The Meet Group, Inc.
Live Privacy Policy

Updated as of April 1, 2023

This Live Privacy Policy (“Privacy Policy”) relates to the information collection and use practices of The Meet Group, Inc. and its U.S. subsidiaries (collectively, “TMG,” “we,” “us,” or “our”) in connection with your access and/or use of the live-streaming video feature (“Live”) made available by us on our owned and operated website(s) or application(s) (“TMG Apps”) and/or on the website(s) or application(s) of our Live Partners (“Partner Apps”). By accepting this Privacy Policy, accessing or using Live, or otherwise manifesting your assent to this Privacy Policy, you agree to be bound by this Privacy Policy and the Live Terms of Service, which together make up the Agreement. If you do not agree (or cannot comply) with all of the terms of this Privacy Policy or any other terms of the Agreement, you may not access or use Live. Capitalized terms not defined in this Privacy Policy shall have the meaning set forth in the Live Terms of Service.

Age Restricted: If you are under the age of 18, you may not access or use Live. We do not knowingly collect, maintain, or sell personal information from minors under the age of 18.

Language: This Privacy Policy is written in English. If you are reading a translation and it conflicts with the English version, please note that the English version controls.

What This Privacy Policy Covers

This Privacy Policy describes how we process the information we collect or receive about you when you access or use Live via TMG Apps or Partner Apps.

What this Privacy Policy does not cover

TMG provides Live to third parties (“Live Partners”) that make Live available to their users via Partner Apps. This Privacy Policy does not apply to the information collection and use practices of the Live Partners or any other third-party companies that we do not own or control (“Third Parties”) such as our payment processors, and companies that advertise on Live. Third Parties that advertise on Live, for example, may tag your device or computer with tracking technologies, including cookies. Also, Live Partners may tag your device or computer when you are using Live on Partner Apps. We do not control any of these Third Parties or their tracking technologies, and their privacy policies may differ from ours. Except for the Live feature that you access through the Partner Apps, we do not have any control over Partner Apps. All features and functionality within the Partner Apps, except for Live, are controlled by Live Partners and your use of Partner Apps is subject to the privacy policies and other terms and conditions of the Partner Apps. Live Partners and all other Third Parties are solely responsible for any of your information that they collect or receive, so we encourage you to review their privacy policies to understand their data collection and processing practices and your rights under applicable law.

Privacy Policy - Contents

  1. INFORMATION WE COLLECT OR IS PROVIDED TO US
  2. HOW WE USE YOUR INFORMATION
  3. HOW WE SHARE YOUR INFORMATION
  4. THIRD PARTY ANALYTICS SERVICES
  5. DATA SECURITY & RETENTION
  6. CONTROLLING AND PROTECTING YOUR DATA PRIVACY
  7. NOTICE TO CALIFORNIA RESIDENTS
  8. NOTICE TO NEVADA RESIDENTS
  9. NOTICE TO VIRGINIA RESIDENTS
  10. NON-US RESIDENTS
  11. CHANGES TO THIS PRIVACY POLICY
  12. CONTACT INFORMATION

1. THE INFORMATION WE COLLECT OR IS PROVIDED TO US

By joining Live you consent to allow our Live Partner to transfer information, including personal information to us and by providing information to us, including any sensitive personal information, you agree and consent to our collection, storage, process, and use of such information for the purposes stated herein and in accordance with the Privacy Policy. If you access Live through the TMG Apps, you may change or update your Profile Information or revoke your consent, at any time, in account settings on the TMG Apps.

TMG Apps: When you access and/or use Live through TMG Apps, this Privacy Policy and the TMG Privacy Policy govern your activity on Live and our collection and use of your information through Live. If there is a conflict between privacy policies, this Privacy Policy controls as it relates to your access and/or use of Live.

Partner Apps: In order for you to access and/or use Live through a Partner App, our Live Partner will provide us with, at a minimum, your user identifier (e.g., user ID), name (including display name and/or first name), age, and gender. Our Live Partner may also provide, your last name, language (selected for your device), other information such as photos and images (we may also collect metadata from your photographs and images), ‘about’ text; location-related data (e.g., city, state, longitude or latitude) and such other information that our Live Partner makes available about you to us (collectively, “Profile Information”), including transaction information about your purchase of credits through the Partner App. You may contact our Live Partner for a complete list of information that is made available about you to us by our Live Partner. In addition to the information that is transferred by our Partner, you may provide information, including personal information directly to us when you access and/or use Live.

Sensitive Personal Information, including Biometric Information: Except for biometric information used to verify that you are a live human and your age (explained below), You and/or our Live Partners are not required to provide sensitive personal information to us, or consent to allow Live Partners to transfer such information to us, to use Live. You and/or our Live Partners may, however, voluntarily provide us with Profile Information and other personal information that is considered “sensitive” or “special category” in your jurisdiction, including, but not limited to, sexual orientation (including who you are interested in which can be used to infer or reveal your sexual orientation), precise geolocation information, religious beliefs, or racial or ethnic origin.

We may collect biometric information through Live to help to verify that you are an actual live human and your age and to prevent duplicate accounts and identity fraud. We ask for your consent to collect and process biometric information in accordance with applicable law. For more information, please review our Biometric Data Specific Notice, which is available. If you do not want to provide biometric information for the purposes stated herein when requested, we reserve the right to not grant you access to Live.

Identity and Tax Information: We may collect information from your government issued identification and relevant tax information (e.g., IRS W-9 and W-8 forms) which will be processed to verify your identity and to meet our legal, tax, and compliance obligations.

Content: You may provide Content through Live (e.g., live streams, video, audio pictures, images, posts, broadcasts, messages, and chats) whether publicly posted or privately transmitted. We (and our service providers) may access and use such information to provide Live, for content moderation, and for safety and legal process purposes. If you do not want us to access your private messages and chats for the purposes described herein, you should not send private messages and chats when using Live.

Geolocation Information: When you use Live through Partner Apps, the Live Partner may provide us with access to your geographic location, which may include precise geolocation. We do not have any control over Partner Apps and how they collect your geolocation data, including precise geolocation. You should read the Live Partner’s terms and conditions and privacy policies to understand their data collection and processing practices with respect to geolocation, including precise geolocation and your rights under applicable law. If you use Live through TMG Apps and allow us to collect and use your geolocation information through the location options in the registration when you download the TMG App, we will collect and use your precise geolocation information to provide you with Live, show you people near you, improve Live, for security and for advertising purposes based on the options you select. You may change the location setting at any time in your device setting. In some jurisdictions precise geolocation is deemed sensitive personal information. To the extent the level of preciseness of the geolocation information collected and used by us is deemed sensitive personal information and therefore requires consent under applicable law, you agree and consent to the collection, use and processing of the precise geolocation for the purposes described in this Privacy Policy and the TMG Privacy Policy. You may change your location setting in the TMG App at any time.

Information Automatically Collected Through the Services:

Device, Activity, Usage Information: When you access or use Live, we or our Live Partner (when you use Live through a Partner App) may collect or receive information from your device or browser, including your IP address, information from and about the computers, devices and other web-connected devices used to access and/or use Live, the operating systems, the ISP, mobile device identification such as AdID (Google) and IDFA (Apple) for advertising and other purposes as set forth in this Privacy Policy. Our Live Partners use and process such information in accordance with their own privacy policies, which we encourage you to review. In addition, TMG also collects or receives information about the features you use in Live, and your transactions with us and our Live Partners. We use all such information to provide Live, analyze trends, prevent fraud, understand your use of Live and the device you use to access Live to help improve and customize your experience on Live, to improve Live and TMG Apps, and otherwise in accordance with this Privacy Policy.

Cookies and Other Tracking Technology: Our use of “cookies” and other tracking technology may involve the collection of personal information. Cookies are small packets of data that a website stores on your device or browser so that your device will recall your preferences and usage patterns for future visits. The information collected by cookies depends on their particular purpose. We use tracking technology and the information collected to (i) authenticate users, (ii) conduct analytics and measure performance of Live, (iii) improve Live, and research and test new features, (iv) personalize your experience when using Live and (v) provide ads about Live or TMG on other apps or websites. We and our advertising partners may also use the information collected by the tracking technology to deliver relevant ads, measure and optimize advertising and promotional effectiveness of relevant ads, and monitor your interactions with ads.

If you do not want TMG, our partners including advertising partners, place cookies or other tracking technology on your hard drive or mobile device, as applicable, you may be able to turn that feature off on your computer or mobile device. Please consult the documentation for your browser or device for information on how to do this. However, if you decide not to accept cookies or other tracking technology from us, Live may not properly function.

When Live is made available to you through Partner Apps, please be aware that these Partner Apps maintain their own policies regarding cookies and the collection and use of information. You are responsible for reviewing those policies.

To find out more about cookies on Live and other websites and apps that you access or use, including how to see what cookies have been set, visit: www.aboutcookies.org or www.allaboutcookies.org.

2. HOW WE USE YOUR INFORMATION

In addition to the way we use your information described in Section 1, we use your information as follows:

Service-Related Usage: We use your information to provide and support Live, such as displaying profiles and other information of users that have created streams you may be interested in viewing based on your preferences, processing your transactions, virtual gifting and credits, talent and VIP management, communicating with you and other users, managing accounts, providing customer service and support, informing you about our products and services, and maintaining our systems and technology infrastructure.

Operate our Business: We use your information to operate our business, maintain our financial books and records, engage in sales of products and services to users and visitors to TMG Apps, advertisers and partnere, enhance the integrity and security of our systems and resources, manage our work environment, and respond to any potential compromise of personal information.

Other Communication: We use your information to communicate with you such as responding to your inquiries, troubleshooting, communication regarding Live, surveys, sweepstakes, events and contests and push notification regarding Live, Content that may be of interest, and your account. You may opt-out of receiving push notification in the settings on the TMG Apps. For Partner Apps, you should contact the Live Partner about how to opt-out of receiving push notification.

Analyzing and Improving the Services: We may run calculations, aggregate, normalize, clean, and make derivative works of your information in order to:

  • Understand and analyze traffic on Live, usage trends and preferences;
  • Monitor and analyze the effectiveness of Live;
  • Improve Live and develop new products, services, features, and functionality; and
  • Test Live and our technology infrastructure to make sure Live is working correctly.

Policy Enforcement and Legal Purposes: We use your information to:

  • Enforce and resolve disputes related to our Privacy Policy, Terms of Service or other agreements we have with you;
  • Protect our legal rights;
  • Verify accounts and activity;
  • Combat harmful conduct, such as abusive behavior and other violations of our Terms of Service and our Content and Conduct Policy;
  • Detect and prevent spam;
  • Detect and prevent money laundering and fraud;
  • Maintain the integrity of Live;
  • Protect the rights, property or safety of you, us, or another party;
  • Respond to claims that any posting or other content violates third-party rights; and
  • Promote safety and security on Live, such as monitoring for illegal activity and reporting to the appropriate authorities.

3. HOW WE SHARE YOUR INFORMATION

Live Network: Live may operate within a network of other applications owned or operated by TMG and/or Live Partners (“Multi-Party Network”) or within a single application on a standalone network (“Single-Party Network”). Your Profile Information and Content will be visible to other users of Live, and if you do not want to be visible to others on Live, you should not use Live. When you access Live via an application that is part of a Multi-Party Network, your Profile Information and Content will automatically be visible to all users within the Multi-Party Network. If you access Live via an application that is a Single-Party Network, your Profile and Content will be visible to only those users of the application in the Single-Party Network. If you do not want to be visible to other users in a Multi-Party Network, you should not use Live on a Multi-Party Network.

Service Providers: We engage third parties to perform services on our behalf such as hosting, payment processing, content moderation, video streaming, customer service, maintenance and support for our technology infrastructure and systems, and other functions. These third parties will have access to your information only as necessary to perform their services and to the extent permitted by law.

Marketing and Business Partners: We may share your information with third party business partners to administer our promotions, sweepstakes, contests, surveys, and other programs, deliver targeted advertising, measure the effectiveness or our advertising campaign and provide marketing support.

Sale of Our Business or Assets: As we develop our businesses, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, investment, or similar corporate event, we expect that your information will be part of the transferred assets. In such cases, we would require any such business entity to honor the terms of this Privacy Policy.

Legal Purposes and Cooperation with Law Enforcement: We may disclose information when required by law, court order, subpoena, or other government or law enforcement authority or regulatory agency. We cooperate with government and law enforcement officials to enforce and comply with the law. We report threats of violence or self-harm and other illegal activities proactively, and we may disclose information about you to government or law enforcement officials in order to protect the safety and security of our users and members of the public, satisfy subpoenas, court orders and/or other governmental or law enforcement requests.

Advertising; Third Parties: We may share information about your device with Third Parties for the purpose of tailoring, analyzing, managing, reporting, and optimizing advertising you see on Live and elsewhere. We may share information collected from the devices that you use to access Live, such as your geolocation, IP address, AdID and IDFA to allow such Third Parties to deliver relevant, personalized advertisements or Content on Live. Third Party advertising companies may also collect information from and about you by using cookies, pixel tags (also called web beacons or clear gifs), and/or other technologies through Live, by tracking you on sites and apps that you visit, and through other sources. Pixel tags, for example, enable us and Third-Party advertisers to recognize a browser’s cookie when a browser visits the site on which the pixel tag is located in order to learn which advertisement brings a user to a given site. To achieve these purposes, we and these Third Parties may combine and use the information to (i) evaluate the nature of the connection across your devices, browsers, or applications; (ii) assess the suitability of your desktop or mobile device for interest based content; (iii) provide information about user interests to Third Parties; and (iv) develop insights and reports relating to the presentation of customized advertisements or content, including statistical reports in connection with activity on a website, optimization of ad placement and performance, development of reach and frequency metrics, billing activities, and tracking ads served on a particular day to a particular account. These Third Parties may also combine the information with additional non-identifying information collected from other sources to enhance these activities. By accessing and/or using Live you consent to the processing of data about you by these Third Parties in the manner and for the purposes set out in this Privacy Policy.

You may opt-out of the use of your information for these purposes. To learn more or to choose to opt-out, please visit the Network Advertising Initiative at https://www.networkadvertising.org/ and/or Ad Choices https://youradchoices.com/appchoices. If you delete your cookies, use a different browser, or buy a new device, or reset your IDFA or AdID, you will need to renew your opt-out choice.

4. THIRD PARTY ANALYTICS SERVICES

We use third-party analytics services (such as Google Analytics) to evaluate your use of Live, compile reports on activity, analyze performance metrics, and collect and evaluate other information relating to Live and mobile and Internet usage. These third parties use cookies and other technologies to help analyze and provide us the data and reports. By accessing and using Live, you consent to the collection and processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy.

For more information on Google Analytics, including how to opt out from certain data collection, please visit https://www.google.com/analytics. Please be advised that if you opt out of any third-party analytics service, you may not be able to use the full functionality of Live.

5. DATA SECURITY AND RETENTION

We use industry standard security measures to safeguard your information in our possession or under our control against unlawful or unauthorized access, disclosure, loss, misuse and alteration of the information. We make reasonable efforts to ensure a level of security appropriate to the risk of the processing, taking into account the costs of implementation and nature of the processing of the information. However, we cannot guarantee the complete safety of your information or that our security measures will prevent “hackers” from illegally obtaining this information.

Your live video streams in Live will not be stored, subject to limited exceptions, for example, if some information is required to be retained for compliance with legal obligations or as part of Live streaming moderation activities.

6. CONTROLLING AND PROTECTING YOUR DATA PRIVACY

Limit Mobile Ad Tracking. You may set your mobile device to limit ad tracking, in which case we will not be able to see your AdID or IDFA. We will, however, still share your information with our advertising partners as described in this Privacy Policy unless you choose to opt-out (See, Section 3).

Do Not Track Signals. Some Internet browsers include the ability to transmit “Do Not Track” signals, but there are no uniform standards for this. We do not process or respond to “Do Not Track” signals.

7. NOTICE TO CALIFORNIA RESIDENTS

Residents of the State of California may have additional rights under the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020 (the “CPRA”). For more information, see our CPRA Privacy Notice to California Residents.

8. NOTICE TO 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. You can exercise this right here or by contacting us at support@themeetgroup.com 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, however, that we do not “sell” personal information for monetary consideration as defined in (Chapter 603(a) of the Nevada Revised Statutes).

9. NOTICE TO VIRGINIA RESIDENTS

Residents of the Commonwealth of Virginia may have additional rights under the Virginia Consumer Data Protection Act (the “VCDPA”). For more information, see our VCDPA Privacy Notice to Virginia Residents.

10. NON-US RESIDENTS

If you are located in the European Economic Area (the European Union, Lichtenstein, Norway, or Iceland) or the United Kingdom, you may have additional rights under the applicable General Data Protection Regulation (the “GDPR”) with respect to your personal data. See our GDPR Privacy Notice to European Individuals here.

11. CHANGES TO THIS PRIVACY POLICY

We may revise this Privacy Policy from time to time to reflect new or changed features, changes in the law, or changes in our use or collection of personal information. We display the date of our last update on the first page of the Privacy Policy. Your continued access or use of Live after we post an updated Privacy Policy means that you accept the revisions. If you do not accept the Privacy Policy or any revisions, or are otherwise dissatisfied with Live in any way, your sole option is to cease accessing or using Live. Please refer back to the Privacy Policy on a regular basis.

12. CONTACT INFORMATION

For all requests concerning the security or privacy of your personal information, or questions regarding this Privacy Policy, please contact our data protection officer at support@themeetgroup.com. If you have a particularly sensitive request, please contact our data protection officer via postal mail, as email communication cannot be guaranteed to be secure.

Mail: The Meet Group, Inc.
100 Union Square Drive
New Hope, PA 18938
Attn: Legal Department
Web: www.themeetgroup.com
Phone: 215-862-7832
Email: support@themeetgroup.com

Privacy Notice to California Residents Pursuant to the California Privacy Rights Act

If you are a California resident (“Consumer”), you may have additional or different rights under the California Privacy Rights Act (“CPRA”) and this CPRA Privacy Notice (“CPRA Notice”) applies to you. This CPRA Notice is incorporated in the Privacy Policy. In the event of any conflict between this CPRA Notice and any term of the Privacy Policy, the provision that is more protective of consumer personal information shall control to the extent of such conflict. Capitalized terms not defined in this CPRA Notice shall have the meaning set forth in the CPRA. If you have any questions about this CPRA Notice please contact us at support@themeetgroup.com with the subject line “California Privacy Request.”

1. Personal Information Collected and Retention Period.

We may collect or receive the personal information (including sensitive information) categories listed in the tables below.
Personal Information Category Source of the Data Business Purpose and Use Third Parties To Whom Information is Shared
Identifiers, such as:
  • user identifier (such as user ID);
  • name, including display name, first name, last name, age and gender;
  • language;
  • photos and image(s);
  • about text;
  • location related data
You or our Live Partners may provide to us as further described in Sections 1 and 2 in the Privacy Policy. We use this information for the purposes stated in Sections 1 and 2 of the Privacy Policy, including to provide Live to you. We may share this information with third parties as described in Section 3 of the Privacy Policy, including with Live Partners and other users of Live within the same network, Service Providers, Government & Law Enforcement Officials, Marketing and Business Partners or other third parties in connection with a corporate transaction such as a sale of business.
Other Personal Information:
  • Content of live streams, including video and audio, pictures, images, posts and broadcasts.
  • Device or browser information, including your mobile device identification (AdID (Google), IDFA (Apple), device ID, etc.), and IP address as further described in Section 1 of the Privacy Policy.
You may provide personal information related to the content you provide to us as further described in Section 1 in the Privacy Policy.
Device or browser information as further described in Section 1 of the Privacy Policy may be automatically collected through your use of the Live.
We use content of live streams to provide Live, for content moderation and for safety and legal process as further described in Sections 1 and 3 of the Privacy Policy.
We use your device or browser information to provide you with Live and to serve you relevant advertising as further described in Section 3.
We may share the Content of live streams with third parties, including Service Providers, Government & Law Enforcement Officials.
With respect to device and browser information, we may share this information with third parties, including Service Providers, Government & Law Enforcement and Advertising Partners as described in Section 3 of the Privacy Policy.

Retention Period: Your personal information will be retained until it is no longer necessary in relation to the purposes for which it was collected (or otherwise processed), except where TMG is required to retain such information under applicable law. Your live video streams in Live will not be retained after the stream ends, subject to limited exceptions, for example, if some information is required to be retained for compliance with legal obligations or as part of Live streaming moderation activities.

2. Your Rights Under CPRA and How to Exercise Your Rights:

Notice of Right to Know About Information Collected. Consumers have the right to request certain information about our collection, use, disclosure and sale of their personal information, and to request a list of the personal information that we have. To make such a request, please contact us as described below. Please be advised that we will verify all such requests prior to providing any personal information. Please be advised that we are only required to respond to two requests per user each year. These reports will be provided free of charge.

Notice of Right to Request Correction of Personal Information. If you are a Consumer and your personal information that we have collected is incorrect or incomplete, you may request correction. To make such a request, please contact us as described below. Please be advised that we will verify all such requests prior to providing any personal information.

Notice of Right to Request Deletion of Personal Information. If you are a Consumer, you may request the deletion of personal information we have collected from you. To make such a request, please contact us as described below. Please be advised that we will verify all such requests prior to providing any personal information.

Notice of Right to Limit Use of Sensitive Personal Information. You have the right to request that we limit the use of Sensitive Personal Information by clicking here.

Sale of Personal Information: CPRA broadly defines “sale” such that it may include allowing third parties to receive certain information to deliver interest-based advertising to you. In the past twelve months, we have shared the following consumer personal information that may be deemed a “sale” as the term is defined under the CPRA for the purpose of delivering customized advertising: Location, Advertising ID, IP Address, App Usage, and Device Information.

Notice of Right to Opt-Out of the “Sale” of Personal Information and Limit Use of Sensitive Personal Information. Consumers have the right to request that we not sell or share their personal information with third parties [who are not our service providers]. In our App, this can be done by clicking on the “Do Not Sell My Info” link on the settings page. On our Website, this can be done by clicking the link on the landing page or here. Consumers must have accessed the Services to use the mobile or web links. Alternatively, you may request that we stop selling your personal information by contacting support@themeetgroup.com.

Nondiscrimination. We will not discriminate against Consumers who exercise their rights under the CPRA.

Authorized Agent. Consumers may use an authorized agent to make requests on their behalf. We require the authorized agent to provide us with proof of the Consumer’s written permission (for example, a power of attorney) that shows the authorized agent has the authority to submit a request for the Consumer. In addition to providing this proof, the authorized agent must follow the appropriate process described above to make a request.

California Shine the Light Law. Consumers that provide personal information in obtaining products or services for personal, family, or household use are entitled to request and obtain from us once a calendar year information about the personal information we shared, if any, with other businesses for their own direct marketing uses. To obtain this information, please contact us as described below by mail (if by email include “Request for California Privacy Information” on the subject line and in the body of your message). If you are a Consumer, we will provide the requested information to you at your email address in response. Please be aware that not all information sharing is covered by the “Shine the Light” requirements.

Our California Do Not Track Notice. We do not currently respond or take any action with respect to web browser “do not track” signals or other mechanisms that provide users the ability to exercise choice regarding the collection of personal information about that user’s online activities over time and across third-party web sites or online apps.

3. Exercising Your Rights.

If you have any questions or comments about this CPRA Notice, the ways in which we collect and use your information, your choices and rights regarding such use, or wish to exercise your rights under CPRA, please submit your request [here- this will resolve to the web form for data subject rights] our contact us at:

Email: support@themeetgroup.com
Phone: 844-534-1340
Mail: Member Apps, The Meet Group, Inc. 100 Union Square Drive, New Hope, PA 18938

Virginia Consumer Data Protection Notice

If you are a Virginia resident (“Consumer”), you may have additional or different rights under the Virginia Consumer Data Protection Act (“VCDPA”) and this Virginia Consumer Data Protection Notice (“VCDPA Notice”) applies to you. This VCDPA Notice is incorporated in the Privacy Policy.

In the event of any conflict between this VCDPA Notice and the Privacy Policy, the provision that is more protective of your personal information shall control to the extent of such conflict. If you have any questions about this VCDPA Notice please contact us at support@themeetgroup.com with the subject line “Virginia Privacy Request.”

1. Your Rights Under VCDPA

The VCDPA provides consumers with specific rights regarding their personal information. We will usually be the controller of your personal information. If we are acting as a processor of your personal information on behalf of another controller, please contact the entity that collected your personal information in the first instance regarding your rights under the VCDPA.

A. Right to Know About Your Personal Information

You have the right to request that we disclose the following kinds of information to you about our processing of your personal information:

  • Whether or not we process your Personal Information.
  • The categories of Personal Information we process; we process the categories of personal information from or about consumers and their devices that are referenced in Section 1 of the Privacy Policy.
  • The purpose for processing your Personal Information; we process the categories of personal information listed above for the purposes referenced in Sections 1 and 2 of the Privacy Policy.
  • The categories of Personal Information that we share with third parties; we share the categories of personal information referenced in Sections 2 and 3 of the Privacy Policy with third parties.
  • The categories of third parties with whom we share your Personal Information; we share your personal information with the third-party recipients referenced in Section 3 of the Privacy Policy.

B. Right to Data Portability

You have the right to obtain a copy of your personal information that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance. If you would like to obtain a copy of your personal information that you previously provided to us in a portable and, to the extent technically feasible, readily usable format, please contact us as described in Section 2 below.

C. Right to Request Deletion

You may have the right to request deletion of your personal information. We will honor such request but might not be able to fulfill your request if we (or our service providers) are required to retain your personal information. Examples of such exceptions are:

  • Completing a transaction or performing a contract we have with you;
  • Complying with our audit and substantiation purpose for transaction data;
  • Detecting and addressing data security incidents, and repairing or upkeep of our IT systems;
  • Protecting against fraud, money laundering or other illegal activity;
  • Complying with applicable law or a legal obligation, such as a preservation order, exercising rights under the law (e.g., the right to free speech), or defending legal claims; or
  • Using your personal information internally to improve Live.

D. Right to Request Correction

You may have the right to request that we correct inaccurate personal information that we maintain about you. We will honor such request but might not be able to fulfill your request if it is impossible to do so or would involve disproportionate effort, or if we have a good-faith, reasonable, and documented belief that a request to correct is fraudulent or abusive.

E. Your Opt-Out Rights

You have the right to opt-out of the processing of your personal information for purposes of:

  • Targeted Advertising;
  • Sale of your Personal Information (for monetary consideration as defined under the VCDPA);
  • Profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer

If you wish to exercise any of your opt-out rights, please contact us as set out in Section 2 below.

2. Exercising Your VCDPA Rights

To exercise the rights described above, please submit a request to us by using one of the following methods:

To fulfill your request, we may need you to (i) provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and (ii) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information related to you.

We will confirm receipt of your request within (10) business days of its receipt, and endeavor to respond within forty-five (45) calendar days of its receipt. If we require more time, we will notify you of the extension and provide an explanation of the reason for the extension in writing, and we will provide you with a response no later than ninety (90) calendar days of receipt of the request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. We may charge a reasonable fee to process or respond to your requests if they are excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will inform you of the reasons for this decision and provide you with a cost estimate before completing your request.

If we decline your request, you have the right to appeal within a reasonable period of time after you have received notice of this decision. You may appeal by contacting us through one or more of the methods set out in Section 2. We will get back to you within 60 days of receipt of an appeal and inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decision. If we deny the appeal, we will provide you with a method through which you may contact the Attorney General to submit a complaint.

Privacy Notice to European Individuals Located in the EEA or the United Kingdom

If you are located in the European Economic Area or the United Kingdom, you may have additional or different rights under the EU and/or UK General Data Protection Regulation (together, "GDPR") with respect to your personal data, as set forth in this GDPR Privacy Notice (“GDPR Notice”).

For this GDPR Notice, the terms “personal data,” “processing,” “data subject” and “controller” shall have the meaning set forth in the GDPR.

With respect to Partner Apps, we and our Live Partners process your personal data as a joint controller as further described below. A list of Live Partners and the applications can be found here.

Where applicable, this GDPR Notice is incorporated into the Privacy Policy. In the event of any conflict between the GDPR Notice and the other parts of the Privacy Policy, the provision that is more protective of personal data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at support@themeetgroup.com with the subject line “GDPR Request.”

1. THE CONTACT DETAILS OF OUR DATA PROTECTION OFFICERS

ePrivacy GmbH
represented by Prof. Dr. Christoph Bauer
Große Bleichen 21
20354 Hamburg
Email: privacy@themeetgroup.com

The contact details for our UK representative is:

eHarmony UK Ltd.
6-10 Great Portland Street
London W1W 8QL
Great Britain

The contact detail for our EU representative is:

LOVOO GmbH
Prager Strasse 10
01069 Dresden
Germany

2. PROCESSING OF YOUR PERSONAL DATA IN LIVE

In the context of Live accessible via Partner Apps, we and our Live Partners may process your personal data as joint controllers to the extent described in Section 3 below or separate independent controller. "Joint control" means that we and the relevant Live Partner(s) jointly determine the means and purposes of processing (i.e., we determine together how and why your personal data is processed in the context of Live). If you wish to exercise your data protection rights in the context of Live accessible via Partner Apps, please contact us at: support@themeetgroup.com.

3. JOINT CONTROL

In the context of Live accessible via the Partner Apps, we and our Live Partners are joint controllers to the extent that your personal data is shared and otherwise processed among us and the Live Partners in order to provide Live to you via the application you are using. For example:

  • To the extent you are using Live with respect to persons who are using the same application as you to access Live, we (which operates Live) and the provider of the application are joint controllers regarding the personal data processed for the provision of Live.
  • To the extent you are using Live with respect to persons who are using other applications than you to access Live, we, the provider of the application you are using as well as the provider(s) of the other relevant application(s) are joint controllers regarding the personal data processed for the provision of Live.

We and our Live Partners have entered into joint controller arrangements with respect to processing activities carried out as joint controllers. In these arrangements the joint controllers, in particular, have determined the following:

  • We are responsible for informing you about the essence of the joint controller arrangements.
  • You may contact either us or the Live Partner to exercise your data protection rights with respect to personal data processed under joint control as outlined in this Section 3. We can be contacted at: support@themeetgroup.com
  • Please note that irrespective of the possibility to contact us, you may alternatively exercise your rights in respect of and against each joint controller.
  • We and our Live Partners shall inform you about the processing activities related to your personal data in the publicly available privacy policies click here.
  • We and our Live Partners shall implement appropriate technical and organizational measures to ensure an adequate level of security for personal data processed as joint controller.
  • We and our Live Partners shall implement appropriate safeguards for any transfer of personal data of Live users located outside the EEA/UK.
  • In the context of Live and subject to the joint control, we and our Live Partners shall only share and otherwise process the categories of personal data outlined below and for the purposes listed below.

We may receive the categories of personal data outlined below and in Section 1 of the Privacy Policy from the Live Partners, depending on which Partner Apps you are using to access LIVE (some personal data is only collected if you have consented accordingly). Other personal data is collected directly when you are using LIVE.

We and our Live Partners may share and otherwise process the following categories of personal data with respect to the provision of Live:

  • user identifier (such as user ID);
  • name, including display name, first name, last name, age and gender;
  • language;
  • photos and image(s);
  • about text;
  • (only with your consent) location related data;
  • (only with your consent) who you are interested in (men, women or both), which reveals your sexual orientation;
  • (only with your consent) religious belief;
  • (only with your consent) racial or ethnic origin;
  • information from your government issued ID and relevant tax information as described in Section 1 of the Privacy Policy;
  • biometric Information as described below and in Section 1 of the Privacy Policy;
  • content of messages and chats;
  • content of live streams, including video and audio, pictures, images, posts and broadcasts; and
  • device or browser information, including your mobile device identification (AdID (Google), IDFA (Apple),
  • device ID, etc.), and IP address as further described in Section 1 of the Privacy Policy.

Your personal data may be processed under joint control as necessary for the purpose of providing the following functionalities related to Live:

  • enable participation in the chat related to Live to communicate with other users utilizing same;
  • enable participation in live streams via Live;
  • moderation of the use of live streams;
  • supporting (e.g., training) users with respect to becoming live streamers via Live;
  • talent and VIP management;
  • management of virtual gifts in the context of live streams;
  • fraud prevention;
  • age verification; and
  • customer support.

4. SEPARATE INDEPENDENT CONTROLLER

For other processing activities, we and our Live Partners are separate controllers; for example, with respect to the following non-exhaustive list of processing operations:

  • any processing of personal data by the Live Partner in the context of the provision of the Partner App;
  • any analysis of user behavior by the Live Partner in the Partner App; and
  • any processing of personal data by us when providing services other than Live.

We may receive the categories of personal data outlined in this Section from the Live Partners identified in the Partner List, depending on which application you are using to access Live.

5. PROCESSING PURPOSES AND RELEVANT LEGAL BASES FOR SERVICES

We will only process your personal information where we have a legal basis to do so. We may process your personal information to:

  • Provide you with Live and related functionality (we rely on the legal basis "performance of a contract" (Art. 6(1)(b) of the GDPR)).
  • With respect to location data, we rely on your consent (Art. 6(1)(a), Art. 7 GDPR).
  • With respect to sexual orientation, we rely on your explicit consent (Art. Art. 6(1)(a), Art. 7, Art. 9(2)(a) GDPR) or on the exception in Art. 9 (2) (e) GDPR provided that you have publicly disclosed your sexual orientation (e.g., in a live stream).
  • For moderating live streams; for such processing, we rely on the legal basis "legitimate interests" (Art. 6(1)(f) GDPR). In this regard, we pursue our, or Live Partners' and other users' (who are participating in Live) interests in providing the live streams in a pleasant and safe environment.
  • To analyze user behavior related to Live and to create anonymized usage information based on such analysis; for such processing, we rely on the legal basis "legitimate interests" (Art. 6(1)(f) GDPR). In this regard, we pursue our interest in understanding how Live is used.
  • To prevent fraudulent behavior, we rely on the legal basis "legitimate interests" (Art. 6(1)(f) GDPR). In this regard, we pursue protecting our interest and that of users from fraudulent behavior and related potential damages.
  • To show advertisements to users; for such processing, we rely on your consent (Art. 6(1)(a), Art. 7 GDPR).
  • To carry out potential sales of all or part of our asset(s) and/or activities; for such processing we rely on the legal basis "legitimate interests" (Art. 6(1)(f) GDPR). In this regard, we have an interest in potentially disclosing and otherwise processing information regarding our assets and activities to potential buyers or acquirers, and their external counsel to facilitate sales of such assets and/or activities.
  • To comply with legal obligations to which we are subject; for such processing, we rely on the legal basis (i) "compliance with legal obligations" (Art. 6(1)(b) GDPR where such obligation originates from EU or EU Member State law or (ii) "legitimate interests" (Art. 6(1)(f) GDPR) where such obligation originates from other law. Where legitimate interests are relevant, we pursue the interest of the company in complying with legal obligations to which we are subject.
  • To safeguard our rights; for such processing, we rely on the legal basis "legitimate interests" (Art. 6(1)(f) GDPR). In this regard, we pursue our interests establishing, exercising and defending legal claims.
  • To carry out talent and VIP management, we rely on the legal basis "legitimate interests" (Art. 6 (1) (f) GDPR). In this regard, we pursue our and our Live Partners’ interests in identifying, recruiting, and training users to become live streamers and in managing VIP programs for users who give virtual gifts to streamers.
  • With respect to biometric data (verification of user identity via facial recognition takes place only when there is a reasonable suspicion that a user is not the person he or she claims to be), we process such data for the establishment, exercise or defense of legal claims (Art. 9 (2) (f) GDPR).
  • To verify the age of users who wish to use the live streaming function of LIVE, we generally rely on the legal basis "legitimate interests" (Art. 6 (1) (f) GDPR). In this regard, we pursue our and our Live Partners’ interests in protecting minors from any harm that might result from presenting themselves to a broader audience via live streaming. Exceptionally, if we are unable to estimate whether a user has reached the age of 18 via the age verification process based on a screenshot and scan of the user's face, we will rely on user's explicit consent (Art. 6 (1) (a), Art. 7, Art. 9 (2) (a) GDPR) to allow for an additional possibility for a user to verify user's age based on a scan of user's face and an identification document with a picture of the user (e.g., driver's license). For this purpose, we will compare the biometric data contained in the scan of the user's face against the provided identification document.
  • to send emails and/or push notification related to LIVE (which are not promotional) and respond to requests related to LIVE, we rely on the legal basis "performance of a contract" (Art. 6 (1) (b) GDPR) or - where no contract exists between the relevant LIVE user and us – "legitimate interests" (Art. 6 (1) (f) GDPR). Where we rely on "legitimate interests", we pursue our interests in providing support as well as to answer requests to ensure LIVE-user satisfaction.

6. CATEGORIES OF RECIPIENTS OF PERSONAL DATA

In relation to us, only authorized personnel with appropriate responsibilities have access to your personal data. In addition, we may share your personal data with the following categories of recipients:

We may share your personal data with service providers that process personal data on our behalf and subject to our instructions as so-called processors, for the purpose of providing their professional services to us:

  • IT service providers (e.g., server hosting provider); and
  • Service providers, including for video streaming and content moderation.
  • Furthermore, we may share your personal data with the following third parties:
  • Live Partners as referenced in the Partner List;
  • Law Enforcement (to comply with legal obligations);
  • Consultants (lawyers and auditors) and courts (to comply with legal obligations and/or safeguard our rights);
  • Potential buyer or acquirer of all or part of our asset(s) and/or activities;
  • Marketing and Business Partners; and
  • Advertising Partners.

With respect to payment services provider(s) / app store operators: no payment data is collected or processed by us (or our Live Partners) when a purchase is made. The privacy policy of the respective payment service provider / app store operator will apply.

7. TRANSFERS OF PERSONAL DATA IN THE CONTEXT OF COUNTRIES LOCATED OUTSIDE THE EEA/UK

Recipients of personal data may be located outside the EEA/UK. Where personal data is transferred to locations outside the EEA/UK (which includes transfers from us in the USA as a controller in scope of GDPR to recipients in the USA or other countries outside the EEA/UK, which are not in scope of GDPR), we will, as required by law, ensure that your privacy rights are adequately protected either because the European Commission has decided that the country to which personal data is transferred ensures an adequate level of protection (Art. 45 GDPR) or the transfer is subject to appropriate safeguards (e.g., standard data protection clauses with the recipient) (Art. 46 GDPR) unless GDPR provides for an exception (Art. 49 GDPR). In addition to this, we intend to, where necessary, agree on additional measures with recipients to ensure an adequate level of data protection. Copies of appropriate safeguards (to the extent we rely on such) and a list of recipients located outside the EEA/UK can be requested at support@themeetgroup.com. Please note that such copy may be redacted to the extent necessary to protect business secrets or other confidential information.

8. STORAGE DURATION

Your personal data will generally only be stored until the personal data is no longer necessary in relation to the purposes for which it was collected (or otherwise processed).

Your live video streams in Live will not be retained after the stream ends, subject to limited exceptions, for example, if some information is required to be retained for compliance with legal obligations or as part of Live streaming moderation activities.

9. DATA PROTECTION RIGHTS

You have the following rights provided that the legal requirements pursuant to GDPR are met:

  • Right of access. You may request information about the processing of your personal data and a copy of the personal data undergoing processing insofar as such copy does not adversely affect the rights and freedoms of others.
  • Right to rectification. You may request correction of your personal data that is inaccurate and/or completion of such data which is incomplete.
  • Right to erasure. You may request deletion of your personal data, in particular where (i) the personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed, (ii) you objected to the processing and there are no overriding legitimate interests for the processing, (iii) your personal data has been unlawfully processed or (iv) your personal data has to be erased for compliance with a legal obligation to which we are subject. The right to deletion, however, does not apply in particular where the processing of your personal data is necessary for compliance with a legal obligation or for the establishment, exercise or defense of legal claims.
  • Restriction of processing. You may request restriction of processing (i) for the period in which we verify the accuracy of your personal data if you contested the accuracy of the personal data, (ii) where the processing is unlawful and you request restriction of processing instead of deletion of the data, (iii) where we no longer need the personal data, but you require the data for the establishment, exercise, or defense of legal claims, or (iv) if you objected to processing until it has been verified whether our legitimate grounds override your interests, rights, and freedoms.
  • Right to data portability. You may request to receive your personal data, which you have provided to us, in a structured, commonly used machine-readable format and transmit the data to another controller without hindrance from us, where the processing is based on consent or a contract and the processing is carried out by automated means; in these cases, you may also request to have the personal data transmitted directly to another controller where this is technically feasible.
  • Right to withdraw consent. You may withdraw your consent at any time for the future where processing is based on your consent, without affecting the lawfulness of processing based on consent before its withdrawal.
  • Right to object. You have the right to object, on grounds relating to your particular situation, at any time to processing of your personal data which is based on our or a third party’s legitimate interest (Art. 6 (1)(f) GDPR). We then will no longer process your personal data for the purpose to which you have objected, unless we are able to demonstrate compelling legitimate grounds for the processing which override your interests, rights, and freedoms or for the establishment, exercise, or defense of legal claims.
  • Further, you have the right to object at any time to processing of your personal data for direct marketing purposes. Where you object to processing for direct marketing purposes, we will no longer process your personal data for such purposes.
  • Right to lodge a complaint. You may lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work, or place of an alleged infringement if you consider that the processing of your personal data infringes the GDPR.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. We reserve the right to keep any information in our archives that we deem necessary to comply with our legal obligations, resolve disputes and enforce our agreements. Note that all of these rights are subject to applicable exemptions and restrictions, they are not absolute rights, and we will provide information to you if we need to rely on these exemptions or restrictions in our response. If you wish to exercise your data protection rights (other than the right to lodge a complaint with a data protection authority) in the context of Live, please contact us at by using one of the following methods: