This Privacy Policy describes the privacy practices of Sondr, Inc. (“Sondr”, “us”, “our” or “we”) with respect to your information collected, stored, disclosed and used by Sondr, through our Platform, App or Services, (as each term is defined in the Terms of Service posted at www.sondr.com/___________.

YOUR USE OF OUR PLATFORM, APP AND SERVICES IS SUBJECT TO THIS PRIVACY POLICY, END USER LICENSE AGREEMENT AND THE TERMS OF SERVICE. BY USING OUR PLATFORM, APP AND SERVICES, YOU ARE ACCEPTING THE PRACTICES SET OUT IN THIS PRIVACY POLICY.

If we decide to change our Privacy Policy, we will post those changes to this page and any other places we deem Appropriate so that you are aware of what personal information we collect, how we use it, and under what circumstances, if any, we disclose it.

The effective date of this Privacy Policy is noted below. We reserve the right to modify this Privacy Policy at any time, so please review it frequently. If we make material changes to this Privacy Policy, we will notify you here, or by other means, such as e-mail, at our discretion. Your continued use of any portion of our Platform, App or Services following the posting of the updated Privacy Policy will constitute your acceptance of the changes.

In order to provide our Services, we collect information about you that, alone or in combination with other information, can be used to identify you as an individual (“personal information”). What personal information we collect and process depends on how and why you interact with us.

The technologies we use to automatically collect data from you may include:

We use information that we collect about you or that you provide to us, including any personal information, to:

• Provide, secure and improve our Services;
• Establish and manage Member accounts, such as your “Member Profile”;
• Display the public fields of your Member Profile to your introductions and matches, including recent login date, user name, photos, videos, and other profile content;
• Provide customer support, troubleshoot issues, manage our Services, and respond to requests, questions, and comments;
• Process transactions;
• Communicate with you about our Services, including order confirmation, refund and renewal processing, notifying of introductions and matches for our Services, service announcements and administrative messages;
• Communicate with you regarding promotions, including newsletters, new product offerings, special discounts, event notifications, special third-party offers;
• Conduct market and consumer research and trend analyses;
• Enable posting on our blogs, forums, and other public communications;
• Present webinars and other interactive events;
• Perform accounting, auditing, billing, reconciliation, and collection activities;
• Prevent, detect, identify, investigate, and respond to potential or actual claims, liabilities, prohibited behavior, and criminal activity;
• Comply with and enforce legal requirements, agreements, and policies;
• Achieve purposes for which we provide specific notice at the time of collection; and
• For any other purpose with your consent.

One of the methods we use to communicate with you in connection with our Services may be by telephone or text message (including to any wireless number you may provide to us). For example, you may sign up for a text messaging service (“SMS Verification”) which enables Sondr to verify your phone number via a confirmed text message and display such verification in your public account (as a security measure for your matches’ benefit). If you would rather not receive telephone calls or text messages from us, you may change or delete your number from your account preferences page(s), or ask to be removed from our contact list if you receive a call or text message from us. You may also opt-out of the SMS Verification service at any time.

In addition to the uses outlined above, by accessing or using our Services, you agree to allow us to anonymously use the information from you and your experiences to continue our research into social networking and successful relationships. This research may be published. However, all of your responses will be kept anonymous, and no personal information will be published.

We will send you push notifications if you choose to receive them for purposes of receiving notice of introductions and matches for our Services, letting you know when someone has sent you a message, or for other Service-related matters. If you wish to opt-out from receiving these types of communications you may turn them off at the device level.

If you do not provide us with the personal information we request, this may limit our ability to fulfill the applicable purpose for collection and the services we are able to provide you. For example, we may not be able to consider or process your payment, introduce you to or match you with other Members or provide a particular service you have requested.

In general, we may share personal information we collect:

• With current and future entities that are part of our network for the purposes described in this Privacy Policy, including with your consent;
• With affiliated and unaffiliated service providers who help us perform and deliver our Services, subject to agreements, including: customer care agents; technology assistants; service fulfillment; form processing; website management and hosting; information technology and security; email and newsletter delivery; advertisement partners and corporate sponsors; auditing; and credit card processing;
• With the appropriate authorities if we believe disclosure is necessary and appropriate to prevent physical, financial, or other harm, injury, or loss, including to protect against fraud or credit risk;
• With legal, governmental, or judicial authorities as instructed or required by those authorities and applicable laws, or in relation to a legal activity, such as in response to a subpoena or investigation of suspected illicit or illegal activities, or where we believe in good faith that users may be engaged in illicit or illegal activities, or where we are bound by contract or law to enable a network partner to comply with applicable laws;
• With necessary third parties in connection with, or during negotiations for, an acquisition, merger, asset sale, or other similar business transfer that involves all or substantially all of our assets or functions where personal information is transferred or shared as part of the business assets;
• With your consent or at your direction, such as when you choose to share information or publicly post content and reviews (for example, social media posts); and
• With persons of your choosing and at your discretion, should the Services you are subscribed to allow that functionality.

In addition, Sondr may disclose personal information as follows.

• To Your Introductions and Matches. As an integral part of providing some of our Services, we will disclose your profile information (including, but not limited to, last login date, whether you are currently online, your compatibility score) to your introductions and matches. Photos and other profile information posted by you will be available to Members that are introduced to you or matched with you. We never share your contact information with your introductions or matches.
• To Comply with Valid Legal Requests. You acknowledge and agree that we may disclose information you provide if required to do so by law, or if we, in our sole discretion, believe that disclosure is reasonable to (1) comply with the law, requests or orders from law enforcement, or any legal process (whether or not such disclosure is required by applicable law); (2) protect or defend Sondr’s, or a third party’s, rights or property; or (3) protect someone’s health or safety, such as when harm or violence against any person (including you) is threatened.
• To Protect Abuse Victims. Notwithstanding any other provision of this Privacy Policy or our Terms of Service, we reserve the right, but have no obligation, to disclose any information that you submit to the Services, if in our sole opinion, we suspect or have reason to suspect, that the information involves a party who may be the victim of abuse in any form. Abuse may include, without limitation, elder abuse, child abuse, spousal abuse, neglect, or domestic violence. Information may be disclosed to authorities that we, in our sole discretion, deem Appropriate to handle such disclosure. Appropriate authorities may include, without limitation, law enforcement agencies, child protection agencies, or court officials. You hereby acknowledge and agree that we are permitted to make such disclosure.
• To Trusted Third Parties By Us. We may share your information with third parties, but not in a manner that would reveal your identity. We may share your personal information, sometimes in conjunction with non-identifying information, with service providers that may be associated with us to perform functions on our behalf. For example, outsourced customer care agents or technology assistants may need access to your information to perform services for you. Your information will be treated as private and confidential by such service providers and not used for any other purpose than we authorize.
• To Transfer As a Result of Sale of Business. As we develop our business, we may buy or sell assets and, depending on the transaction, your personal information may be one of the transferred assets. In the event that we are acquired by another company, your personal information may be part of the assets transferred to the acquiring party. If this occurs, you will be notified if there are any material changes to the way your personal information is collected or used.

We process all information, including your personal information, via our servers and networks located in the United States. However, some of our service providers may be located in other jurisdictions. By using our Services and expressly assenting to this privacy policy, you have consented to the transfer of your personal information solely for the purpose of providing you the Services for which you have registered or to which you have subscribed. We take all reasonable steps to ensure that all overseas recipients will not hold, use or disclose your personal information inconsistently with applicable law.

We may use third-party advertising agencies or other service providers to serve ads on our Platform on behalf of Sondr. These companies may employ cookies or pixels to measure advertising effectiveness. Any information that these third parties collect via cookies and pixels is anonymous. Some of these third-party advertising agencies may be members of the Digital Advertising Alliance, which offers you the option to opt out of ad targeting from its member agencies by following the procedures listed here at https://optout.aboutads.info/ or for Applications, access the App Choices Platform here at https://youradchoices.com/choices.

We will only share your information with third parties in the ways defined in this Privacy Policy.

We only accept registrations to our Services from users who are 18 years or older (or the age of majority in applicable jurisdictions, if higher), and any information we may receive from Members we believe to be under the age of 18 will be purged from our database. If you believe that we may have collected any such personal information through our Services, please notify us as specified below.

We may also use services provided by third-party websites (such as social networking and other websites) to serve targeted advertisements on such websites to you or others, and we may provide a hashed version of your email address or other information to the website operator or provider for such purposes. To opt-out of the use of your information for such purposes, please email us at ______________@Sondr.

We store information in a combination of electronic storage facilities, paper-based files and other records. While we cannot guarantee your personal information is completely secure at all times, we have administrative, organizational, technical, and physical security measures in place to help protect against the loss, misuse and alteration of the information collected and processed. These measures include the use of firewalls, digital certificates, Security Socket Layer (SSL) and encryption technology during credit card transactions and administrative access to website data, as well as other proprietary security measures which are applied to all repositories and transfers of Member information.

We do not process or respond to web browsers’ “do not track” signals or other similar transmissions that indicate a request to disable online tracking of users who use or visit our Platform and use our App. You may, however, disable certain tracking as discussed above (e.g., by disabling cookies). Please consult the “Help” section of your internet browser for more information.

You may be able to access your account or content of your account from third party websites or platforms, such as social networking websites, by way of various applications. These services will authenticate your identity and provide you with the option to share certain personal information with us such as your name and email address to pre-populate our registration form. The privacy policies and practices of such websites in connection with information you disclose on such websites may differ from the practices of Sondr as set forth in this Privacy Policy. We are not responsible for the privacy policies or practices or the content of any other Platforms that may provide access to, or be linked to or from, our Services, including that of any social networking websites.

You may use the following options for removing your information from our e-mail database if you wish to opt out of receiving promotional emails.

We provide Members the following options to access, change, correct, update or delete personal information previously submitted to us.

We retain your personal information for as long as necessary to fulfill the purpose(s) for which it was collected and to comply with applicable laws, and your consent to such purpose(s) remains valid after termination of your relationship with us. Except for information required for accounting or record-keeping purposes, we will automatically delete your personal information after 12 months of inactivity as a Member (as defined in the Terms of Service) unless we have a valid reason to retain such information.

Your personal information may be processed and stored outside of the jurisdiction or country in which you reside by us, an affiliate or an unaffiliated service provider for the purposes set out in this Privacy Policy and, under the laws of these other jurisdictions, in certain circumstances foreign courts, law enforcement agencies or regulatory agencies may be entitled to access your personal information.

If you have any questions about this Privacy Policy or our privacy practices, you can contact us by writing to:

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact us at the address or email address listed above.

This Section 17 of this Privacy Policy is applicable only to California residents.

California Consumer Rights

Effective January 1, 2020, under the California Consumer Privacy Act (“CCPA”), California residents have the right to know what categories of personal information we generally collect, use, disclose, and/or sell about them within the past 12 months. California residents have the right to know where that information came from, the business or commercial purposes for the collection, and the categories of third parties with and/or to whom that information was shared and/or sold within the past 12 months. Throughout this Privacy Policy, and specifically in this section, we have set out our policies and processes as it relates to the collection, use and disclosure of your personal information.

California residents also have the right to request access to that information on an individual level, to remove their personal information in accordance with Applicable laws. Consumers who have a visual disability may be able to use a screen reader or other text-to-speech or text-to-Braille tool to review the contents of this notice.

Data Access Request

If you are a California consumer and you would like to submit a request to exercise your right to know what personal information Sondr has collected, used or disclosed to third parties in the 12-month period prior to your request, you can make a request by sending an email to _______________@Sondr with "CCPA Request" in the subject line, along with your email address and phone number used to sign up to the App. Please be sure specify in your request the details you would like to know, including any specific pieces of personal information you would like to access.

Please note that your right to know can be exercised without justification and free of charge. However, we may request a fee, notably when requests are unfounded, excessive or have a repetitive character. We are not required to provide access to personal information more than twice in 12 months.

Data Deletion Request

If you are a California consumer and a Member (as defined in our Terms of Service) and would like to exercise your personal data deletion rights, you can log into your account in the App, visit Settings, and click Delete Account. Please note that this deletion on your own is only possible on our App and not in our website. If you cannot log into the App, you need to submit a data deletion request as described below.

To submit a data deletion request, please send an email to ______________@sondr.com with "CCPA Deletion Request" in the subject line, along with your email address and phone number used to sign up to the App.

Please note that your right to deletion can be exercised without justification and free of charge. However, we may request a fee, notably when requests are unfounded, excessive or have a repetitive character. We are not required to comply with your request to deletion in the following circumstances: (i) to perform our contract with you, (ii) to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for the activity, (iii) to debug to identify and repair errors that impair existing intended functionality, and/or (iv) to comply with our obligation to maintain records of consumer requests made pursuant to the CCPA.

Verification Process

To protect your privacy, we must first verify your identity before we can respond to and process your request for access to specific data or to delete data. To do that and if you are a Member, please login and send us your request through one of the contact links above that we can easily identify you. If you are not able to log in your profile before sending us your request, we will request certain account information that may include the following: the email address associated with your profile, your profile ID and your service password (that is not your personal password) in response to your request. Your profile ID and service password are assigned to you when you register to our Service. If you cannot provide us with such information, we will ask you to provide other account information to verify your identity. Requests to opt out of selling of personal information, if applicable, do not need to be verified and will be honored in accordance with applicable laws.

We will make good faith efforts to provide you with access to your data when you request it, but there may be circumstances in which we may not provide access or delete data as allowed by law. For example, we are not required to delete personal information needed to provide a service you’ve asked us to provide, to detect fraudulent or illegal activity, required for bookkeeping or tax purposes (e.g., transaction data), or required for legal purposes. Also, we are not required to provide access to information that contains legal privilege, where your identity could not be verified, or where the information would compromise others’ privacy or other legitimate rights, like intellectual property rights. If we determine that your request for access or deletion should be denied or restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries.

Authorized Agent

If you wish to designate an authorized agent to make a request on your behalf, please let us know when you make your request. You can designate an authorized agent to make a request under the CCPA on your behalf if: (i) the authorized agent is a natural person or a business entity registered with the Secretary of State of California; and (ii) you sign a written declaration that you authorize the authorized agent to act on your behalf.

If you use an authorized agent to submit a request to exercise your right to know or your right to request deletion, please take the following steps:

• Mail your written declaration authorizing the authorized agent to act on your behalf, certified by a California notary public, to this address: Sondr, Inc., ________________________, Attn: CCPA Request; and
• Provide any information we request as described above and/or in our response to verify your identity.

Non-Member / Visitor

If you are a California consumer and a non-Member or visitor to our Platform and you would like to exercise your right to know or your right to deletion: please note that we only collect, use, and disclose non-name identifying information. For this reason, we do not have a reasonable method by which we could verify your identity, or individually verify all the members of a household, to the degree of certainty required under CCPA. Therefore, we are not able to comply with your request.

Data Retention

Personal data of Members will be stored for the duration of your membership. However, we will erase your data at your request, provided that there is no statutory storage obligation that Applies to that information. If your data is subject to a mandatory storage period, we will ensure that this information is isolated and stored until the expiration of the mandatory retention period. Once your membership is over, Sondr automatically erases personal profile data of Members who are inactive for 12 months.

Sondr will also store any personal data which is required to demonstrate that Sondr has lawfully complied with valid requests under the CCPA for the required period.

Additional Information

Any access or deletion requests that can be processed by us will be done so within 45 days from the date we receive your request unless we notify you that an extension is required. In case of an extended completion period, we will process your request within 90 days from the date of your original request. If we are unable to satisfactorily verify your identity, we will not be able to process your request.

We will not discriminate against you if you choose to exercise any of your privacy rights under California law.

Right to Opt-Out of the Sale of Personal Information

California residents also have the right to request that we limit or stop the “selling” (a broad word used to also include some types of sharing) of their personal information under certain circumstances. However, we do not engage in selling personal information.

Contact for More Information or Questions?

If you have any questions about this section or about exercising your rights described above, you can contact us by mailing us at:

This Privacy Policy was last revised on ___________, 2022.