Privacy Policy

Last Updated: December 20, 2023

Thank you for visiting Play Dates. This Privacy Policy outlines how and why we collect, use, disclose, sell, share, store, and retain your personal information. Please read it carefully as it contains important information on who we are and our information practices. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint or request.

We collect, use, and are responsible for certain personal information about you. When we offer goods and services to individuals in the European Economic Area (EEA), we are subject to the EU General Data Protection Regulation (EU GDPR), which applies across the entire European Union. For California consumers, we are subject to the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA). We are responsible as a “controller” of that personal information for the purposes of the GDPR. We are responsible for your personal information as a “business” under the CCPA/CPRA.

Personal Information We Collect About You. Personal information is any information relating to an identified or identifiable individual. We may collect and use the following personal information, including sensitive personal information, that identifies, relates to, describes, is reasonable capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:

Categories of Personal Information

Specific Types of Personal Information Collected

Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers)

Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

Email address

IP address

Billing State

Information you share voluntarily while using the site

Account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account

Username and password

Characteristics of protected classifications under California or federal law.

Sex/Gender identity/Gender expression

Sexual Orientation

Age/date of birth

National Origin (as may be inferred by language preferences)

Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement)

Information about your device, browser, IP address, and online session duration. To provide and improve our services, and to protect our website or app from security threats.

Information about your online activities on our website or app, such as the content you view, download, or share, the ads you click, and the cookies or other technologies that track your preferences

Geolocation data

We do not collect your exact location, but our partners may use your IP address to estimate your region, such as the city or country for analytics or ads. We will ask for your permission before they do so. You can opt-out or change your consent anytime

Professional or employment-related information

Information you voluntarily provide while using the Site

Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (FERPA)

Information you voluntarily provide while using the Site

Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes

Information you voluntarily provide while using the Site

Racial or ethnic origin, religious or philosophical beliefs, union membership, or citizenship or immigration status

Information you voluntarily provide while using the Site

Health Information

Information you share voluntarily while using the Site

Sex life or sexual orientation

Information you voluntarily provide while registering to use the Site

Information you share voluntarily while using the Site

Analytics information as you navigate the Site

Information about how you use our website, such as the pages you view, the time you spend, the links you click, the sources you come from, and the actions you take

If you do not provide personal information required to use the Site, it may delay or prevent your use of the Site.

How Your Personal Information is Collected. We collect personal information from the following categories of sources:

You, directly via our website and/or mobile apps
Third party with your consent (e.g., your bank)
Advertising networks
Internet service providers
Data analytics providers
Government entities
Operating systems and platforms
Social networks
Data brokers
Publicly accessible sources (e.g., property records)
Cookies on our website
Our IT and security systems, including: Automated monitoring of our websites and other technical systems, such as our computer networks and connections, communications systems, email, and instant messaging systems

How and Why We Use Your Personal Information. Under data protection laws, we can only use your personal information if we have a proper reason for doing so, for example:

To comply with our legal and regulatory obligations
For the performance of our contract with you or to take steps at your request before entering into a contract
For our legitimate interests or those of a third party –or–
Where you have given consent

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The table below explains what we use (process) your personal information for and our reasons for doing so:

What we use your personal information for

Our reasons

To provide services to you

For the performance of our contract with you or to take steps at your request before entering into a contract

To prevent and detect fraud against you or playdates.ai

For our legitimate interests or those of a third party, i.e., to minimize fraud that could be damaging for us and for you

Conducting checks to identify our customers and verify their identity (i.e. age verification)

Other processing necessary to comply with professional, legal, and regulatory obligations that apply to our business, e.g., under health and safety regulation or rules issued by our professional regulator]

To comply with our legal and regulatory obligations

Gathering and providing information required by or relating to audits, inquiries or investigations by regulatory bodies

To comply with our legal and regulatory obligations

Ensuring business policies are adhered to, e.g., policies covering security and internet use

For our legitimate interests or those of a third party, i.e., to make sure we are following our own internal procedures so we can deliver the best service to you

Operational reasons, such as improving efficiency, training, and quality control

For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price

Ensuring the confidentiality of commercially sensitive information

For our legitimate interests or those of a third party, i.e., to protect trade secrets and other commercially valuable information

To comply with our legal and regulatory obligations

Statistical analysis to help us manage our business, e.g., in relation to [our financial performance, customer base, product range or other efficiency measures]

For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price

Preventing unauthorized access and modifications to systems

For our legitimate interests or those of a third party, i.e., to prevent and detect criminal activity that could be damaging for us and for you

To comply with our legal and regulatory obligations

Updating and enhancing customer records

For the performance of our contract with you or to take steps at your request before entering into a contract

To comply with our legal and regulatory obligations

For our legitimate interests or those of a third party, e.g., making sure that we can keep in touch with our customers about existing orders and new products

Statutory returns

To comply with our legal and regulatory obligations

Ensuring safe working practices, staff administration and assessments

To comply with our legal and regulatory obligations

For our legitimate interests or those of a third party, e.g., to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you

Marketing our services to:

Existing and former customers
Third parties who have previously expressed an interest in our services
Third parties with whom we have had no previous dealings

For our legitimate interests or those of a third party, i.e., to promote our business to existing and former customers

External audits and quality checks

For our legitimate interests or a those of a third party

To comply with our legal and regulatory obligations

Chatbot Information. When using the Site, you are not communicating with a real person. Our chatbot (your “virtual partner”) is trained based on information you provide to remember your interests and preferences to provide a more tailored, engaging, and intimate experience. Collecting this information allows you to participate with the Site and for your virtual partner to respond to questions and comments. This information is not shared with third-parties except in response to law enforcement agencies and regulatory bodies when required to comply with our legal and regulatory obligations.

Payment Information. We provide paid services for use of the Site. We use a third-party service to process your payment (a “payment processor”). We do not store your credit or debit card, or other payment information. The payment processor’s privacy policy will apply to such information.

Age Verification. Where required by law you may be asked to verify your age, in which case you will be required to upload or email a state issued ID before gaining access to the Site. We will only retain your ID information for so long as may be required pursuant to your state’s law. We will not sell or use the information for any other purpose.

EEA Data Subjects: Promotional Communications. We may use your personal information to send you updates (by email, text message, telephone, or post) about our products and/or services, including exclusive offers, promotions or new products and/or services.

We have a legitimate interest in processing your personal information for promotional purposes (see above “How and why we use your personal information”). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

We will always treat your personal information with the utmost respect and never sell it with other organizations for marketing purposes.

You have the right to opt out of receiving promotional communications at any time by:

Contacting us at privacy@playdates.ai or
Using the “unsubscribe” link in emails or “STOP” number in texts

We may ask you to confirm or update your marketing preferences if you instruct us to provide further products and/or services in the future, or if there are changes in the law, regulation, or the structure of our business.

Who We Share Your Personal Information With. We routinely share personal information with:

Our affiliates, representatives, and/or agents so they can provide support services
Service providers we use to help deliver our products and/or services to you, such as payment service providers
Other third parties we use to help us run our business, such as marketing agencies or website hosts
Third parties approved by you, including social media sites you choose to link your account to or third-party payment providers
Credit reporting agencies
Our insurers and brokers
Our bank(s)

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors, e.g., in relation to the audit of our financials.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

Personal Information We Sold or Shared. In the preceding 12 months, we have not sold or shared any personal information.

10.

How Long Your Personal Information Will Be Kept. We will keep your personal information while you have an account with us or while we are providing products and/or services to you. Thereafter, we will keep your personal information for as long as is necessary:

To respond to any questions, complaints or claims made by you or on your behalf
To show that we treated you fairly –or–
To keep records required by law

We will not retain your personal information for longer than necessary for the purposes set out in this policy.

11.

California Consumers: Your Rights Under the CCPA/CPRA. You have the right under the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA), and certain other privacy and data protection laws, as applicable, to exercise free of charge:

Disclosure of Personal Information We Collect About You

You have the right to know, and request disclosure of:

The categories of personal information we have collected about you, including sensitive personal information
The categories of sources from which the personal information is collected
The categories of third parties to whom we disclose personal information, if any –and–
The specific pieces of personal information we have collected about you

Please note that we are not required to:

Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained
Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information –or–
Provide the personal information to you more than twice in a 12-month period

Disclosure of Personal Information Sold, Shared, or Disclosed for a Business Purpose

In connection with any personal information we may sell, share, or disclose to a third party for a business purpose, you have the right to know:

The categories of personal information about you that we sold or shared and the categories of third parties to whom the personal information was sold or shared –and–
The categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom the personal information was disclosed for a business purpose

You have the right to opt-out of the sale of your personal information or sharing of your personal information for the purpose of targeted behavioral advertising. If you exercise your right to opt-out of the sale or sharing of your personal information, we will refrain from selling or sharing your personal information, unless you subsequently provide express authorization for the sale or sharing of your personal information.

To opt-out of the sale or sharing of your personal information, visit our homepage and click on the Do Not Sell or Share My Personal Information link here: Do Not Sell or Share My Personal Information

Right to Limit Use of Sensitive Personal Information

You have the right to limit the use and disclosure of your sensitive personal information to the use which is necessary to:

Perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services
To perform the following services: (1) Helping to ensure security and integrity to the extent the use of the consumer's personal information is reasonably necessary and proportionate for these purposes; (2) Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of a consumer's current interaction with the business, provided that the consumer's personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer's experience outside the current interaction with the business; (3) Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business; and (4) Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business –and–
As authorized by further regulations

You have a right to know if your sensitive personal information may be used, or disclosed to a service provider or contractor, for additional, specified purposes.

To limit the use of your sensitive personal information, visit our homepage and click on the "Limit the Use of My Sensitive Personal Information" link here: Do Not Sell or Share My Personal Information

Right to Deletion

Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:

Delete your personal information from our records –and–
Delete your personal information from our records –and–
Direct third parties to whom the business has sold or shared your personal information to delete your personal information unless this proves impossible or involves disproportionate effort

Please note that we may not delete your personal information if it is reasonably necessary to:

Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us
Help to ensure security and integrity to the extent the use of the consumer's personal information is reasonably necessary and proportionate for those purposes
Debug to identify and repair errors that impair existing intended functionality
Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law
Comply with the California Electronic Communications Privacy Act
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent
Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us
Comply with an existing legal obligation –or–
Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information

Right of Correction

If we maintain inaccurate personal information about you, you have the right to request us to correct that inaccurate personal information. Upon receipt of a verifiable request from you, we will use commercially reasonable efforts to correct the inaccurate personal information.

Protection Against Retaliation

You have the right to not be retaliated against by us because you exercised any of your rights under the CCPA/CPRA. This means we cannot, among other things:

Deny goods or services to you
Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties
Provide a different level or quality of goods or services to you –or–
Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services

Please note that we may charge a different price or rate or provide a different level or quality of goods and/or services to you, if that difference is reasonably related to the value provided to our business by your personal information. We may also offer loyalty, rewards, premium features, discounts, or club card programs consistent with these rights or payments as compensation, for the collection of personal information, the sale of personal information, or the retention of personal information.

12.

Virginia Consumers: Your Rights Under the VCDPA. Residents of Virginia have certain personal data rights under the Virginia Consumer Data Protection Act (VCDPA) which may be exercised free of charge up to two times per year, provided that in cases where the requests are manifestly unfounded, excessive, or repetitive, we may charge a reasonable fee to cover the administrative costs of complying with the request or decline to comply with the request.

You have the right to:

Confirm whether or not we are processing your personal data and access that data.
Correct inaccuracies in your personal data.
Delete personal data provided by or obtained about you.
Opt-out of the processing of your personal data for targeted advertising.
Opt-out of the sale of your personal data.
Opt-out of profiling performed in furtherance of decisions that produce legal or similarly significant effects.
Non-discrimination or retaliation for exercising any of these rights.

We are required to respond without undue delay but within 45 days of receipt of your request. Depending on factors such as the type and complexity of the request, we may extend the time for response once for an 45 additional days, as long as we notify you within the original 45 days.

If we decline to take action regarding your request, we must notify you without undue delay, but within 45 days of the receipt of the notice and provide information on our appeal process. We are required to provide justification and provide information on the appeal process within a reasonable time after the communication of the decision to decline.

Please note that you may only make a VCDPA-related data access or data portability disclosure request twice within a 12-month period.

13.

Colorado Consumers: Your Rights Under the CPA and How to Exercise Them. Residents of Colorado have certain personal data rights under the Colorado Privacy Act (CPA).

You have the right to:

Opt-out of the processing of your personal data for purposes of:
Targeted advertising
Sale of personal data
Profiling that produces legal or significant effects on you
Access your data and to confirm that your data is being processed by us.
Request deletion of your data held by us.
Request correction of your data held by us.
Receive your requested data in a usable and transferable form.
Non-discrimination or retaliation for exercising any of these rights.
Designate an agent to exercise your rights on your behalf.
Appeal if your request is denied.

Responding to Requests. We are required to respond without undue delay but within 45 days of receipt of your request. Depending on factors such as the type and complexity of the request, we may extend the time for response once for 45 additional days, as long as we notify you within the original 45 days.

You can request information under the CPA free of charge once per year. For a second or subsequent request within a 12-month period, we may charge an amount that is the same for the provision of a public record, which is $0.25 per standard page, or a fee not to exceed the actual cost of providing a copy, printout, or photograph of the record in a format other than a standard page.

How to Exercise Your Rights: If you would like to access your data, confirm that your data is being processed by us, request deletion of your data, request correction of your data, or receive your requested data in a usable and transferable form, you may email/write to us at privacy@playdates.ai.

If you wish to exercise your opt-out rights, you can do so here Do Not Sell or Share My Personal Information. If you wish to designate an agent to exercise your rights on your behalf or are a guardian or conservator exercising consumer rights on behalf of another you can do so here: Do Not Sell or Share My Personal Information. You may also email us at privacy@playdates.ai. If your request to exercise your rights is declined, you may appeal by contacting us at privacy@playdates.ai and following the process found here: Do Not Sell or Share My Personal Information.

Please note that you may only make a CPA-related data access or data portability disclosure request for free once within a 12-month period. Subsequent requests may result in fees as noted above.

If you choose to contact us directly by email, you will need to provide us with:

Enough information to identify you (e.g., your full name, address and customer or matter reference number);
Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and
A description of what right you want to exercise and the information to which your request relates.

We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information or is someone authorized to act on such person's behalf.

Any personal data we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.

14.

EEA Data Subjects: Your Rights Under the EU GDPR.

Right to Be Informed

The right to know or be notified about the collection and use of your personal information.

Right to Access

The right to be provided with a copy of your personal information (the right of access)

Right to Rectification

The right to require us to correct any mistakes in your personal information

Right to Data Portability

The right to receive the personal information you provided to us, in a structured, commonly used, and machine-readable format and/or transmit that data to a third party—in certain situations

Right to Object

The right to object:

At any time to your personal information being processed for direct marketing (including profiling)
In certain other situations to our continued processing of your personal information, e.g., processing carried out for the purpose of our legitimate interests

Right Not to be Subject to Automated Individual Decision-Making

The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

For further information on each of those rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner's Office (ICO) on individual rights under the EU General Data Protection Regulation.

15.

How to Exercise Your Rights. If you would like to exercise any of your rights as described in this Privacy Policy, you can do so here: Do Not Sell or Share My Personal Information. You may also email us at privacy@playdates.ai.

Please note that you may only make a CCPA/CPRA-related data access or data portability disclosure request twice within a 12-month period.

If you choose to contact us directly by email, you will need to provide us with:

Enough information to identify you (e.g., your full name, address and customer or matter reference number)
Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill) –and–
A description of what right you want to exercise and the information to which your request relates
We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information or is someone authorized to act on such person's behalf.
Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.

16.

EEA Data Subjects: Where Your Personal Information is Held. Information may be held at our offices and those of our affiliates, third party agencies, service providers, representatives and agents as described above (see above: “Who We Share Your Personal Information with”).

Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: “Transferring Your Personal Information Out of the EEA.”

17.

EEA Data Subjects: Transferring Your Personal Information Out of the EEA. To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), e.g.:

With our offices outside the EEA
With your and our service providers located outside the EEA
If you are based outside the EEA –or–
Where there is an international dimension to the services we are providing to you

These transfers are subject to special rules under European and UK data protection law.

If you would like further information, please contact us (see “How To Contact Us” below).

18.

Keeping Your Personal Information Secure. We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

19.

EEA Data Subjects: How to File a GDPR Complaint. We hope that we can resolve any query or concern you raise about our use of your information.

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred.

You may find your supervisory authority by visiting this website: EU Data Protection Board Members.

20.

Children’s Privacy. The Site is strictly intended for adults. Anyone under the age if 18 is expressly prohibited from using the Site. We don’t knowingly collect any information from anyone under the age of 18. If you think your child has submitted information to the Site, please contact us and we will remove such information from our records.

21.

Changes to This Privacy Notice. We may change this privacy notice from time to time–when we do, we will inform you via posting a revised policy on the Site or where material changes are made we will contact you by email.

22.

How to Contact Us. Please contact us by email at privacy@playdates.ai or via the Contact Us page on the Site if you have any questions about this privacy policy or the information we hold about you.

23.

Do You Need Extra Help? If you would like this notice in another format (for example: audio, large print, braille) please contact us (see “How to contact us” above).