First Round Is On Me, Inc. (“FROM”, “we”, “us”, or “our”) has prepared this Privacy Policy to explain (1)  what personal information we collect, (2) how we use and share that information, and (3) your choices concerning our privacy and information practices.  

This Privacy Policy applies to personal information that we collect in connection with our website located at https://www.firstroundsonme.co/ (the “Site”) and through our mobile application and related technologies (“Mobile App”, and collectively, such Mobile App and the Site, including any updated or new features, functionality and technology, the “Service”).  

• Account information, such as your name, username and password, email, billing address, birthday,  phone number, and other similar information when you create an account with us.  

• Profile information, such as any photos or videos you wish to upload, as well as additional information about yourself for your dating profile, such as your school, occupation, current city,  demographic, gender, gender preference and sexual orientation, religious beliefs, and other details about your personality and lifestyle.  

• Service communication information, such as content you publish or texts, messages, and other communications that you have with other users of the Service.  

• Payment and transaction information needed to subscribe to a paid service, including name,  payment card information, and billing information. Our payment processors process your payment information, and we do not have direct access to any credit card information.  

• Feedback or correspondence, such as information you provide when you contact us with questions,  feedback, product reviews, or otherwise correspond with us online.  

• Marketing information, such as your preferences for receiving communications about our activities,  events, and publications, and details about how you engage with our communications.  

• Other information that we may collect which is not specifically listed here in order to provide the  Service, but which we will use in accordance with this Privacy Policy or as otherwise disclosed at the time of collection.  

• Facebook. We may access and process certain Facebook account information if you use choose to use your Facebook account to log into your FROM account. 

• Other Users. We may receive information about you from other users of the Service, including through customer support inquiries. 

• Social media information. We may maintain pages on social media platforms, such as Facebook,  LinkedIn, Instagram, and other third-party platforms. When you visit or interact with our pages on those platforms, the platform provider’s privacy policy will apply to your interactions and their collection, use, and processing of your personal information. You or the platforms may provide us with information through the platform, and we will treat such information in accordance with this  Privacy Policy.  

• Third-Party Services. We may obtain your personal information from other third parties, such as marketing partners, data providers, and publicly available sources.  

Automatic data collection. We and our service providers may automatically log information about you,  your computer or mobile device, and your interaction over time with the Service, our communications  and other online services, such as:  

• Device data, such as your computer’s or mobile device’s operating system type and version,  manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., WiFi, LTE,  4G), and general location information such as city, state or geographic area.  

• Activity data, such as the pages or screens you viewed, conversations, how long you spent on a page or screen, browsing history, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access.  

• Cookies, which are text files that websites store on a visitor’s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you  navigate between pages efficiently, remembering your preferences, enabling functionality,  helping us understand user activity and patterns, and facilitating online advertising.  

• Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications.  

• Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked. 

• Provide, operate, maintain, secure, and improve the Service.  

• Fulfill payments and transactions.  

• Provide information about the Service. 

• Communicate with you about the Service, including by sending you announcements, updates,  security alerts, and support and administrative messages.  

• Understand your needs and interests, and personalize your experience with the Service and our communications.  

• Respond to your requests, questions, and feedback.  

• Recommend meaningful connections with users based on your and others’ profiles.  

For marketing and advertising. We may collect and use your personal information for marketing and  advertising purposes, including:  

• Direct marketing. If you have opted-in to receiving marketing communications, we may from time to-time send you direct marketing emails as permitted by law, including, but not limited to,  notifying you of special promotions, offers and events. 

To comply with the law. As we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal processes, such as to respond to subpoenas or requests from government authorities.  

For compliance, fraud prevention, and safety. To: (a) protect our, your or others’ rights, privacy, safety, or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern the Service; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized,  unethical or illegal activity.  

For research and development. We may create and use de-identified information for our business purposes, including to analyze the effectiveness of the Service, to improve and add features to the  Service, and to analyze the general behavior and characteristics of users of the Service. We may use this anonymous, aggregated, or de-identified data and share it with third parties for our lawful business purposes. 

If you are an individual in the United Kingdom or European Economic Area (EEA), we collect and process information about you only where we have legal bases for doing so under applicable United Kingdom and/or EU laws. The legal bases depend on the Service you use and how you use them. This means we  collect and use your information only where:  

• We need it to provide you with the Service, including operating the Service, providing customer  support and personalized features, and to protect the safety and security of the Service;  

• It satisfies a legitimate interest (which is not overridden by your data protection interests), such  as for research and development, to market and promote the Service, and to protect our legal  rights and interests;  

• You give us consent to do so for a specific purpose; or  

• We need to process your data to comply with a legal obligation.  

If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. 

Where we are using your information because we or a third party (e.g. your employer) have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer using the Service.  

FROM is headquartered in the United States. To provide and operate the Service, it is necessary for us to  process your personal information in the United States. If we transfer personal information across borders such that we are required to apply appropriate safeguards to personal information under applicable data protection laws, we will do so. Please contact us for further information about any such transfers or the specific safeguards applied.  

We will not share, rent, sell or otherwise disclose any personal information we collect about you through the Service to any third party, except as set forth below.  

Other Users. Information that you have voluntarily provided for your public profile will be shared with other users. If someone submits a report involving you (such as a claim you violated our Terms of  Service), we may let the reporter know what actions we took, if any, as a result of their report. The same applies if you submit a report involving another user.  

Service providers. We may share your personal information among our affiliates or with third-party companies that provide services on our behalf or help us operate the Service (such as customer support,  hosting, analytics, email delivery, marketing, and billing), including to enable that party to perform business,  professional, or technical support for us.  

For compliance, fraud prevention and safety. We may share your personal information for the compliance, fraud prevention, and safety purposes described above. 

Business transfers. We may sell, transfer, or otherwise share some or all of our business or assets,  including your personal information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution. In such a case, we will make reasonable efforts to require the recipient to honor this Privacy Policy.  

Through your use of the Service. When you use the Service, we may share your profile information with other users of the Service or assist with facilitating your communications with users that you choose to interact with.  

In this section, we describe the rights and choices available to all users.  

Opt out of marketing communications. You may opt out of marketing-related communications by following the opt-out or unsubscribe instructions within the marketing communication we send you.  

Cookies. Most browser settings let you delete and reject cookies placed by websites. Many browsers accept cookies by default until you change your settings. If you do not accept cookies, you may not be able to use all functionality of the Site and it may not work properly. For more information about 

cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org.  

Online tracking opt-out. There are a number of ways to opt out of having your online activity and device  data collected through the Site, which we have summarized below:  

• Blocking cookies in your browser. Most browsers let you remove or reject cookies, including cookies used for interest-based advertising. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit allaboutcookies.org.  

Use the following links to learn more about how to control cookies and online tracking through your  browser:  

o Firefox; Chrome; Microsoft Edge; Safari 

• Blocking advertising ID use in your mobile settings. Your mobile device settings may provide functionality to limit the use of the advertising ID associated with your mobile device for interest-based advertising purposes.  

• Using privacy plug-ins or browsers. You can block the Service from setting cookies used for interest-based ads by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, DuckDuckGo, Ghostery, or uBlock Origin, and configuring them to block third-party cookies/trackers.  

• Platform opt-outs. Some third-party ad networks, including third-party ad servers, ad agencies, ad technology vendors, and research firms, allow you to opt-out directly by using their opt-out tools.  Some of these providers, and links to their opt-out tools, are:  

o Google  

o Facebook 

• Advertising industry opt-out tools. You can also use these opt-out options to limit the use of your  information for interest-based advertising by participating companies:  

o Digital Advertising Alliance  

o Network Advertising Initiative  

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.  

Personal information requests: In certain circumstances (including based on where you are located), you  may have the following rights in relation to your personal information:  

• the right to learn more about what personal information of yours is being processed, how and why such information is processed, and the third parties who have access to such personal information. We have made this information available to you without having to request it by  including it in this Privacy Policy;  

• the right to access your personal information;  

• the right to rectify/correct your personal information; 

• the right to restrict the use of your personal information where permitted under applicable law;  

• the right to request that your personal information is erased/deleted where permitted under  applicable law;  

• the right to data portability (i.e. receive your personal information or have it transferred to  another controller in a structured, commonly-used, machine-readable format) where permitted  under applicable law; and  

• the right to object to the processing of your personal information or to direct us not to share your personal information with a non-affiliated third party where permitted under applicable law.  

To make a request, please email us as provided in the “How to Contact Us” section below. We may ask for specific information from you to help us confirm your identity. We will require authorized agents to confirm their identity and authority, in accordance with applicable laws. You are entitled to exercise the rights described above free from discrimination.  

In addition, where you have provided your consent to the processing for the purposes indicated above, you may withdraw your consent at any time (or otherwise exercise your aforementioned rights in relation to your personal information) by contacting us below(see contact details below).  

Please note that in some circumstances, we may not be able to fully comply with your request, for example, if we are required to retain certain information about you to comply with applicable laws and regulations or if the information is necessary in order for us to provide the services you requested. In particular, we, and our collection and processing of your personal information, may be governed by laws and regulations on anti-money laundering, fraud prevention, taxation, and financial services. We will not discriminate against you for exercising your rights. We will not deny you access to the Service, or provide you a lower quality of services if you exercise your rights.  

You also have the right to lodge a complaint with the relevant authority (as applicable) or a supervisory authority in the UK or EU member state of your usual residence or place of work or of the place of the alleged breach, if you consider that the processing of your personal information carried out by FROM or any of our affiliates or third-party service providers, has breached data protection laws.  

You may also appeal to certain courts against (A) any failure of the relevant authority to give written notice of whether the complaint is either being investigated or not being investigated and, where applicable, the progress and the outcome of the investigation or (B) a determination of the relevant authority not to investigate the complaint or a determination that a controller or processor has not breached or is not likely to breach an operative provision in connection with the complaint.  

The Service may contain links to other websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We do not control third-party websites, mobile applications, or online services, and we are not responsible for their actions. Other websites and services follow different rules regarding the collection, use, and sharing of your personal information. We encourage you to read the privacy policies of the other websites mobile applications and online services you use. 

We retain your personal information for as long as appropriate to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for your personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of personal information, the purposes for which we process personal information, and whether we can achieve those purposes through other means, and the applicable legal requirements.  

We use organizational, technical, and administrative measures designed to protect against unauthorized access, misuse, loss, disclosure, alteration, and destruction of personal information we maintain.  Unfortunately, data transmission over the Internet cannot be guaranteed as completely secure.  Therefore, while we strive to protect your personal information, we cannot guarantee the security of personal information.  

The Service is not intended for use by children under 18 years of age. If we learn that we have collected personal information through the Service from a child under 18 without the consent of the child’s parent or guardian as required by law, we will delete it.  

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this  Privacy Policy, we will notify you by updating the date of this Privacy Policy.  

Please direct any questions or comments about this Privacy Policy or privacy practices to  support@firstroundsonme.co