twice in any twelve-month period.

10.2.2 Right to Delete. You have the right to request deletion of Personal Information we collected from you, subject to statutory exceptions including legal obligations, security purposes, and completion of transactions.

10.2.3 Right to Correct. You may request correction of inaccurate Personal Information we maintain about you.

10.2.4 Right to Non-Discrimination. We do not discriminate against individuals for exercising CCPA rights. We will not deny Services, charge different prices, or provide a different level or quality of Services because you exercised your privacy rights, except where a difference is reasonably related to the value provided by your data and is permitted by law.

10.2.5 Right to Opt Out of Sale, Sharing, and Targeted Advertising. You may opt out of activities that may fall under the legal definitions of "targeted advertising," "sale," or "sharing" under applicable laws. Where we engage in such activities, we provide an opt-out control in the "Your Privacy Choices" link in the footer of our website and in the settings menu of our applications. We also honor recognized opt-out preference signals, including Global Privacy Control (GPC), where required by applicable law. Authorized agents may submit opt-out requests on behalf of consumers where permitted.

10.2.6 Right to Limit Use of Sensitive Personal Information. You may request that we limit the use and disclosure of Sensitive Personal Information to those purposes permitted by CPRA Section 1798.121.

10.2.7 Right to Appeal. Residents of jurisdictions providing an appeal right — including Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, and Virginia — may appeal a denial of a privacy request 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.

10.3 Tools Available Within the Services

We provide self-service tools that allow you to exercise many of your rights directly:

Access and Update Tools: Account settings that allow you to view, rectify, or delete information associated with your account directly within the Services.

Profile Visibility Controls: Settings governing what information is displayed on your profile and to whom.

Notification and Marketing Preferences: Settings governing which communications you receive, by which channel.

Device Permissions: Mobile operating systems provide permission systems for specific types of device data and notifications — including camera, photo library, contacts, location services, and push notifications. You may change these settings on your device at any time to grant or withdraw consent for the corresponding collection or notification. Withdrawing a permission may cause certain features to lose functionality.

Advertising Preferences: Controls governing personalized advertising, together with the device-level advertising identifier reset controls provided by your operating system.

Account Deletion: Functionality allowing you to delete your account directly within the Services.

If you have questions about these tools and settings, contact our customer care team at [email protected].

10.4 Exercising Your Rights

Email: [email protected] (subject line: "Privacy Rights Request")

Required Information in Request:

• Full name and, where applicable, username
• Email address associated with your account
• The specific right you wish to exercise
• Sufficient detail to allow us to locate your information
• Preferred response delivery method

Identity Verification: For your protection and the protection of all of our Users, we may ask you to provide information sufficient to verify your identity, or your authority to act on behalf of another individual, before we respond to a request. Responsive information will generally be delivered only to the email address assigned to the subject account. If there is no verifiable information associated with your account, we may be unable to complete your request.

Grounds for Rejection: We may reject requests, including where we are unable to authenticate you, where the request is unlawful, excessive, or manifestly unfounded, or where fulfilling it would infringe trade secrets, intellectual property, or the privacy or other rights of another person.

Requests Concerning Other Users: If you wish to receive information relating to another User — for example, a copy of messages you received from them — that User must submit their own request for their information, and we may require them to verify their identity before we respond.

Limits on Objection and Restriction: We may be unable to accommodate certain requests to object to or restrict processing where doing so would prevent us from providing the Services to you. For example, we cannot provide the Services without your date of birth, because we would be unable to verify that you are 18 years of age or older.

Authorized Agents: Where permitted by applicable law, an authorized agent may submit a request on your behalf, subject to proof of authorization and verification of your identity.

Sequoia Network, Inc. uses cookies, web beacons, pixel tags, software development kits (SDKs), local storage, and similar tracking technologies on the Meetville Platform to enable functionality, analyze usage patterns, deliver advertising, and support legitimate business operations.

11.1 Categories of Tracking Technologies We Use

11.1.1 Strictly Necessary Technologies

These technologies are essential for Platform operation and cannot be disabled without rendering the Services inoperable or severely impairing functionality.

Purpose and Use:

• Authentication: Maintaining logged-in sessions, verifying user identity, managing authentication state across Platform navigation
• Security: Preventing cross-site request forgery (CSRF) attacks, detecting suspicious activity patterns, protecting against unauthorized access, bot detection, and abuse prevention
• Session Management: Preserving application state during multi-step processes such as registration, profile creation, and checkout
• Load Balancing and Availability: Routing requests across infrastructure and maintaining service continuity

11.1.2 Functional and Preference Technologies

These technologies remember your settings and preferences, including language, locale, display preferences, notification settings, and previously entered information, to provide enhanced and personalized functionality.

11.1.3 Analytics and Performance Technologies

These technologies collect information about Platform usage patterns, performance metrics, and user interactions to support product improvement, issue identification, and performance optimization. They are used to understand which features are used, how Users navigate the Services, where errors occur, and how performance can be improved.

11.1.4 Advertising and Targeting Technologies

These technologies are used to deliver advertisements relevant to your interests, measure the effectiveness of advertising campaigns, attribute installations and conversions, limit the number of times you see a particular advertisement, and construct audiences for marketing purposes. They may be set by us or by third-party advertising partners, and may track your activity across websites and applications over time.

Third-party analytics and advertising providers collect information pursuant to their own privacy policies. Where required by applicable law, we obtain your consent before deploying non-essential cookies and similar technologies.

11.2 Managing Cookie Preferences

Consent Management: Where required by applicable law, we present a consent management interface allowing you to accept, reject, or configure non-essential cookie categories. You may change your preferences at any time through that interface.

Browser Controls: Most web browsers allow you to manage cookies through browser settings. You can typically view cookies stored on your device, delete all or specific cookies, block third-party cookies, and block all cookies from specific sites.

Mobile Device Controls: Mobile operating systems provide controls for resetting or limiting advertising identifiers (Google Advertising ID and Apple Identifier for Advertisers) and for restricting app tracking.

Consequences of Blocking: Blocking strictly necessary cookies will impair or prevent operation of the Services. Blocking other categories may reduce personalization and functionality but will not prevent basic access.

11.3 Do Not Track

As described in Section 3.4, the Platform does not currently respond to Do Not Track browser signals, as no uniform standard for such signals exists. We do honor Global Privacy Control (GPC) and other recognized opt-out preference signals where required by applicable law.

The Meetville Platform interacts with third-party services through integrations, may contain links to external websites, may display advertisements linking to third-party destinations, and relies on third-party service providers for certain functionality.

12.1 Outbound Links and Third-Party Content

If you access a website, application, or service provided by a third party — whether through a link in the Services, an advertisement, or content shared by another User — that third party may collect information about you. We do not own, control, operate, or monitor third-party websites or applications, and we are not responsible for their privacy practices, security, or content.

No Endorsement Implied: Inclusion of links or display of advertisements does not constitute endorsement, recommendation, approval, or representation regarding the accuracy, completeness, or reliability of third-party content; the quality, safety, or legality of third-party products or services; or the privacy practices or data security of third-party websites.

User Responsibility: Please refer to the privacy policies of each third party for information about how they collect and use information. This Privacy Policy does not apply to any exchange of information between you and any such third party. You access third-party websites at your own risk.

12.2 Third-Party Platform Operators

Where you download our applications from, or make purchases through, the Apple App Store, Google Play Store, or a similar platform, that platform operator processes information about you under its own terms and privacy policy. We receive only the information the platform operator makes available to us, such as transaction confirmations, entitlement data, subscription status, and aggregate performance metrics.

12.3 Social Authentication and Connected Accounts

Where you connect a third-party account to the Services, that third party's privacy policy governs its processing of your data. You may disconnect a linked account at any time through your account settings, though information already received by us will continue to be processed in accordance with this Policy until deleted under Section 9.

Age Restriction: The Meetville Platform is restricted to individuals who are eighteen (18) years of age or older. We do not permit individuals under the age of 18 on our Platform, and we do not knowingly collect Personal Information from anyone under the age of 18.

Age Verification: We collect date of birth at registration and use it to verify that you meet the minimum age requirement. We may apply additional age-assurance measures, including requesting government-issued identification, where we have reason to believe a User may be underage or where required by applicable law.

Reporting: If you suspect that a User is under the age of 18, please use the reporting mechanism available within the Services, or contact us at [email protected].

Action Upon Discovery: If we become aware that an individual under the age of 18 has registered with us and provided Personal Information, we will take steps to terminate that registration and delete the associated profile information from the Services promptly. Where we delete a profile for violation of our minimum-age requirement, we may retain limited account and technical identifiers for the purpose of preventing that individual from circumventing the restriction by creating a new account, and for the purpose of complying with legal reporting obligations. Such retained information is not used for commercial purposes, is not used for advertising or marketing, and is not sold or shared with third parties for commercial purposes.

Prohibition on Sale: We do not sell, and will not sell, the personal information of any individual we know to be under the age of 18.

Automated Processing: We use automated systems, including machine learning algorithms, to analyze profile data, interaction behavior, location, and stated preferences in order to generate match recommendations, rank and order content, personalize your experience, deliver relevant advertising, and detect fraudulent, abusive, or unsafe behavior.

Profiling for Recommendations: Match recommendations constitute profiling within the meaning of the GDPR. These recommendations do not produce legal effects concerning you and are designed to assist rather than replace your own decision-making — you retain complete discretion over whom you contact, engage with, or meet.

Automated Enforcement Decisions: Certain safety and integrity enforcement actions — including content removal, feature restriction, account suspension, and account termination — may be initiated by automated systems where the detected conduct meets defined criteria, in order to respond rapidly to harmful behavior at scale. Where such a decision significantly affects you, you have the right to request human review, to express your point of view, and to contest the decision by contacting [email protected] or by using the appeal mechanism available within the Services.

DISCLAIMER: Automated systems are imperfect and may produce errors including false positives and false negatives. Match recommendations do not constitute a representation regarding the identity, character, intentions, or safety of any User, and you remain solely responsible for your own decisions regarding interaction with other Users.

Incident Response: We maintain procedures for detecting, investigating, containing, and responding to security incidents affecting Personal Information.

Regulatory Notification: Where an incident constitutes a personal data breach under applicable law, we notify the relevant supervisory authorities within the timeframes required by applicable law — including, where the GDPR applies, without undue delay and where feasible within seventy-two (72) hours of becoming aware of the breach — and we notify affected individuals where the breach is likely to result in a high risk to their rights and freedoms or where otherwise required by applicable law.

Notification Method: Where individual notification is required, we will notify you at the email address associated with your account, through in-Platform notice, or by other means reasonably designed to reach you.

No Guarantee: Despite the security measures described in Section 8, we cannot guarantee that incidents will never occur. No security system is impenetrable.

We also process the personal information of job candidates, contractors, and vendor representatives as part of our recruitment and talent management operations and our management of services that contractors and vendors provide to us.

If you are a job candidate, contractor, or vendor representative of Sequoia Network, Inc., certain relevant provisions of this Privacy Policy apply to our processing of your personal information — including the sections identifying the entity responsible for processing, international transfers of personal information, rights you may have under applicable law, how to contact us, and California-specific provisions.

Job Candidates: The personal information we process about you may vary depending on the role you seek, but typically includes what you provide as part of your application, together with professional qualifications, employment history, background information, and reference information that recruiters or other third parties share with us. We use this information to support the recruitment process, which may lead to an employment contract, and to comply with applicable employment and equal opportunity laws.

Contractors and Vendor Representatives: We may process identification information and work-related information as necessary to manage our relationship with you and your employer, which is necessary for the performance of the applicable services agreement, and to establish, exercise, or defend potential legal claims.

Sharing: We may share personal information with service providers that assist us with recruitment, background verification, payroll, and technical data processing operations, and with other companies where you have a business relationship with them.

Retention: We keep this personal information only as long as necessary for the purposes described above and as required by applicable employment, tax, and limitation-period laws.

Corporate Transactions: In the event of a merger, acquisition, asset sale, reorganization, bankruptcy, or similar corporate transaction, Personal Information may be transferred to successor entities as a business asset.

Successor Obligations: This Privacy Policy continues to apply to previously collected Personal Information after transfer until you receive notice of changed practices from the successor entity.

Modification Rights: We may modify this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or business operations. When we post changes, we will revise the "Last Updated" date at the top of this Policy.

Material Changes: For material changes significantly affecting your privacy rights or expanding our collection, use, or disclosure of Personal Data, we will provide:

• Notice to the email address associated with your account at least thirty (30) days before the effective date, where feasible
• Conspicuous notice within the Services
• An updated Privacy Policy bearing a revised effective date

Prior Versions: Where a new version has been published but has not yet taken effect, the prior version continues to apply until the stated effective date.

Acceptance: Continued use of the Services after the effective date of changes constitutes acceptance of the revised Policy, except where applicable law requires affirmative consent, in which case we will obtain that consent before the change applies to you.

We recommend that you review this Privacy Policy periodically to remain informed of any changes to this Policy or our other policies.

19.1 Limitation of Liability

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW:

NO LIABILITY FOR USER CONDUCT: SEQUOIA NETWORK, INC. SHALL HAVE NO LIABILITY WHATSOEVER FOR THE CONDUCT OF ANY USER OF THE SERVICES, WHETHER ONLINE OR OFFLINE, INCLUDING BUT NOT LIMITED TO MISREPRESENTATION, FRAUD, HARASSMENT, ABUSE, THEFT, OR PHYSICAL HARM. YOUR INTERACTIONS WITH OTHER USERS ARE YOUR SOLE RESPONSIBILITY.

NO LIABILITY FOR USER-PUBLISHED CONTENT: SEQUOIA NETWORK, INC. SHALL NOT BE LIABLE FOR CONTENT PUBLISHED, TRANSMITTED, OR SHARED BY USERS, OR FOR THE SUBSEQUENT USE, COPYING, OR REDISTRIBUTION OF CONTENT YOU CHOOSE TO SHARE WITH OTHER USERS.

NO LIABILITY FOR MATCH OUTCOMES: SEQUOIA NETWORK, INC. SHALL NOT BE LIABLE FOR THE ACCURACY, RELEVANCE, OR OUTCOMES OF ANY MATCH RECOMMENDATION, COMPATIBILITY INDICATOR, OR SEARCH RESULT GENERATED BY THE PLATFORM.

NO LIABILITY FOR THIRD-PARTY SERVICES: SEQUOIA NETWORK, INC. SHALL NOT BE LIABLE FOR THE PRIVACY PRACTICES, SECURITY, CONTENT, OR CONDUCT OF ANY THIRD-PARTY WEBSITE, APPLICATION, PLATFORM OPERATOR, OR SERVICE PROVIDER.

EXCLUSION OF DAMAGES: IN NO EVENT SHALL SEQUOIA NETWORK, INC., ITS AFFILIATES, OFFICERS, DIRECTORS, EMPLOYEES, AGENTS, OR LICENSORS BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, PUNITIVE, OR EXEMPLARY DAMAGES, INCLUDING BUT NOT LIMITED TO DAMAGES FOR LOSS OF PROFITS, GOODWILL, USE, DATA, OR OTHER INTANGIBLE LOSSES, ARISING OUT OF OR RELATING TO YOUR USE OF OR INABILITY TO USE THE SERVICES, REGARDLESS OF WHETHER SUCH DAMAGES ARE BASED ON WARRANTY, CONTRACT, TORT (INCLUDING NEGLIGENCE), STATUTE, OR ANY OTHER LEGAL THEORY, AND WHETHER OR NOT WE HAVE BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.

MAXIMUM LIABILITY: TO THE EXTENT LIABILITY CANNOT BE COMPLETELY EXCLUDED UNDER APPLICABLE LAW, SEQUOIA NETWORK, INC.'S TOTAL CUMULATIVE LIABILITY FOR ALL CLAIMS ARISING OUT OF OR RELATING TO THIS PRIVACY POLICY OR THE SERVICES SHALL NOT EXCEED THE GREATER OF (A) THE AMOUNTS PAID BY YOU TO SEQUOIA NETWORK, INC. FOR THE SERVICES DURING THE TWELVE (12) MONTHS IMMEDIATELY PRECEDING THE EVENT GIVING RISE TO THE CLAIM, OR (B) ONE HUNDRED UNITED STATES DOLLARS ($100.00).

STATUTORY RIGHTS PRESERVED: NOTHING IN THIS SECTION LIMITS OR EXCLUDES ANY LIABILITY THAT CANNOT BE LIMITED OR EXCLUDED UNDER APPLICABLE LAW, INCLUDING LIABILITY UNDER MANDATORY CONSUMER PROTECTION OR DATA PROTECTION STATUTES. IF YOU ARE A CONSUMER RESIDING IN A JURISDICTION THAT PROHIBITS SUCH LIMITATIONS, THIS SECTION APPLIES TO YOU ONLY TO THE EXTENT PERMITTED BY THE LAW OF THAT JURISDICTION.

19.2 User Indemnification

YOU AGREE TO INDEMNIFY, DEFEND, AND HOLD HARMLESS SEQUOIA NETWORK, INC., ITS AFFILIATES, OFFICERS, DIRECTORS, EMPLOYEES, AGENTS, AND LICENSORS FROM AND AGAINST ANY AND ALL CLAIMS, DAMAGES, LOSSES, LIABILITIES, COSTS, AND EXPENSES (INCLUDING REASONABLE ATTORNEYS' FEES AND COSTS) ARISING OUT OF OR RELATING TO:

• YOUR USE OF OR RELIANCE ON THE SERVICES
• CONTENT YOU SUBMIT, PUBLISH, OR TRANSMIT THROUGH THE SERVICES
• YOUR INTERACTIONS WITH OTHER USERS, ONLINE OR IN PERSON
• YOUR VIOLATION OF APPLICABLE LAWS OR REGULATIONS
• YOUR VIOLATION OF THIS PRIVACY POLICY OR THE TERMS OF USE
• YOUR VIOLATION OF ANY RIGHTS OF THIRD PARTIES, INCLUDING PRIVACY, PUBLICITY, OR INTELLECTUAL PROPERTY RIGHTS

19.3 Acknowledgment of Risk

YOU EXPRESSLY ACKNOWLEDGE AND AGREE THAT:

• THE PLATFORM IS AN INTRODUCTION AND COMMUNICATION TOOL ONLY
• YOU BEAR SOLE RESPONSIBILITY FOR YOUR DECISIONS REGARDING OTHER USERS
• SEQUOIA NETWORK, INC. DOES NOT VERIFY THE IDENTITY, BACKGROUND, OR INTENTIONS OF ALL USERS
• YOU MUST EXERCISE INDEPENDENT JUDGMENT AND APPROPRIATE SAFETY PRECAUTIONS
• YOU ASSUME ALL RISKS ASSOCIATED WITH USE OF THE PLATFORM AND WITH INTERACTIONS INITIATED THROUGH IT

Direct Contact Encouraged: Before lodging a regulatory complaint, we encourage you to contact us directly at [email protected] so that we may attempt to resolve your concern informally.

Data Protection Authorities:

EEA Supervisory Authorities: Residents of the European Economic Area may lodge complaints with the data protection authority in their country of habitual residence, place of work, or the place of an alleged infringement. Contact information: https://www.edpb.europa.eu/about-edpb/who-we-are/edpb-members_en

UK Information Commissioner's Office: Website: https://ico.org.uk Telephone: +44 (0) 303 123 1113

Swiss Federal Data Protection and Information Commissioner: Website: https://www.edoeb.admin.ch Email: [email protected]

U.S. Regulatory Authorities:

Federal Trade Commission: Website: https://www.ftc.gov Complaint Portal: https://reportfraud.ftc.gov

California Privacy Protection Agency: Website: https://cppa.ca.gov

Right to Judicial Remedy: In certain countries, including in the European Economic Area and the United Kingdom, you have a right to an effective judicial remedy in addition to the right to lodge a complaint with a supervisory authority.

All privacy inquiries, data subject requests, consent withdrawals, security notifications, and other communications regarding this Privacy Policy should be sent by email to:

[email protected]

Subject Line Guidance: To ensure efficient routing, please include one of the following in your subject line, as applicable: "Privacy Inquiry," "Data Subject Request," "Data Deletion Request," "Privacy Rights Request," "Privacy Request Appeal," or "Security Notification."

Data Protection Officer: Sequoia Network, Inc. has designated a Data Protection Officer who may be reached at [email protected].

Response Time: We acknowledge inquiries within ten (10) business days and provide substantive responses within thirty (30) days, or within the timeframes specified by applicable law for specific request types as set out in Section 9.4.2.

Company Information:

• Legal Name: Sequoia Network, Inc.
• Registered Address: 1470 Civic Ct Ste 309, Concord, CA 94520-5230
• Incorporation: Delaware, United States
• Website: https://meetville.com
• Contact Email: [email protected]

Effective Date: January 1, 2024

Last Updated: July 23, 2026

Acceptance: By accessing or using the Meetville Platform, creating an account, or engaging with our Services on or after the Effective Date, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy, including all disclaimers, limitations of liability, and assumption of risk provisions contained herein.

Superseding Effect: This Privacy Policy supersedes all prior privacy policies, notices, or statements related to the Meetville Platform, except to the extent that prior versions govern Personal Information collected under such versions per Section 18 (no retroactive application unless legally required or consented to).

Complete Agreement: This Privacy Policy, together with our Terms of Use and any supplemental privacy notices provided at the point of collection, constitutes the complete agreement regarding privacy practices and data protection obligations.

Severability: If any provision of this Policy is found invalid, illegal, or unenforceable, it will be modified to the minimum extent necessary to make it valid and enforceable, or, if modification is not possible, severed. All other provisions remain in full force and effect.

Survival: Provisions that by their nature should survive termination of the Services or account closure will survive, including data retention obligations, limitation of liability, indemnification, dispute resolution, and governing law provisions.

Language: This Privacy Policy is drafted in English. Where we provide a translation, the English version controls in the event of any conflict, except where applicable law requires otherwise.