1. Introduction

Welcome to the Matter Privacy Policy. This Privacy Policy, as amended from time to time, sets out the basis on which Matter Group Inc. and its subsidiaries ("we", "us", "our" or "Matter") may collect, use, share or otherwise process personal information of our customers. Please carefully review this Privacy Policy to comprehend our practices and views with regards to your personal information and how we will handle it.

2. Who is responsible for your information?

The controller for your information, unless otherwise stated, is:

For more information about how to contact us, please see Section 17 below.

3. Scope of this Privacy Policy

This Privacy Policy applies to information we collect whenever you use our (a) websites (any page on the matter.dating domain, including https://matter.dating/); and (b) the Application or otherwise interact with us as described below (collectively, the "Services").

4. Content

By using the Services, you understand and agree that we are providing a platform for you to post and share text, audio recordings, graphics, photos or other materials (collectively referred to as "Contents"), to the Services and to create or share Content publicly within the Services. Please be advised that other users may search for, see, use, or share any of your Content that you make publicly available through the Services, consistent with the terms and conditions of this Privacy Policy and our Terms of Use.

5. Collection of information

We collect Contents, communications and other information you provide when you use the Services, including when you sign up for an account, create or share Content, and send voice or text message or otherwise communicate with others. Depending on the nature of your interaction with the Services, some examples of personal information which we may collect from you include:

Information we do not collect

• We do NOT record nor transcribe audio conversations during your Happy Hour blind dates.

  We host a one-hour, interactive Happy Hour sessions, where our users go on audio blind dates. Blind dates are live audio conversations between two users.

  Matter does not record nor transcribe audio conversations between our users during the Happy Hour blind dates. In this regard,

  • we do not collect any personal information that you share during these sessions;
  • during Happy Hour blind dates, without your help, we are not be able to detect or combat any offensive and harmful behaviors that violate our Community Rules. If you believe that a user is being offensive and harmful to you or others in our community, please use the reporting mechanism available within the Application. Please refer to our Community Rules to learn more.

• We do NOT record nor transcribe communications in audio rooms.

  With the help of our built-in tools (including blind dates, voice introduction etc.), once users match with another, they can create an audio room session where they can have live audio-conversations.

  Matter does not record nor transcribe audio-conversations made during these audio room sessions. In this regard,

  • we do not collect any personal information that you share during these sessions;
  • during a live-conversation in an audio room, without your help, we are not be able to detect or combat any offensive and harmful behaviors that violate our Community Rules Guidelines. If you believe that a user is being offensice and harmful to you or others in our community, please use the reporting mechanism available within the Application. Please refer to our Community Rules to learn more.

Information you choose to provide to us directly:

• Pre-registration: When you pre-register for the Services, we may collect your email address, gender, and school that you attend.
• Account Creation: When you create an account, we may collect your name, login credentials, email address, profile photos, what you are "looking for", as well as some basic details (such as your gender identity and date of birth) necessary for the Application to work.
• Profile Information: When you complete your profile, you may, at your sole discretion, choose to provide additional information, such as the details on your education, work, personality, lifestyle, preferences, interests and other details about you, as well as contents such as your voice introduction, photos and videos. To add certain Contents, such as your voice introduction, pictures or videos, you may allow us to access your device’s microphone, camera or photo album. Some of the information you choose to provide us may be considered "special" or "sensitive" in certain jurisdictions, for example your sexual orientation, health, racial or ethnic origins, religious beliefs or political views. By choosing to provide this type of personal information, you consent to our processing of that information.
• Text and voice messages: When you send to and receive from other users text and voice messages on the Application, we review the contents of these messages only if the recipient of your message or submit a complaint about you or report your account, or upload, sync or import your contact information. Each voice message is automatically deleted twelve (12) hours after the recipient listen to such voice message.
• Payment Information: When you subscribe to a paid service or make a purchase directly from us (rather than through a platform such as iOS or Android), we may collect personal information and details associated with your purchases, including payment information such as your debit or credit card number or other financial information. Any payments made through the Services are processed by a third-party payment processor. We do not directly collect or store any payment card information entered through our Services, but we may receive information associated with your payment card information (e.g., your billing details).
• Surveys: When you participate in surveys or market studies, we may collect certain information related to your insights into the Services, responses to our questions and testimonials.
• Your Communications with Us: If you contact us or our customer care team: (1) we may collect the information you choose to send to us, such as your name, email address, or account information; and (2) with your consent, we may access your messages within the Application that are directly or indirectly related to your complaints. We also may keep records of our communications with you, including any complaints that we receive from you about other users within the Application.
• Information about Others: If you ask us to communicate with or otherwise process information of other people (for example, if you ask us to send an email on your behalf to one of your friends), we collect the information about others that you give us in order to complete your request.
• Contents: We process your chats with other users as well as the Contents and images you post, publish or transmit when using the Application.

Information we receive from others:

In addition to the information you provide us directly, we receive information about you from others, including:

• Other users: We receive and analyze Content, communications and information that other people provide when they use the Services. This can include information about you, such as when other users like your Contents, send a text message to you, submit a complaint about you or report your account, or upload, sync or import your contact information.
• Social media and content streaming platforms: You may be able to connect your other internet service provider accounts including social media and content streaming platforms (including, but not limited to, Facebook, Instagram, Spotify, Netflix, Apple or Google Login) with the Application. This may allow you to publish your Contents from your social media accounts directly on your profile in the Application. The Contents published from your social media accounts may be used by the Application to personalize features and Contents and make suggestions for you (topics, voice introductions and thoughts you may be interested in and other users who are likely to match with you).
• Other partners: We may receive information about you from our partners, for instance where the Services advertisements are published on a partner’s websites and platforms (in which case they may pass along details on a campaign’s success).
• Other sources: We may also obtain information from other sources. We protect this information according to the practices described in this Privacy Policy, plus any additional restrictions imposed by the source of the data. These sources vary over time, but could include:
  1. third-party payment service providers who provide us with payment or balance information, or updates to that information, based on their relationship with you;
  2. security service providers who provide us with information to secure our systems, prevent fraud and help us protect the security of accounts in the Application; and
  3. online and offline data providers, from which we obtain aggregated demographic, interest based and online advertising related data.

Your usage of the Application:

When you use the Services, we may collect information about how you use the Services, such as the types of Contents (including thoughts, voice introductions and topics) you view or engage with (e.g. your thought creation, your voice introduction, swipes, views, clicks, skips, likes, searches or search parameters, advertising that you click on); the features you use; the actions you take, the people or accounts you interact with (e.g. users you block, users you connect and interact with, time and date of your exchanges, voice or text messages you send and receive); the time, frequency and duration of your activities.

Technical information:

When you use the Services, we may collect information from and about the device(s) you use to access the Services, including hardware and software information such as IP address, device ID and type, device-specific and apps settings and characteristics, app crashes, advertising IDs (such as Google’s AAID and Apple's IDFA, both of which are randomly generated numbers that you can reset by going into your device’ settings), browser type, version and language, operating system, time zones, identifiers associated with cookies or other technologies that may uniquely identify your device or browser (e.g., IMEI/UDID and MAC address).

Analytics information:

We may use third-party analytics tools to help us measure traffic and usage trends for the Services. These tools collect information sent by your device or the Services, including the sections of the Application and website that users visit, the thoughts and topics that users view, like and skip, aggregate user location statistical data, duration of use and other statistical data that assists us in continuously improving the Services. We collect and utilize this analytics information in the aggregate as it pertains to all of our users. As such, the analytics insights that we derive from our analytics data cannot reasonably be used to identify any particular individual user. Our analytics partners include Google Analytics. For more information, please visit Google Analytics’ Privacy Policy. To learn more about how to opt-out of Google Analytics’ use of your information, please click here.

Other information with your consent:

If you give us your consent, we will be able to collect your precise geolocation (latitude and longitude) in order to offer you features that make use of it. Such geolocation is collected through various means, depending on the service and device you’re using, including GPS, Bluetooth or Wi-Fi connections. If you decline permission for us to collect your geolocation, we will not collect it. If you give us your consent, we will be able to collect your precise geolocation (latitude and longitude) in order to offer you features that make use of it. Such geolocation is collected through various means, depending on the service and device you’re using, including GPS, Bluetooth or Wi-Fi connections. If you decline permission for us to collect your geolocation, we will not collect it.

6. Cookies and other tracking technologies

We may use web beacons (tracking pixels), cookies, and other tracking technologies ("Technologies") to collect information about you when you interact with our emails or the Application, including information about your browsing behavior on the Application. We use this information to make improvements to the Services and your experience, to observe features and areas of the Services that are more popular, understand the effectiveness of campaigns, count visits, and determine whether an email sent by us was opened and if hyperlinks contained in the email were clicked.

Our uses of these Technologies fall into the following general categories:

• Operationally Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular website behavior, prevent fraudulent activity and improve security or that allow you to make use of our functionality;
• Performance-Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how individuals use our Services (see Analytics below);
• Functionality-Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed;
• Advertising or Targeting-Related. We may use first party or third-party Technologies to deliver content, including ads relevant to your interests, on our Services or on third-party websites.

See Section 10 below to understand your choices regarding these Technologies.

7. Use of information

In addition to some of the specific uses of information we describe in this Privacy Policy, we collect, use and/or share your personal information for any or all of the following purposes:

• To manage your account, including creation and maintenance of your account in the Application.
• To personalize features and Contents (including your voice introduction and thoughts created on the Application) and make suggestions for you (voice introductions, topics and thoughts you may be interested in and other users who are likely to match with you) on the Services.
• To create personalized user experiences that are unique and relevant to you, we use your connections, voice introductions, text or voice messages, preferences, interests and activities based on the data we collect and learn from you and others (including any information with special protections you choose to provide); how you use and interact with the Services; and the people, places, or things you are interested and people you connect with on the Application.
• To determine your general geographic location, provide localized profiles, provide you with customized and personalized profile recommendations we think will be of interest to you.
• To secure our systems, prevent fraud and help us protect the security of accounts on the Services.
• To prevent, detect and investigate potentially prohibited or illegal activities, including fraud, and to enforce our Terms of Use.
• To develop, test and improve the Services, including by conducting surveys and research, and testing and troubleshooting new products and features of the Services.
• To analyze and understand our audience, develop and test new features of the Application, improve our Services (including our user interface experiences and service performance), diagnose or fix technology problems, and optimize content selection, recommendation algorithms and delivery.
• To process payment or credit transactions.
• To comply with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority.
• To communicate with you concerning our Services so that we can send you news about the Services, details about new features and content available on the Services, special offers, promotional announcements, consumer surveys, and to assist you with operational requests such as password reset requests. These communications may be by various methods, such as email, push notifications, text or voice message, online messaging channels, and matched identifier communications.
• For other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.
• To create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, information about the device from which you access our Services, or other analyses we create.

8. Sharing of information

We share your information for certain purposes and to third parties, as described below:

• Other users:

  We share your information with other users within the Application when you voluntarily share your information on the Application (including your profile). Please be careful with your information and make sure that the information and the Contents you share are things that you are comfortable being publicly viewable since neither you nor we can control what others do with your information once you share it in the Application.

• Service Providers:

  We may use other companies, agents or contractors ("Service Providers") to perform services on our behalf or to assist us with the provision of services to you. For example, we may engage Service Providers to provide marketing, advertising, communications, security, infrastructure and IT services, to customize, personalize and optimize our service, to provide bank account or balance information, to process credit card transactions or other payment methods, to provide customer service, to analyze and enhance data (including data about users' interactions with our service), and to process and administer consumer surveys. In the course of providing such services, these Service Providers may have access to your personal or other information. We do not authorize them to use or disclose your personal information except in connection with providing their services (which includes maintaining and improving their services).

• Business transfers:

  In connection with any reorganization, restructuring, merger or sale, or other transfer of assets, we will transfer information, including personal information, provided that the receiving party agrees to respect your personal information in a manner that is consistent with this Privacy Policy.

• Compliance:

  We may share and otherwise use your personal and other information where we reasonably believe such disclosure is needed to (a) satisfy any applicable law, regulation, legal process, or governmental request, (b) enforce applicable terms of use, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address illegal or suspected illegal activities (including payment fraud), security or technical issues, or (d) protect against harm to the rights, property or safety of the Application, its users or the public, as required or permitted by law.

• Permitted disclosure:

  You may also choose to disclose your information in the following ways:

  • the Application may contain a tool which gives you the option to share information by email, text message and social or other sharing applications, using the clients and applications on your smart device; and
  • social plugins and similar technologies allow you to share information.
  Social plugins and social applications are operated by the social networks themselves, and are subject to their terms of use and privacy policies.

• Other users: We share your information with other users within the Application when you voluntarily share your information on the Application (including your profile). Please be careful with your information and make sure that the information and the Contents (including your voice introduction) you share are things that you are comfortable being publicly viewable since neither you nor we can control what others do with your information once you share it in the Application.
• Service Providers: We may use other companies, third parties, agents or contractors ("Service Providers") to perform services on our behalf or to assist us with the provision of services to you. For example, we may engage Service Providers to provide marketing, advertising, communications, security, infrastructure and IT services, to customize, personalize and optimize our service, to provide bank account or balance information, to process credit card transactions or other payment methods, to provide customer service, to analyze and enhance data (including data about users' interactions with our service), and to process and administer consumer surveys. In the course of providing such services, these Service Providers may have access to your personal or other information. We do not authorize them to use or disclose your personal information except in connection with providing their services (which includes maintaining and improving their services).
• Affiliates: We may share your personal information with our company affiliates, for our administrative purpose including activities such as IT management, for them to provide services to you, or support and supplement the Services we provide.
• APIs/SDKs: We may use third-party Application Program Interfaces ("APIs") and software development kits ("SDKs") as part of the functionality of our Services. For more information about our use of APIs and SDKs, please contact us as set forth below.
• Business transfers: In connection with any reorganization, restructuring, merger or sale, or other transfer of assets, we will transfer information, including personal information, provided that the receiving party agrees to respect your personal information in a manner that is consistent with this Privacy Policy.
• Compliance: We may share and otherwise use your personal and other information where we reasonably believe such disclosure is needed to (a) satisfy any applicable law, regulation, legal process, or governmental request, (b) enforce applicable terms of use, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address illegal or suspected illegal activities (including payment fraud), security or technical issues, or (d) protect against harm to the rights, property or safety of the Application, its users or the public, as required or permitted by law.
• Permitted disclosure: You may also choose to disclose your information in the following ways:
  • the Application may contain a tool which gives you the option to share information by email, text or voice message and social or other sharing applications, using the clients and applications on your smart device; and
  • social plugins and similar technologies allow you to share information.
  Social plugins and social applications are operated by the social networks themselves, and are subject to their terms of use and privacy policies.

9. Storage of information

• We keep your personal information only as long as we need it for legitimate business purposes as laid out in Section 7 (Use of Information) above and as permitted by applicable law.
• We delete or anonymize your information upon deletion of your account in the Application, unless:
  • we must keep it to comply with applicable law;
  • we must keep it to evidence our compliance with applicable law;
  • there is an outstanding or potential issue, claim or dispute requiring us to keep the relevant information until it is resolved; or
  • the information is kept for our legitimate business interests, such as fraud prevention and enhancing users' safety and security. For example, information may need to be kept to prevent a user who was banned for unsafe behavior or security incidents from opening a new account.

10. Your choices

• Email and text messages: If you no longer want to receive certain communications from us via email, simply click the "unsubscribe" link in the email. Please note that you cannot unsubscribe from service-related correspondence from us, such as emails relating to your account transactions. You may opt out of receiving text messages from us by following the instructions in the text message you have received from us or by otherwise contacting us.
• Push notifications: You can choose to receive mobile push notifications from the Application. On some device operating systems, you will be automatically enrolled in the notifications. If you subsequently decide you no longer wish to receive these notifications, you can use your mobile device's settings functionality to turn them off. We also offer push notifications on certain web browsers. If you agree to receive those notifications and subsequently decide you no longer wish to receive these notifications, you can use your browser’s settings to turn them off. With your consent, we may also collect precise location-based information if you use our mobile application. You may opt out of this collection by changing the settings on your mobile device.
• "Do Not Track": Do Not Track ("DNT") is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
• Access and update: We provide tools and account settings that help you to access, rectify or delete information that you provided to us and that are associated with your account directly within the Application. If you have any questions on those tools and settings, please contact our customer care team via the Help & Support function within the Application or via email at privacy@matter.dating.
• Deletion: You can delete your account by using the corresponding functionality within the "Settings" portion of the Application or by contacting our customer care team via the Help & Support function within the Application.

11. Your privacy rights

In accordance with applicable law, you may have the right to:

• Access Personal Information about you, including: (i) confirming whether we are processing your personal information; (ii) obtaining access to or a copy of your personal information;
• Request Correction of your personal information where it is inaccurate, incomplete or outdated. In some cases, we may provide self-service tools that enable you to update your personal information;
• Request Deletion, Anonymization or Blocking of your personal information when processing is based on your consent or when processing is unnecessary, excessive or noncompliant;
• Request Restriction of or Object to our processing of your personal information when processing is noncompliant;
• Withdraw your Consent to our processing of your personal information. If you refrain from providing personal information or withdraw your consent to processing, some features of our Service may not be available;
• Request data portability and receive an electronic copy of personal information that you have provided to us; and
• Be informed about third parties with which your personal information has been shared.
• Requests: For all your privacy related requests, or if you have a question regarding our privacy practices, please contact our customer care team via Help & Support function within the Application or via email at privacy@matter.dating. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. For your protection and the protection of all of our users, we may ask you to provide proof of identity before we can answer your privacy requests. We may reject requests that are unreasonable or not required by law, including those that would be extremely impractical, could require disproportionate technical effort, or could expose us to operational risks such as free trial fraud.
• Retention of personal information: We may retain information as required or permitted by applicable laws and regulations, including to honor your choices, for our billing or records purposes, to resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and to fulfill the purposes described in this Privacy Policy. We endeavor to destroy or de-identify personal information in a secure manner when it is no longer required.

12. Security

We use reasonable administrative, logical, physical and managerial measures to safeguard your personal information against loss, theft and unauthorized access, use and modification. These measures are designed to provide a level of security appropriate to the risks of processing your personal information. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure.

By using our Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our Services, by mail or by sending an email to you.

13. Children’s Privacy

Our services are restricted to users who are 18 years of age or older. We do not permit users under the age of 18 on the Application and we do not intentionally collect personal information from anyone under the age of 18. If you suspect that a user is under the age of 18, please use the reporting mechanism available within the Application. If you are a parent or guardian and wish to review information collected from your child, or have that information modified or deleted, you may contact us as described below. If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it, and terminate the child’s account.

14. Third-Party Websites and Applications

The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.

15. Supervisory Authority

If you are located in the European Economic Area, Switzerland, the United Kingdom or Brazil, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.

16. Changes to this Privacy Policy

To realize our commitment to help our customers to build meaning relationships, we strive to continue innovating and improving our products and services. In this regard, we may make changes to this Privacy Policy from time to time. If we do make changes, we will inform you by sending an email to you or posting a notice of statement within Matter. Once the changes are made to this Privacy Policy, we will update the last revised date at the top of this Privacy Policy.

17. Contact Us

We hope that this document clarifies any privacy or security concerns that you might have. If you have any further questions or concerns about this Privacy Policy, please do not hesitate to contact us at privacy@matter.dating.

18. Supplemental Notice for Nevada Residents

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Information to third parties who intend to license or sell that Personal Information. You can exercise this right by contacting us at privacy@matter.dating with the subject line "Nevada Do Not Sell Request" and providing us with your name and the email address associated with your account. Please note that we do not currently sell your Personal Information as sales are defined in Nevada Revised Statutes Chapter 603A.

19. Effective date

This Privacy Policy was last updated on 17 September 2021.