LEGAL BASES FOR PROCESSING

Last updated 2022-07-06

The table below describes all the purposes for which we collect, use, share, and otherwise process Personal Information of our users through the Grindr Services, the categories of Personal Information, the lawful basis under which we process Personal Information (where required by law), the source of the Personal Information, and the categories of recipients of Personal Information. Grindr retains and deletes Personal Information pursuant to its data retention policy [LEARN MORE] and has established appropriate technical and organizational security controls to protect Personal Information.

Grindr is a U.S.-based company with no EEA/EU/UK establishments at this time. By using the Grindr Services, you are transmitting information to Grindr in the United States and its service providers (in the United States and third countries). If you are a resident of another country, note that the United States, and other third countries, may not afford the same privacy protections as your country of residence. We will take steps to ensure that transfers of Personal Information are in accordance with applicable law, carefully managed to protect your rights and limited to countries which are recognized as providing an adequate level of legal protection (or where we can be satisfied that alternative arrangements are in place to protect your rights). To this end:

We have a dedicated data security team that actively works to monitor the integrity and safety of the Grindr Services. We have policies and protocols in place to help protect Personal Information. We consistently strive to improve our defenses in the ongoing battle against bad actors. That said, no method of transmission over the Internet, or method of electronic storage, is fully secure, and Grindr cannot guarantee the security of your Personal Information.

Processing Purpose Categories of Personal Information (as listed in the “Personal Information Collected” section) Legal Basis Data Source Shared With (outside of Grindr) [LEARN MORE]
1. Provide you with the Services associated with your Grindr account, which may include:
  • Facilitating communications between App users, including messages, photos, audio calls, video calls, videos or audio at your request.
  • Troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data.
  • Processing your location to allow you to use our services.
  • Sending service notifications and displaying first party ads. 
  • Processing your purchases and transactions.
The Personal Information you are required to provide for creating a Grindr account generally includes your email, phone number and password. If you are registering for an account through Facebook or Google log-in, those respective credentials will be required when utilizing those methods.

We may need to process Personal Information you have the option to provide (including Location Information) in order to facilitate communications between you and other App users.

In the course of your interactions through the App or with any other Grindr Services, we may identify the device you use to access the Grindr Services and certain activities you conduct through the Personal Information we receive from your device. Such Personal Information generally includes hardware and software information (e.g., device make, model, and carrier), user activity data (e.g., user profiles you have viewed, products and services purchased), and information obtained via cookies.

Please note that we may receive Personal Information from third parties about your purchases (e.g., from our payments service providers).
Performance of Contract
  • You
  • Your Device
  • Service providers
  • Service providers
  • Other Partners
2. Answer your inquiries and provide you with support. In addition to the categories of data mentioned above, we may need to process additional Personal Information you have the option to provide for the purposes of answering your requests (e.g., you may want to disclose some of your messages with other users when reporting inappropriate behavior or disclose additional information about you to support the report). Performance of Contract
  • You
  • Your device
  • Service providers
3. Improve our services and ensure safety within the App (including machine learning and automated decision making), which may include:
  • Providing or enhancing our security features, including authentication, anti-spam, fraud protection, quality assurance, abuse prevention controls, and investigating, preventing, or responding to suspected illicit activities.
  • Collecting statistical information about the use of the App and Services
  • Identifying, blocking, and/or removing illicit content or activity through machine learning algorithms
We may need to process:
  • Personal Information you are required to provide*;
  • Personal Information we receive from your device when you use Grindr Services;
  • Personal Information you have the option to provide; and
  • Personal Information we may receive from third parties.
*Note that we do not use Personal Information you are required to provide, such as email address and password, for statistical purposes.
Legitimate Interest – it is in our interests to analyze the way in which Users are accessing and using our Services so that we can continually enhance our security features and accurately generate and maintain internal user counts and metrics.
  • You
  • Your device
  • Service providers
4. Protect our interests as a company for different purposes, such as:
  • Enforcing the Grindr Terms of Service
  • Assessing claims that any content violates the rights of third parties
  • Answering customer requests
  • Protecting the rights, property or personal safety of Grindr, its users or the public
  • Establishing or exercising our legal rights or defending against legal claims
We may need to process:
  • Personal Information you are required to provide;
  • Personal Information we receive from your device when you use Grindr Services;
  • Personal Information you have the option to provide; and
  • Personal Information we may receive from third parties.
Legitimate Interest – it is in our legitimate interests to protect our legal rights, defend legal claims and to protect our Users and third parties from harm
  • You
  • Your device
  • Service providers
5. Allow you to enjoy certain App and Service features such as:
  • Enabling you to make any information that you choose to provide in your Profile (“About Me”) visible and available to other Grindr users
  • Sending you notifications and reminders based on the data you have voluntarily provided to us (e.g., testing reminders)
  • Presenting public service messaging or similar communications based on your Personal Information (e.g., Profile Information or use of the Grindr Services)
  • Facilitating communications between App users, including messages, photos, calls, video calls, videos or audio at your request, where such communications include special categories of data.
  • Accessing your camera, photo roll, and microphone to allow you to include photos in your public profile, and photos, audio, and live video messages in your private and group messages at your request.
  • Accessing your location to allow you to share your current location in your private and group messages at your request.
  • Enabling you to backup your locally-stored account information (e.g., chats, favorites, profile information and photos).
  • Personalizing and customizing your experience on the Grindr Services by providing tailored recommendations through machine learning and automated-decision making.

We may need to process:

  • Personal Information you are required to provide;
  • Personal Information we receive from your device when you use Grindr Services;
  • Personal Information you have the option to provide; and
  • Personal Information we may receive from third parties.

Please note:

  • You may need to adjust your device settings or permissions to enjoy certain App features (e.g., allowing Grindr to access your microphone for sending audio to other Grindr users, or allowing Grindr to process your location for sending your current location to other Grindr users - (note: the location you share is not updated once shared). You are also required to disclose certain information in your Profile (e.g., self-reported health information), which is visible to other Grindr users, to utilize certain App features (e.g., testing reminders).
  • If you do not grant the necessary permissions, or if you do not disclose the required information, such features may not work correctly.
  • Profile Information will not be shared with third-party partners except with Service Providers that support the core functionality of the App.
  • If you do not provide consent, you will be opted out of a personalized/customized experience enabled by machine learning and automated decision-making while using the Grindr Services.
Consent
  • You
  • Your device
  • Service providers
  • Other Partners
6. Allow third-party ad / marketing partners to use cookies and other technologies on the Grindr Services for the purposes of serving ads. In order to serve ads (i.e., displaying ads, personalizing ads, measuring ad performance, etc.), we may need to process:
  • Personal Information we receive from your device when you use Grindr Services (e.g., advertising ID and IP address); and
  • Personal Information we may receive from third parties (e.g, consent preferences).
Consent
  • You
  • Your device
  • Third Parties
  • Ad / Marketing Partners
7. Conduct surveys or obtain your feedback about our Services. We may invite you to participate, on a voluntary basis, in surveys about our Services. Such surveys allow us, for example, to research your behaviors to improve our Services.

If you choose to participate in surveys, we may need to process Personal Information you have the option to provide (e.g., your answers to our questions, testimonials, feedback).
Consent
  • You
  • Your device
  • Service providers
8. Respond to legal requests from law enforcement agencies, regulators, and other third parties to comply with legal obligations. We may need to process:
  • Personal Information you are required to provide;
  • Personal Information we receive from your device when you use the Grindr Services;
  • Personal Information you have the option to provide; and
  • Personal Information we may receive from third parties.
Comply with Legal Obligations - in response to requests from EEA member states

Legitimate Interest - it is in our interests to comply with the laws to which we are subject outside of the EEA
  • You
  • Your device
  • Requestor related to Legal Obligations