Privacy Policy

 

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, and date of birth, and,

only if you choose (or are required) to complete our optional identity verification, 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. You must

be at least 18 years of age to use the Services. Because identity verification is optional, we

generally rely on the date of birth and other information you provide to determine your eligibility,

and we do not independently confirm the age of users who do not complete identity verification.

The Company does not knowingly collect personal information from anyone under 18 years of

age. If we learn that we have collected personal information from a person under 18, we will

take steps to delete that information and close the associated account. If you believe a person

under 18 is using the Services, please contact us at ask@talktomyface.com. The Company is

not liable for any unauthorized use of the Services by minors, including use made possible by a

user's misrepresentation of their age.

Identity Verification and Biometric Data

Identity verification through our third-party verification provider, Veriff, is optional. You may

choose to complete identity verification to receive a verified status on your profile (a "Verified

User"), or you may use the Services without completing identity verification (an "Unverified

User"). Certain features of the Services may be available only to Verified Users, and we may

require you to complete identity verification in certain circumstances, such as to investigate a

report of suspected fraud, impersonation, underage use, or another violation of the Agreement.

The information described in this section is collected only if you choose, or are required, to

complete identity verification.

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 your consent at any time by contacting ask@talktomyface.com or by

deleting your request for an account or your account. If you withdraw consent without

deleting your account, your verified status will be removed and you may continue to use

the Services as an Unverified User, except for any features available only to Verified

Users

 We will not collect biometric data without your informed written consent

 Choosing not to complete identity verification will not prevent you from creating an

account or using the Services, except for any features that are available only to Verified

Users

 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.

If You Do Not Complete Identity Verification:

 We do not collect government-issued identification documents or biometric information

from you

 We rely on the information you provide to us (such as your name, date of birth, and

photos) and do not independently confirm its accuracy

 Other users may be able to see that you have not completed identity verification

 You may choose to complete identity verification at any time through the Application

Verification Status Visible to Other Users:

 If you are a Verified User, other users may see an indicator on your profile showing that

you have completed identity verification; if you are an Unverified User, other users may

see that you have not

 We do not share your government-issued identification, the images you submit to Veriff,

or your biometric identifiers with other users

 A verified status means only that, at the time of verification, Veriff reported that the

identification submitted appeared authentic, matched the selfie provided, and indicated

the user was at least 18 years of age. It is not a background check, and it does not mean

that we endorse or vouch for any user

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 (if you choose, or are required, to complete identity verification)

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

 displaying your verification status (verified or not verified) to 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, where identity verification is completed

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 (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

If you choose to complete identity verification, the biometric data you provide to Veriff for identity

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 (for users who

complete identity verification), 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