Legal Bases for Processing

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Effective Date: The earlier of 2024-09-15 or user acknowledgment.

The table below describes all the purposes for which we collect, use, share, and otherwise process Personal Information of our users through the Grindr Properties, 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.

We have a dedicated data security team that actively works to monitor the integrity and safety of the Grindr Properties. 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.

Note: Legal bases apply as required under applicable law to individuals in certain jurisdictions such as Brazil, EU/EEA, and UK. The processing purposes listed below are applicable regardless of your jurisdiction.

<table>
<tbody>
<tr>
<td>
Processing Purpose
</td>
<td>
Categories of Personal Information (as listed in the
"Personal Information Collected" section)
</td>
<td>
Legal Basis
</td>
<td>
Data Source
</td>
<td>
Shared With (outside of Grindr) <a href="/privacy-policy/third-parties/">[LEARN MORE]</a>

</td>
</tr>
<tr>
<td>
1. Provide you with the Services
associated with your Grindr account, which may
include:
<ul>
<li>Facilitating communications between users of the
Services, including messages, photos, audio calls, video
calls, videos or audio at your request.</li>
<li>Troubleshooting, data analysis, testing, system
maintenance, support, reporting, and hosting of data.
</li>
<li>Processing your location to allow you to use our
Services.</li>
<li>Sending service notifications and displaying first party
ads.</li>
<li>Processing your purchases and transactions.</li>
</ul>
</td>
<td>
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 your Location
information) in order to facilitate communications between
you and other users of the Services. 
 
In the course of your interactions through the Service or
with any other Grindr Properties, we may identify the device
you use to access the Grindr Properties and certain
activities you conduct through the Personal
Information We Receive From Your Device When You Use The
Grindr Properties. 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 We
Receive From Third Parties about your
purchases (e.g., from our payments service providers).

</td>
<td>
Performance of Contract
</td>
<td>
<ul>
<li>You</li>
<li>Your Device</li>
<li>Service Providers</li>
</ul>
</td>
<td>
<ul>
<li>Service Providers</li>
<li>Other Partners</li>
</ul>
</td>
</tr>
<tr>
<td>
2. Answer your inquiries and provide you with
support.
</td>
<td>
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).
</td>
<td>
Performance of Contract
</td>
<td>
<ul>
<li>You</li>
<li>Your Device</li>
</ul>
</td>
<td>
<ul>
<li>Service Providers</li>
</ul>
</td>
</tr>
<tr>
<td>
3. Improve our Properties and ensure safety within
the Services (including machine learning/AI and
automated decision making), which may include:
<ul>
<li>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.</li>
<li>Collecting statistical information about the use of the
Services and Properties</li>
<li>Identifying, blocking, and/or removing illicit content
or activity through /AI algorithms</li>
</ul>
</td>
<td>
We may need to process:
<ul>
<li>Personal Information You Are Required To
Provide*;</li>
<li>Personal Information We Receive From Your Device
When You Use The Grindr Properties;</li>
<li>Personal Information You Have The Option To
Provide; and</li>
<li>Personal Information We Receive From Third
Parties.</li>
</ul>
*Note that we do not use Personal Information You Are
Required To Provide, such as email address and
password, for statistical purposes.
</td>
<td>
Legitimate Interest - it is in our interests
to analyze the way in which Users are accessing and using
our Properties so that we can continually enhance our
security features and accurately generate and maintain
internal user counts and metrics.
</td>
<td>
<ul>
<li>You</li>
<li>Your Device</li>
</ul>
</td>
<td>
<ul>
<li>Service Providers</li>
</ul>
</td>
</tr>
<tr>
<td>
4. Protect our interests as a company for
different purposes, such as:
<ul>
<li>Enforcing the Grindr Terms of Service</li>
<li>Assessing claims that any content violates the rights of
third parties</li>
<li>Answering customer requests</li>
<li>Protecting the rights, property or personal safety of
Grindr, its users or the public</li>
<li>Establishing or exercising our legal rights or defending
against legal claims</li>
</ul>
</td>
<td>
We may need to process:
<ul>
<li>Personal Information You Are Required To
provide;</li>
<li>Personal Information We Receive From Your Device
When You Use The Grindr Properties;</li>
<li>Personal Information You Have The Option To
Provide; and</li>
<li>Personal Information We Receive From Third
Parties.</li>
</ul>
</td>
<td>
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
</td>
<td>
<ul>
<li>You</li>
<li>Your Device</li>
</ul>
</td>
<td>
<ul>
<li>Service Providers</li>
</ul>
</td>
</tr>
<tr>
<td>
5. Allow you to enjoy certain Service and Property
features such as:
<ul>
<li>Enabling you to make any information that you choose to
provide in your Profile ("About Me") or in your post
associated with a Right Now session visible and
available to other Grindr users</li>
<li>Sending you notifications and reminders based on the
data you have voluntarily provided to us (e.g., testing
reminders)</li>
<li>Presenting public service messaging or similar
communications based on your Personal Information (e.g.,
Profile Information or use of the Grindr Services)</li>
<li>Facilitating communications between users of the
Services, including messages, photos, calls, video
calls, videos or audio at your request, where such
communications include special categories of data.</li>
<li>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.</li>
<li>Accessing your location to allow you to share your
current location in your private and group messages at
your request.</li>
<li>Engaging in training to improve data models to support
the Grindr Services (e.g., personalization and chatbots)
</li>
<li>Personalizing and customizing your experience on the
Grindr Services by providing tailored recommendations
through machine learning/AI and automated-decision
making.</li>
</ul>
</td>
<td>
We may need to process:
<ul>
<li>Personal Information You Are Required To
Provide;</li>
<li>Personal Information We Receive From Your Device
When You Use The Grindr Properties;</li>
<li>Personal Information You Have The Option To
Provide, including sensitive Personal Information;
and</li>
<li>Personal Information We Receive From Third
Parties.</li>
</ul>
Please note:
<ul>
<li>You may need to adjust your device settings or
permissions to enjoy certain features of the Services
(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 features of the
Services (e.g., testing reminders).</li>
<li>If you do not grant the necessary permissions, or if you
do not disclose the required information, such features
may not work correctly.</li>
<li>Profile Information will not be shared with third-party
partners except with Service Providers that support the
core functionality of the Services.</li>
<li>If you do not provide consent to process select
categories of Personal Information (e.g., sensitive
Personal Information), you will be opted out of data
model training and/or a personalized/customized
experience enabled by machine learning/AI and automated
decision-making while using the Grindr Services.</li>
</ul>
</td>
<td>
Consent
</td>
<td>
<ul>
<li>You</li>
<li>Your Device</li>
</ul>
</td>
<td>
<ul>
<li>Service Providers</li>
<li>Other Partners</li>
</ul>
</td>
</tr>
<tr>
<td>
6. Allow third-party ad / marketing partners to use
cookies and other technologies on the Grindr Services
for the purposes of serving ads.
</td>
<td>
In order to serve ads (i.e., displaying ads, personalizing
ads, measuring ad performance, etc.), we may need to
process:
<ul>
<li>Personal Information We Receive From Your Device
When You Use The Grindr Properties (e.g.,
advertising ID and IP address); and</li>
<li>Personal Information We Receive From Third
Parties (e.g., consent preferences).</li>
</ul>
</td>
<td>
Consent
</td>
<td>
<ul>
<li>You</li>
<li>Your Device</li>
<li>Third Parties</li>
</ul>
</td>
<td>
<ul>
<li>Ad / Marketing Partners</li>
</ul>
</td>
</tr>
<tr>
<td>
7. Conduct surveys or obtain your feedback about our
Properties.
</td>
<td>
We may invite you to participate, on a voluntary basis, in
surveys about our Properties. Such surveys allow us, for
example, to research your behaviors to improve our
Properties. 
 
If you choose to participate in surveys, we may need to
process Personal Information You Have The Option To
Provide, including sensitive Personal Information
(e.g., your answers to our questions, testimonials,
feedback), which may include using this information for the
purposes of audience segmentation.

</td>
<td>
Consent
</td>
<td>
<ul>
<li>You</li>
<li>Your Device</li>
</ul>
</td>
<td>
<ul>
<li>Service Providers</li>
</ul>
</td>
</tr>
<tr>
<td>
8. Respond to legal requests from law enforcement
agencies, regulators, and other third parties to comply
with legal obligations.
</td>
<td>
We may need to process:
<ul>
<li>Personal Information You Are Required To
Provide;</li>
<li>Personal Information We Receive From Your Device
When You Use The Grindr Properties;</li>
<li>Personal Information You Have The Option To
Provide, including sensitive Personal Information;
and</li>
<li>Personal Information We Receive From Third
Parties.</li>
</ul>
</td>
<td>
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

</td>
<td>
<ul>
<li>You</li>
<li>Your Device</li>
</ul>
</td>
<td>
<ul>
<li>Requestor related to Legal Obligations</li>
</ul>
</td>
</tr>
</tbody>
</table>

Controller: Grindr LLC
Controller and Data Protection Officer Contact Information: PO Box 69176, West Hollywood, CA 90069. You can also submit a request to contact Grindr's EEA/UK Data Protection Officer (DPO) through our website here and Grindr's Brazil DPO here.

EEA and UK Representative Contact Information: If you are based in the EEA or UK or have GDPR-related inquiries, you may contact our EEA and UK Representative by submitting your request or inquiry to the postal address listed here for your country of residence, by emailing [email protected], or submitting an online form at www.datarep.com/data-request. Please make sure your request is addressed to DataRep and not Grindr LLC.

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