Privacy Policy

PRIVATE POLICY OF ENCOUNTR

This is Encountr’s Privacy and Cookie Policy (“Policy”). This Policy applies to Encountr LLC, its parent companies, and its subsidiaries such as Encountr Canada Inc., which are referred to as “Encountr”, “we”, “us”, or “our” in this Policy. This Policy tells you how Encountr LLC handles and gives you control over your Personal Information. At Encountr, “Personal Information” means any information that can be used to identify, or reasonably link to, you directly or indirectly. When we talk about “processing” of Personal Information, we mean how we gather, use, share, and keep Personal Information. This policy covers these activities across all of our properties (“Properties” or “Encountr Properties”).

This policy covers the following Encountr Properties:

The Encountr applications and related features (the “Encountr App” or “App”) including web https://web.encountr.com (“Encountr Web”) and mobile platforms and any related services (collectively known as the “Encountr Services”), The websites https://www.encountr.com and https://encountr.gay (“Encountr Site”), The website https://encountrads.com (“Encountr Ads”), and The website https://encountrbloop.com (“Bloop Site”)

To review how we handle Personal Information of Encountr employees, contractors, and applicants, please click here to see our related processing practices.

Our Promise of Privacy. The Encountr Properties are a global LGTBQ+ social networking application that lets you share information about yourself with us, Encountr’s service providers who assist us in providing our Properties, and other Encountr users, including your exact location and information that may be considered “sensitive” or “special category” in some jurisdictions such as ethnicity, sex life, sexual preferences, or your self-reported health information. Our aim is to give you control over as much of the Personal Information that you share within the Encountr Properties as possible. We advise you to read this Privacy and Cookie Policy and our Terms and Conditions of Service carefully. To support our promise of ongoing transparency, in addition to regular updates to this Policy, within the Encountr Services you will see occasional pop-up privacy notices designed to help you understand what you are engaging in when you decide to use certain features or services.

Encountr LLC is a Company based in the U.S. When you use the Encountr Properties, you are sending information to Encountr in the United States and its service providers

(in the United States and other third countries). If you live in another country, be aware that the United States and other third countries may not offer the same privacy protections as your country of residence.

Allowed Age. The Encountr Properties are designed only for users who are legal adults, usually eighteen (18) years old and above. If you know that a child or minor has provided Personal Information on the Encountr Properties, please get in touch with us by either using the in-app reporting tool (click here for more details) or by sending a request outside of your Encountr account by clicking here, so that we can take suitable action.

If you are a resident of a U.S. state that grants you certain privacy rights under its laws, please refer to Your U.S. State Privacy Rights to find out what rights you have. This applies to you only if the laws in your state allow it.

HOW WE HANDLE YOUR PERSONAL INFORMATION: The main purpose of using your Personal Information is to enable the Encountr Properties, such as giving you access to core features of the Services, helping you with your issues, and ensuring platform security. We only process your Personal Information in line with specific purposes and legal grounds where necessary. [FIND OUT MORE]

In general, we use your Personal Information to:

Deliver the Services related to your Encountr account. Respond to your questions and provide you with assistance. Enhance our Properties and support user safety within the Services (including machine learning and automated decision-making). Safeguard our interests as a company. Enable you to use certain Service and Property features (including machine learning and automated decision making - click here for more information). Permit third-party ad / marketing partners to employ cookies and other technologies for the purposes of showing ads to free users of the Services. Carry out surveys or collect your voluntary feedback about our Properties. Comply with legal requests from law enforcement agencies, regulators, and other third-parties to fulfill “Legal Obligations”.

HOW WE MANAGE YOUR PERSONAL INFORMATION: The main reason we use your Personal Information is to enable the Encountr Properties, most of which you decide to provide. We may collect data about your interactions, use, and experiences with our Properties and receive information from third-parties.

Personal Information You Need to Provide. When you create an account, we need you to provide limited Personal Information such as email or phone number and date of birth to verify that you are an adult. Personal Information You Can Choose to Provide. You have an option about what Personal Information you provide as part of your public profile (“Encountr Profile”). Personal Information that you include in your Encountr Profile is called your “Profile Information” which is shared with other users of the Encountr Services (the “Encountr Community”). For example, you may choose to share location, HIV status, vaccination status, photos and videos. However, note that not providing certain information may affect the functionality of certain Encountr Services. You may also voluntarily provide Personal Information to us for feedback and customer support services or when you consent to participate in surveys. Such data differs from survey to survey. Note on “sensitive” Personal Information. In some jurisdictions and under some regulations, information that may disclose an individual’s racial or ethnic origin or details on their health or sex life/sexual orientation, among other data, may be regarded as “sensitive” or “special category” Personal Information. A note on location information. We may collect your exact location (“Location”) to determine your distance from other users (“Distance Information”). Advanced users who use the Encountr Services in an unauthorized way, or other users who change their location while you stay in the same location, may use Distance Information to figure out your precise location and may be able to identify you. You may choose to conceal your Distance Information; however, the Encountr Services will still sort and display your profile based on your relative distance from other users. Therefore, even if you choose to conceal your Distance Information, others may still be able to find out your Location. You may revoke this permission and disable the location services on your device on an iPhone by going to Settings> Privacy> Location Services> Encountr; on an Android device by going to Settings> Location> Encountr> Permissions> Location; and on Encountr Web by changing your browser settings. Personal Information We Receive From Your Device When You Use The Encountr Properties. To keep and improve the Encountr Properties, we collect Personal Information such as user activity, hardware and software information, cookies, and use other technologies such as web beacons, software development kits (SDKs), local storage, and log files. Personal Information We Receive From Third-Parties. Encountr collects limited information from third-parties. For example, we may collect Personal Information from payment processors, app usage and website tracking information partners, authentication partners (e.g., Google and Facebook), machine learning partners, and our consent management platform provider.

WHAT WE DO WITH YOUR PERSONAL INFORMATION: To help you make meaningful

connections, Encountr allows you to share information about yourself with the Encountr Community and third-parties in relation to our providing you with the Encountr Properties as explained in this Policy. In general, we share your Personal Information in the following ways:

The Encountr Community. The Encountr Services are designed to be a safe space where you can explore, navigate, and interact with others in the Encountr Community. As part of the Services, Encountr enables you to share your Profile Information, location, and other information with the Encountr Community. Third-Party Partners. Encountr shares Personal Information with a number of third-party partners to offer you the Encountr Properties, such as Service Providers (e.g., Sift for fraud prevention and PartnerHero for customer support), Ad / Marketing Partners help create advertising experiences (e.g., AppLovin), and Other Partners that support the Encountr Properties and with whom you may share Personal Information directly (e.g., Apple for chat back up and Stripe for payment processing). To be clear, Encountr only shares HIV status, Last Tested Date, and vaccination status with necessary Service Providers such as companies that store data on our behalf (i.e., Amazon Web Services) or help in handling data access requests you initiate ( i.e., PartnerHero) - we do not share this information with any advertising companies. NDBusiness Transactions. If another company buys, or plans to buy, our company, business, or assets, that company will own the Personal Information collected by us and will take on the rights and obligations regarding your Personal Information as described in this Policy. Legal Obligations. We may access, preserve and disclose Personal Information to investigate, prevent, or act in connection with: (i) enforcement of the Encountr Terms and Conditions of Service; (ii) allegations that any content or behavior breaches our policies or the rights of third-parties; (iii) demands for customer service; (iv) technical issues; (v) safeguarding the rights, property or personal safety of Encountr, its users or the public; (vi) lawful legal requests including subpoenas, warrants, or court orders or in relation to any legal process; (vii) asserting or exercising our legal rights or defending against legal claims; (viii) tax and accounting purposes; or (ix) as otherwise required by law, collectively "Legal Obligations".

HOW WE STORE YOUR PERSONAL INFORMATION: We keep your Personal Information for no longer than is needed to achieve the purposes for which the information was gathered or as otherwise allowed or pursuant to Legal Obligations or pursuant to the Encountr Terms and Conditions of Service and/or the Encountr Community Guidelines. We also keep a device identifier (i.e., IDFV and Android ID) and limited log information for up to a period of two years after account deletion to support internal reporting, metrics and statistics. Personal Information may be kept for longer periods of time if

needed for legal or security purposes. For example, Encountr may keep some account information, a device identifier (i.e., IDFV and Android ID), and limited log information for accounts that have been banned or that breach the Encountr Terms and Conditions of Service and/or Encountr Community Guidelines. In some situations, Encountr may also keep chat messages used for reporting violative behavior leading to an account’s ban.

Server-side and Local Storage: Encountr is moving to the storage of chat messages on its servers to support the use of the Encountr Services including enhanced safety features and a better user experience across multiple platforms and devices, which will result in a longer retention in accordance with our data retention policy. However, chat messages, including images and recordings, may still be stored locally on user devices and may still be stored on the recipient’s device even after the information is no longer accessible on Encountr’s servers

YOUR OPTIONS AND RIGHTS: Where your jurisdiction’s law permits, you can make the following options and exercise your rights regarding your Personal Information held by Encountr:

Access & Portability. You may request that we provide you with information about our processing of your Personal Information and provide you with a machine-readable copy of your Personal Information. We may not be able to provide some parts of the information if that information would also reveal Personal Information about another person or if we are legally prohibited from disclosing such information. If you have questions regarding your Access & Portability output, reach out to us here. Delete Account and Related Information. You may delete your account and related Profile Information at any time. After deletion, your Personal Information will be deleted from Encountr’s systems in accordance with this Policy. There are situations where some or all of your information may be kept after your request (such as for Legal Obligations, moderation review, dispute resolution, and other matters in accordance with this Policy). For more information on how to delete your account, click here. Correct Profile Information. By creating an account, you are providing us your Personal Information for your Encountr Profile. You can review and change your Profile Information at any time by accessing the “Edit Profile” section of the Encountr Services. Behavioral Advertising On Websites, Third-Party Platforms, and the Encountr Services. You can opt-out of the sharing of your Personal Information (or the “sale” of your Personal Information as the practice may be called in some jurisdictions) with our Ad / Marketing Partners for behavioral advertising purposes. Please note that opting-out of behavioral advertising does not mean that you will not receive advertising while using the free version of Encountr Services. It will,

however, exclude you from interest-based advertising as provided by the applicable choice mechanisms. For more information on how to opt out of behavioral advertising on the various Encountr Properties, click here. Promotional Emails. You may choose to allow us to use your email address to send free newsletters, surveys, offers, and other promotional materials related to Encountr and/or the Encountr Properties, as well as targeted offers from third-parties. You can stop receiving promotional emails by following the unsubscribe instructions in emails that you receive. If you unsubscribe from receiving such promotional emails, we may still send you service-related communications, and our applications will continue to deliver you in-app messages. Third-Party Tracking. You may opt-out of Google Analytics’ collection and use of your Personal Information on the Encountr Site by following the instructions here to download an opt-out browser add-on. Restrict Processing. Under certain circumstances, you may restrict the way we process your Personal Information (e.g., through controls provided by your device’s operating system, like “Location” (defined below) access, Location granularity, and opt-ing out of the use of your Ad ID for behavioral advertising). Withdraw Consent. You may withdraw consent that you have previously given us at any time. Revocation of your consent will only apply to future processing activities and will not apply retroactively. To learn more about the processing activities where Encountr relies on your consent, refer to our Legal Bases. [FIND OUT MORE] Object to Processing. You may object to us relying on our legitimate interests as the reason for why we process your Personal Information. Non-Discrimination. You are entitled to exercise the rights described above free from discrimination.

HOW WE SAFEGUARD YOUR PERSONAL INFORMATION YAt Encountr, we take the privacy and security of your Personal Information, including information considered sensitive, seriously. Our cybersecurity team actively works to preserve the integrity, confidentiality and availability of the Encountr Properties and our policies and protocols are aimed at protecting your Personal and sensitive Personal Information. We constantly strive to enhance our defenses in the ongoing fight against threat actors. However, no method of transmission over the Internet, or method of electronic storage, is completely secure, and Encountr cannot guarantee the security of your Personal Information. Our security, safety, and privacy features are offered on an “as-is” basis. Therefore, their effectiveness and error-free operation cannot be assured, and we cannot guarantee absolute confidentiality, anonymity, or personal safety. Individuals who have specific worries about how their data may be protected are advised not to use the Properties. In the event that we are required by law to inform you of any unauthorized access to your Personal Information, we may notify you electronically or in

writing in accordance with applicable law.

SUBSCRIPTION POLICY: Our app subscription prioritizes your privacy and provides clear guidelines for cancellation and refund requests. You can cancel your subscription at any time through the app settings or by contacting customer support. Upon cancellation, you'll retain access to the subscription features until the end of the current billing cycle, after which access will be revoked. Refunds are issued in accordance with our refund policy, which may vary based on individual circumstances and applicable laws. We strive to process refund requests promptly and fairly. Your data remains protected throughout the cancellation and refund process, adhering to our stringent privacy measures. For further details on cancellation, refunds, and data handling, please consult our comprehensive privacy policy available within the app or on our website.

HOW TO REACH US OR FILE COMPLAINTS: Contact Information. Encountr appreciates your comments, questions, or complaints regarding this Privacy and Cookie Policy, our use of your Personal Information, or our response to your requests regarding your Personal Information.

Individuals in the European Economic Area (EEA) and the United Kingdom (UK) also have the right to lodge a complaint with a supervisory authority in the EEA Country where they live or work, or where the alleged violation of the General Data Protection Regulation (EU) 2016/679 (“GDPR”) occurred. You can find information about your data protection regulator here. Individuals in Switzerland also have the right to lodge a complaint with the Swiss Federal Data Protection and Information Commissioner. For complaints from individuals in the EEA, UK, or Switzerland that cannot be resolved with Encountr directly, Encountr will cooperate with EEA, UK, and Swiss authorities and will implement the guidance they provide with respect to such unresolved complaints.

If you are based in the EEA or UK or have GDPR-related inquiries, you may contact our EEA and UK Representative by submitting your request or inquiry.

If you are based in Brazil or have inquiries related to the Lei Geral de Proteção de Dados Pessoais (LGPD) 13.709/2018, you may contact Encountr’s Brazil DPO through our website here.

SUPPORT: We have provided the email and support number on our website: