Privacy Policy

Last Updated: April 17, 2026

This privacy policy ("Privacy Policy") governs how the TTMF, LLC d/b/a Talk To My Face ("Company" "us" "our" or "we") collects, uses, and discloses your personal information that is collected through the your access and use of the Talk To My Face services and any related content or services, including, but not limited to the mobile application (the "Application") (collectively, the "Services").

We reserve the right to modify this Privacy Policy at any time without notice, as reflected in the "last updated" date above. When changes are made to this Privacy Policy, we will revise the "last updated" date at the top of this Privacy Policy. If we make any material changes, then Company may also notify you by other methods. Your continued use of the Services after we have posted any Privacy Policy changes indicates your agreement to such changes.

The Terms and Conditions of Service are incorporated herein by reference (the "Agreement") and the terms of this Privacy Policy is subject to the Agreement. As noted in the Agreement, by using the Services you accept and acknowledge that you are bound by this Privacy Policy.

Information Collected

Generally

We collect information about you when you create an request to create an account through the Services, such as your phone number, name, email address, address, date of birth, government-issued identification documents, and biometric information (as further described in the Identity Verification and Biometric Data section below), and when your request for an account is approved, any information you provide to complete your profile, such as your gender, interests, preferences, photos, location information (as further described in Location Tracking and Geolocation Data section below) . We also collect information from you when you use the Services, such as when you contact us for support, report location check-ins, post photos, content, or update your status indicating your level of desire to engage in discussion and meet other users in person. In addition to personal information you provide to us through the Service, the Company may also collect personal information through the use of tracking technologies based on how you use the Services (e.g. when you log into your account, features you use, actions you take, and information shown to you), how you interact with other users (e.g. matching, communicating, and length of interaction), and information about the device you use to access and use the Services (e.g. hardware, IP address, browser type, browser versions, browser language, browser plug-in type and version, time zones, dates and times of using the Services, page views, and duration of activity on the Services.)

Use of Cookies

A cookie is a small text file that is sent to or accessed from your web browser or device's memory and tracks information about you. When you use the Services, we may assign one or more cookies that enable us to improve the quality of the Services and to personalize your experience. Cookies allow us to automatically collect information about your activity while using the Services, such as information about your device, and content you access or other activity you conduct while using the Services. You may choose to modify your web browser's setting to disable cookies or limit their use. If you choose to disable or limit cookies, you are still able to access the Services, but you may be unable to use all of the features on the Services.

Use of Web Beacons

The Services may contain web beacons (also known as "clear gifs") or similar technologies that gather information about your use of the Services. Such technology may also be contained in e-mail messages from us that allow us to determine whether messages have been accessed. The purpose of this technology is so that we may analyze the effectiveness of its marketing efforts, the quality of the Services provided.

Location Tracking and Geolocation Data

How We Collect Location:

By accessing and using the Services, you give us permission to collect your geolocation from your device through:

Your device's GPS (Global Positioning System)
WiFi network information
Bluetooth signals
Cell tower data
IP address (provides approximate location when other methods unavailable)

Location Collection Timing:

We collect your location automatically when you open and use the Application
Location updates in real-time while the Application is open and active
We do NOT collect location when the Application is closed or running in the background
Your device must have location services enabled for the Application to function

Location Precision and What Others See:

We collect precise GPS coordinates from your device
Your location data is stored with approximately 110-meter precision (3 decimal points)
Other users see your location as a pin on a map within the Application
Other users can see your approximate distance from them (e.g., "0.3 miles away")
Other users CANNOT see your exact street address or precise GPS coordinates
When you close the Application, your last known location may remain visible to other users for a brief period before you appear as "offline"

How Location is Used:

To show you other Talk To My Face users near your current location (within 10 miles)
To enable our matching system based on geographic proximity
To recommend meet-up locations and participating third party vendor locations nearby
To display your approximate location to other users in your vicinity
To verify your location during meetups (tap in/out system, described below)
To analyze geographic usage patterns in aggregated, anonymized form

Tap In/Out System (Meetup Verification):

When you and another user plan to meet in person:

You propose or accept a specific meetup location through the Application
When you arrive at the location, you "tap in" to confirm your arrival
We verify your GPS location is within 100 meters of the agreed meetup location using geofencing technology
Your precise GPS coordinates at tap in are recorded for verification purposes
When the meetup is complete, you "tap out" to end the session
Tap session data (including GPS coordinates, timestamps, duration) is stored for Reward calculations, fraud prevention, and verification of participation of third party vendor visits
Both users must tap out for the session to be marked as complete and for Rewards to be awarded

Location Data Retention:

Current location: Updates in real-time while Application is open
Historical location data: We do not retain a history of your past locations outside of tap sessions
Tap session locations: GPS coordinates from tap in/out are stored for as long as your account is active for Reward validation and fraud prevention
After account deletion: For a reasonable period of time to fulfill legal obligations and to resolve disputes

Location Privacy Controls:

You can disable location services in your device settings (this will prevent use of core Application features)
You control when you "tap in" at meetup locations
Your location is only visible to other users when the Application is open and you are actively using it

IP Address and Approximate Location:

An IP address (Internet address) is automatically assigned to devices that access the internet. You cannot prevent the Application from obtaining your device's IP address. Your IP address includes general information about your device location, and we use that information to provide location-based features when precise GPS is unavailable.

The Services are meant for adults and those who have reached the age of majority. The Company does not knowingly collect personal information from children and is not liable for any unauthorized use of the Services by minors.

Identity Verification and Biometric Data

Before you may access and use the Services, you must complete identity verification through our third-party verification provider, Veriff.

What We Collect Through Veriff:

Valid government-issued photo identification document (driver's license, passport, or state ID)
Biometric identifiers derived from your facial geometry through selfie analysis to verify that your selfie matches your government-issued photo identification document
Name, date of birth, and address from your government-issued photo identification document
Government-issued photo identification images
Verification session metadata (device information, timestamps, verification attempt history)

How Identity Verification Works:

You submit a photo of your government-issued photo identification
You take a live selfie through the Veriff interface
Veriff analyzes your facial geometry to confirm your selfie matches your government-issued photo identification
Veriff verifies the authenticity of your government-issued photo identification
We receive a session reference ID, a verification status (verified/not verified), results (approved/denied) and a time stamp of last status change

How Biometric Data is Used By Us:

To verify your identity matches your government-issued photo identification
To confirm you are at least 18 years of age
To attempt to prevent duplicate accounts and fraud
To attempt to enhance the Services safety and security
To comply with our Agreement eligibility requirements

Biometric Data Processing and Retention:

Veriff collects and processes your biometric identifiers (facial geometry data) on our behalf
Veriff's use of your data is governed by their Privacy Policy: https://www.veriff.com/privacy-policy
From Veriff, we receive a session reference ID and verification status (verified/not verified) and results (approved/denied) and a time stamp of last status change
We do not have direct access to the underlying biometric templates or your biometric identifiers (facial geometry data)
Veriff retains biometric identifies (facial geometry data) according to their retention schedule described in their Privacy Policy

Your Biometric Privacy Rights:

You may request information about the collection, use, and retention practices by contacting ask@talktomyface.com
You may withdraw consent by deleting your request for an account or your account (if verification approved) (though this will prevent use of the Services)
We will not collect biometric data without your informed written consent
We will not sell, lease, or trade your biometric data
We will not disclose biometric data, except as necessary for verification
Biometric data is retained according to Veriff’s Privacy Policy https://www.veriff.com/privacy-policy

For more information about how Veriff processes your identity verification information and biometric data (facial geometry data), please review Veriff's Privacy Policy at https://www.veriff.com/privacy-policy.

Use of the Information Collected

We may use and share your information for any legally permissible purpose. Examples of some ways we may use or share personal information collected about you include:

Providing you the Services and its contents

creating and maintaining your account and profile
operating and maintaining the Service features
verifying your identity and confirming you meet eligibility requirements
tracking your location to recommend other Talk To My Face users to you
presenting you with meet-up locations
sharing your profile and location information with other users
offer third party vendor promotions and communicate with you
Display Rewards from participating third party local businesses based on your location and tier status
Present third-party Rewards
Send you marketing communications about the Services (you can opt out - see Your Rights section)

Responding to your inquiries or requests

responding or investing reports of violations of the Agreement
providing you customer support

Keeping you and other users safe

preventing and detecting violations of our Agreement
verifying your and other users identity

Analyzing, enhancing, and improving the Service

develop and improve new features, including through machine learning
analyzing how the Services are used
notifying you about changes to this Privacy Policy or the Agreement
Notify you about new Business Partners and Rewards (as described further below)

As a part of a business transaction

in the event the Company sells or transfers all of its business or assets by merger, sale, acquisition, divesture, restructuring, reorganization, dissolution, bankruptcy, or other change of control

Complying with applicable laws, court orders, regulations, and industry standards

preserving data to comply with applicable law
reporting illegal or infringing content to law enforcement, government, or other authorities
sharing data with law enforcement to report abusive or illegal behavior
carrying out legal obligations, such as complying with court orders, and cooperating with law enforcement and regulators

Protecting and defending the Company or other third party's rights or property

pursuing or defending potential litigation, regulatory action, or other disputes
assist in the prevention or detection of a crime
protect the safety of a person
enforcing the terms of this Privacy Policy or the Agreement

Sharing with third parties who the Company has contracted with to help provide the Services

Veriff - Identity and age verification, biometric analysis, fraud prevention, background checks (Privacy Policy: https://www.veriff.com/privacy-policy )
Google Analytics - Usage analytics, app performance monitoring (Privacy Policy: https://policies.google.com/privacy ) (Opt out: https://tools.google.com/dlpage/gaoptout )
Firebase (Google) - Push notifications, cloud messaging, app analytics (Privacy Policy: https://firebase.google.com/support/privacy )
MongoDB Atlas - Database hosting (Privacy Policy: https://www.mongodb.com/legal/privacy-policy )

Amazon S3 - Secure storage of photos and documents (Privacy Policy: https://aws.amazon.com/privacy/ )

Cloud Infrastructure Provider - Data hosting

Participating Business Partners (as further described below) - Rewards program fulfillment (receive only anonymous redemption counts, not individual user information)
legal support
Law Enforcement - When required by law or to protect safety

We partner with local third party restaurants, cafes, and merchants ("Business Partners") who offer certain rewards from participating Business Partners, which may include free or discounted products or services (“Rewards”) to our users. Here's what information is shared:

When You Redeem an Offer:

You generate a unique QR code through the Application
You show the QR code to the Business Partner's staff
The Business Partner scans the code to verify the Reward redemption
We record: date/time of Reward, location, offer redeemed, and an anonymous user identifier

What Business Partners Receive:

Aggregate redemption data only (e.g., "15 students redeemed offers today")
Total number of verified meetups at their location (for billing purposes - Business Partners pay $3 per verified visit)
Anonymous verification that meetups occurred at their location
Statistical information about usage patterns (peak times, popular offers, etc.)

What Business Partners DO NOT Receive:

Your name, photo, or profile information
Your contact information (email, phone number)
Your individual identity or personal details
Your location history or activity outside their location
Your messages or interactions with other users
Any information that would allow them to identify you personally

Billing and Verification:

Business Partners are charged $3 for each verified student visit (when users tap in at their location)
We verify visits through geofencing (confirming GPS location) and tap in/out data
Business Partners can see aggregate visit counts through their dashboard
Individual user identities are not disclosed for billing purposes

Business Partner Marketing:

Business Partners may display offers and promotions through the Application
These offers are shown to users based on location (proximity to the business) and tier status (some offers may be exclusive to higher tiers)
We do NOT share your personal information with Business Partners for their independent marketing purposes
Business Partners cannot contact you directly through the Application

If you have concerns about a Business Partner's Rewards or practices, contact us at ask@talktomyface.com. You can choose not to redeem Rewards or visit Business Partner locations. Declining to interact with Business Partners does not affect your ability to use the core features of the Application (connecting with other users and arranging meetups).

We may convert, or permit others to convert, your personal information into deidentified, anonymized, or aggregated information, as permitted by applicable law. We will not sell any personal information you submit to any third party without prior written notice to you and an opportunity for you to opt-out of such sale, provided, however, that the Company is permitted to sell your information in the event of a merger, acquisition, change of control, or sale of substantially all of its assets or business (or any substantially similar transaction).

Data Retention

Account Deletion

If you decide to stop using the Services, you can close your account and your profile will no longer be visible to other Talk To My Face users. When you delete your account, your data is also deleted.

Inactivity Deletion

If you do not use the Services for a period of six (6) months, then automatically your account and data will be deleted.

Biometric Data Deletion

The biometric data you provide to Veriff for identify verification is retained for a period necessary to fulfill its original purpose and will be deleted by Veriff in accordance with its privacy policy https://www.veriff.com/privacy-policy. We do not hold biometric data you provide to Veriff, but the information we do receive from Veriff (i.e. a session reference ID, verification status (verified/not verified), results (approved/denied), and a time stamp of last status change) is held by us for as long as we hold your other data collected in connection with your use of the Services and is deleted upon the sooner of: (a) your request; (b) your account deletion; or (c) your inactivity.

If you need specific information deleted for safety or privacy reasons, contact us at ask@talktomyface.com and we will review your request.

Protection of the Information Collected

We take reasonable security measures to protect your information against unauthorized access, loss, alteration, or destruction. These measures include encryption and physical security measures to guard against unauthorized access to systems where the Company stores personal information, and the usage of reputable third-party vendors. Despite these reasonable measures, we cannot guarantee the security measures are impenetrable. Therefore, although we take reasonable steps to secure your information, it cannot and does not promise or warrant that your personal information will always remain secure.

Who Within Our Company Can Access Your Information

A limited number of Company employees and administrators have access to user information for legitimate business purposes:

Administrators: Can access user profiles, verification information from Veriff, including session reference ID, verification status (verified/not verified), results (approved/denied) and time stamp of last status change for purposes of:

Reviewing and approving/rejecting new account applications
Investigating reports of violations, abuse, or inappropriate behavior
Providing customer support and responding to user inquiries
Complying with legal requirements and responding to law enforcement requests
Maintaining platform safety and security

Customer Support Staff: Can access profile information and account history to provide support

Technical Staff: May access data for system maintenance, debugging, and service improvements

Internal Access Controls and Monitoring

All internal access to user data is logged and monitored
Employees can only access information necessary for their specific job functions (role-based access controls)
Employees are bound by confidentiality agreements and Company internal privacy policies
Unauthorized access or disclosure of user information is grounds for immediate termination
We conduct regular security audits and access reviews

We do not allow employees to access user data for personal purposes or to share user information outside the Company, except as described in this Privacy Policy or as required by law.

Third Party Controls

This Privacy Policy does not cover any third party's use or handling of your personal information once it is shared. Instead, the privacy policies of the third party(ies) will govern. We encourage you to visit the websites of those third parties and fully read and understand their privacy policies.

Your Rights

We value your privacy. You may be able to access, correct, modify, or delete certain of your personal information and update preferences in your account created in connection with your use of the Services. You may also contact us at ask@talktomyface.com if you have any questions on your rights and how to exercise them. For your protection, we may ask you for information that allows us to verify you before we can grant any requests.

Questions

If you have any questions regarding this Privacy Policy, you can contact us at:

TTMF, LLC d/b/a Talk To My Face

Attn: Erin Pash

430 1st Ave. N, Suite 770

Minneapolis, MN 55401

Email: ask@talktomyface.com