This Privacy Policy ("Privacy Policy" or "Policy") explains how MatelinkAi Inc. and its affiliates ("MatelinkAi," "we," "our," "us") collect, use, and protect your information.

Unless otherwise indicated, this Policy applies to all websites, mobile applications, and other electronic or digital products and services offered by MatelinkAi that link to this Policy, as well as our offline offerings (collectively, the "Services").

Your use of the Services constitutes your reading and understanding of this Policy. If you do not agree with the practices described in this Policy, please do not use the Services.

Terms not defined in this Policy shall have the meaning assigned to them in the SpicyLovers Terms of Service.

1. Information We Collect

We may collect information about you when you visit or use our Services. The types of information we collect depend on how you use our Services. Please note that we require certain types of information to provide the Services to you. If you do not provide us with such information, or request that we delete it, you may no longer be able to access or use certain Services. The information we collect may include data you provide to us directly, data we obtain automatically from your interaction with the Services, and data we obtain from other sources.

Information You Provide to Us Directly. We may collect information directly from you. For example, you may provide us with information when you use the Services, communicate with us, register for an account, subscribe to a newsletter, or participate in a promotion. Information you provide to us directly may relate to you and others and may include, but is not limited to:

• Email;
• Username;
• Payment information (e.g., through our payment processing vendor);
• Your User Content (as defined in the Terms of Service), such as chat histories, posted images, and shared characters; and
• The contents of your communications with us.

You are not required to provide us with such information, but if you do not provide requested information, you may not be able to access or use certain features of the Services.

Information We Collect Automatically. We and our third-party vendors (including advertising networks and analytics companies, such as Google Analytics) may use cookies, web beacons, and other tracking technologies to collect information about the computer or device (including mobile devices) you use to access the Services. As described below, we may collect and analyze information including, but not limited to: (a) browser type; (b) internet service provider (ISP) or operating system; (c) domain name; (d) access times; (e) referring or exit pages; (f) page views; (g) IP address; (h) unique device identifiers (e.g., IDFA or Android ID); (i) the version of the Services you use; and (j) the type of device you use. We may also track when and how frequently you access or use the Services, including how you interact with or browse our website or mobile application. We may use this information (including information collected by our third-party vendors) for analytics (including to determine which parts of the Services are used most frequently and what our users like/dislike), to evaluate the success of any advertising campaigns, and for other purposes described elsewhere in this Policy.

We and third-party partners may use cookies, clear GIFs, pixel tags, and similar technologies to better understand user behavior, personalize user experience, conduct research and analysis, and improve the Services. These technologies help us tailor the Services to your preferences, track usage patterns, manage content, and compile aggregated usage statistics. For example, we may use cookies to remember your preferences and facilitate your login to encrypted areas of the Services. Please note that passwords will be processed and stored securely using industry-standard encryption or hashing methods. Additionally, we may use certain technologies in emails to help us measure engagement, such as tracking email open rates or identifying when an email is viewed or forwarded.

Most web browsers automatically accept cookies, but you can modify your browser settings to decline cookies if you prefer. If you disable cookies, you may not be able to fully utilize the Services, as they may not function properly. As we adopt more technologies, we may also collect more information in other ways. For more information, please visit https://www.allaboutcookies.org/.

When you use the Services, we may collect general location information (e.g., general location inferred from IP address).

Information We Collect From Other Sources. We may also collect information about you from other parties, such as when you are referred to us by another user. We may also receive information about you from third-party social platforms (e.g., Facebook or Instagram) when you interact with our social media accounts.

We may also collect information when you connect your account using a third-party account (e.g., a social media account). Depending on your permissions, the Services may collect information from your third-party account. When you connect with us via a third-party account like Facebook or Google, we receive information from that third party to identify your account. We collect and store this information and use it to help you connect to the Services. Connecting your account to a third-party account is entirely optional, and you can choose whether to grant permissions when attempting to connect. You can revoke permissions by logging into the third-party account and disconnecting MatelinkAi from that account, or through the native application on your smartphone. We may retain information previously collected from you.

2. How We Use the Information We Collect

We may use your information for any of the following purposes:

• To provide and manage the Services;
• To personalize the Services;
• To communicate with you, including to provide you with information we believe may be of interest to you regarding features or aspects of the Services, or to communicate with you regarding changes to our terms, conditions, or policies;
• For other communications with you, such as responding to your inquiries, comments, feedback, or questions;
• To analyze, maintain, improve, modify, customize, and measure the Services, including training our AI/machine learning models;
• To develop new programs and services;
• To detect and prevent fraud, criminal activity, or misuse of our Services, and to ensure the security of our IT systems, architecture, and networks;
• To comply with legal obligations and legal process, to protect the rights, privacy, safety, or property of us, our affiliates, you, or other parties, including enforcing our Terms of Service and any other agreements;
• For other purposes described at the time the information was collected.

We may combine information about you collected through the Services with information we obtain from other sources. We may also aggregate and/or anonymize information collected through the Services. We may use anonymized or aggregated data for any purpose, including but not limited to research and marketing purposes.

3. When We Disclose the Information We Collect

We may disclose your information in any of the following circumstances:

• Affiliates: We may disclose information to our affiliates, meaning entities that control, are controlled by, or are under common control with MatelinkAi. Our affiliates may use information we disclose to them in a manner consistent with this Policy.
• Vendors: We may disclose your information to employees, consultants, and other vendors who require access to such information to perform work on our behalf or provide services to us, such as vendors providing data storage, payment, technical support and services, customer service, analytics, fraud prevention, legal services, and marketing services.
• Safety and Protection of MatelinkAi and Others: We may disclose certain information if we believe in good faith that it is necessary or appropriate to (i) protect or defend MatelinkAi or other parties, including defending or enforcing this Policy, our Terms of Service, or any other contractual arrangement; and/or (ii) protect the rights, property, or personal safety of MatelinkAi, our agents and affiliates, our employees, users, and/or the public.
• Advertising and Analytics: We may disclose or provide certain information about you to advertising and analytics partners so they can serve advertisements on our behalf across the internet and provide analytics services. These partners may use cookies and tracking technologies to enable us to track and analyze data, determine the popularity of certain content, serve advertising and content targeted to your interests, and better understand your online activity. To learn more about managing your web browsing information for advertising purposes, please see the "Online Analytics and Personalized Advertising" section below.
• Legal Requirements. We may disclose certain information if we believe in good faith that it is necessary or appropriate to comply with any law enforcement, legal, or regulatory process, such as in response to a search warrant, subpoena, court order, or other applicable laws and regulations.
• Business Transfers. We may disclose certain information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• Your User Content. Certain actions you take may be visible to other users of the Services or may result in other users being able to access your content. For example, if you create User Content (such as creating a shared character), we may also publish it to the Services. If you use group chats to communicate, you authorize us to make your chat history visible to other participants in the group chat, which may include characters and other users in the Services.
• Other Disclosures with Your Consent or at Your Direction. We may disclose your information to non-affiliated third parties based on your consent. For example, when you refer us or our Services to a friend or acquaintance, you may direct us to disclose your information.

4. Online Analytics and Personalized Advertising

Analytics. We may use third-party web analytics services on the Services, such as Google Analytics. These vendors use technologies described in the "Information We Collect Automatically" section above to help us analyze how users use the Services, including by noting the third-party website from which you arrived. The information collected by such technologies will be disclosed to or collected directly by these vendors, who use the information to evaluate your use of the Services. We may also use Google Analytics for certain advertising-related purposes, as described below. To prevent Google Analytics from using your information for web analytics, you may install the Google Analytics Opt-out Browser Add-on.

Personalized Advertising. We may allow third-party advertising networks to place cookies or other tracking technologies on your computer, mobile phone, or other device to collect information about your use of the Services in order to (a) serve, optimize, and deliver marketing content based on your past visits to our website and other online services; and (b) report on the association between the display of our marketing content, your interaction with such marketing content, and your visits to our online services. We may also allow other non-affiliated parties (e.g., advertising networks and ad servers, such as Google Analytics) to serve personalized ads to you and to access their own cookies or other tracking technologies on your computer, mobile phone, or other device you use to access the Services. Third parties using these technologies may offer you a way to opt out of targeted advertising as described below. You may receive personalized ads on your computer via your web browser. Cookies may be associated with de-identified data linked to or derived from data you voluntarily submit to us (e.g., your email address), which we may disclose to vendors in a hashed, non-human readable form.

If you would like to learn more about targeted advertising and how to control the placement of cookies on your computer for such advertising, you may visit the Network Advertising Initiative's ("NAI") Consumer Opt-Out Link, the Digital Advertising Alliance's ("DAA") Consumer Opt-Out Link, and/or the European Interactive Digital Advertising Alliance to opt out of receiving targeted advertising from companies participating in these programs. To set how Google personalizes ads shown to you or customize Google Display Network ads, you can visit the Google Ads Settings page. Please note that if advertising technology is integrated into the Services, you may still receive advertising content even if you opt out of targeted advertising. In that case, the advertising content may not be tailored to your interests. Furthermore, we do not control any of the above opt-out links and are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms. Your opt-out selection may no longer be effective if your browser is configured to reject cookies when you visit these opt-out pages, if you subsequently erase your cookies, or if you use a different computer or change web browsers.

5. Your Choices

We provide you with certain choices regarding the collection, use, and disclosure of your information.

Profile Information. You may deactivate your account via your account profile page. You may also verify, correct, update, or delete certain information via your account profile page.

Marketing Communications. You may unsubscribe from marketing emails by following the instructions in those emails. Please note that even if you unsubscribe from marketing emails, we may still send you administrative messages related to the Services, such as notices of updates to our Terms of Service or this Policy.

Cookies and Analytics. You may opt out of certain processing related to cookies and analytics as described in this Policy.

Your Right to Access Information About You. Laws in your jurisdiction may grant you certain rights regarding your personal information. Depending on your jurisdiction, you may request that we:

• Provide you with information about the categories of personal information we have collected or disclosed about you; the categories of sources of such information; the business or commercial purpose for collecting such information; and the categories of non-affiliated parties to whom we disclose such personal information. This information is also provided in this Policy;
• Provide you with access to and/or a copy of certain information we hold about you;
• Restrict the use of your information for direct marketing purposes (including any direct marketing processing based on profiling);
• Update outdated or incorrect information;
• Delete certain information we hold about you;
• Restrict how we process and disclose certain information about you;
• Transfer your information to a third-party service provider;
• Where applicable, you may opt out of the use of your personal information for analytical decision-making that produces legal effects or similarly significant effects;
• Withdraw your consent to the processing of your information.

You may designate an authorized agent to make a request on your behalf. To verify the authorized agent's identity, you must provide them with a signed written authorization or power of attorney. As permitted by applicable law, we may also contact you to verify your identity before processing the authorized agent's request.

Please note that certain information may not be subject to such requests under applicable law. For example, we may retain certain information for compliance with laws and for the security of the Services. We may require certain information to provide the Services to you; if you request that we delete such information, you may no longer be able to use the Services.

You also have the right to not be discriminated against (as provided by applicable law) for exercising your rights.

You also have the right to opt out of the sale of your personal information or the use of your personal information for targeted advertising. To opt out of any future targeted advertising we may provide, please use the tools described in the "Personalized Advertising" section above.

If you wish to learn about your rights under applicable law or to exercise any of your rights, please contact us at contact@spicylovers.io. To protect your privacy and security, we will take reasonable steps to verify your identity and request before processing it. If we are unable to verify your identity, we may not be able to respond to your request.

Under applicable law, you may have the right to appeal our decision to deny your request (if applicable). We will provide information on how to exercise that right in our response denying the request.

Regional Privacy Disclosures and Rights. Additional disclosures for residents of the European Economic Area, the United Kingdom, California, and Nevada are provided in the "Regional Privacy Disclosures" section below.

6. Regional Privacy Disclosures

This Policy Applies to Residents of the European Economic Area and the United Kingdom. MatelinkAi is considered a "data controller" of the "personal data" (as defined in the General Data Protection Regulation) we process under this Policy. In other words, MatelinkAi is responsible for deciding how to collect, use, and disclose personal data in accordance with applicable law. Laws in the European Economic Area and the United Kingdom require data controllers to inform you of the legal basis for their use, sharing, or disclosure of your personal data. Where these laws apply, our legal bases are as follows:

• Contractual Obligations: We may use, share, or disclose your personal data to fulfill our contractual obligations to you. For example, we process your personal data to comply with our agreement with you and to fulfill commitments in any contracts we have with you.
• With Your Consent: Where required by law, and in some other instances, we use, share, or disclose personal data based on your consent.
• Legitimate Interests: In many cases, we use, share, or disclose personal data because it helps us achieve legitimate business interests without outweighing the interests or fundamental rights and freedoms of affected individuals, such as customer service, certain promotional activities, analyzing and improving our business, securing the Services, preventing fraud, and handling legal matters.
• Legal Compliance: We need to use and disclose personal data in certain ways to comply with our legal obligations.

In addition to the rights described herein, you have the right to lodge a complaint with the relevant supervisory authority. However, we encourage you to contact us first, and we will do our best to resolve your concerns.

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 about you to non-affiliated third parties. You can exercise this right by contacting us as described in the "Contact Us" section below with the subject line "Nevada Do Not Sell Request" and providing your name and email address. We do not currently sell your personal information, where "sale" is defined under Nevada Revised Statutes Chapter 603A.

California Residents. This Policy details the specific personal information and sensitive personal information we collect, the sources of such information, and how we disclose it. Under the California Consumer Privacy Act ("CCPA"), we must also provide you with the "categories" (as defined by the CCPA) of personal information and sensitive personal information we collect and disclose for business purposes.

We have collected and disclosed for business purposes the categories of personal information described in Section 1. These categories of personal information include: identifiers, financial information (e.g., payment information), commercial or transactional information, internet or other electronic network activity information, general geolocation data, audio or visual information (e.g., images and videos you submit), other information you may voluntarily provide to us (e.g., via User Content), other information that could identify you, and inferences drawn from the information we collect.

We also collect the following categories of "sensitive personal information" (as defined by the CCPA): (i) account log-in and password or other credentials allowing access to your account; and (ii) other sensitive personal information you may voluntarily provide to us as an individual user of the Services (e.g., if you voluntarily post User Content revealing your race, religion, or sexual orientation).

We process the above categories of personal information for the purposes detailed in Section 2 above.

We collect the above categories of personal information from: (1) you directly; (2) from your use of the Services; and (3) from other users and non-affiliated parties.

Our information disclosure practices are described in more detail in Section 3 above.

"Sale" and "Sharing" of Personal Information

The California Consumer Privacy Act ("CCPA") imposes certain obligations on businesses that "sell" or "share" personal information. When we refer to "sale" or "sharing" (or variations thereof) in quotes, we are referring to the unique definitions of those terms under the CCPA.

We may use third-party analytics services and online advertising services, which may result in the "sharing" of online identifiers (e.g., cookie data, IP address, device identifiers, general location information, and usage information) with advertising partners to promote our Services on other websites. If you or your authorized agent wish to opt out of our "sharing" of your information for such purposes, you can use the tools described in the "Personalized Advertising" section above, which are also available here.

We do not knowingly "sell" or "share" the personal information of children under 16 years of age.

Do Not Track Disclosure

We do not respond to browser-initiated "Do Not Track" signals, as the Internet industry is still working on Do Not Track standards, implementations, and solutions.

Retention of Your Personal Information

Please see the "Data Retention" section below.

CCPA Rights

California residents may make requests regarding their personal information as described in the "Your Right to Access Information About You" section above. The CCPA also allows you to limit the use or disclosure of your sensitive personal information if it is used for certain purposes. Please note that we do not use or disclose your sensitive personal information for purposes other than those for which you cannot opt out under the CCPA.

7. Children's Privacy

The Services are not designed for individuals under 13 years of age, and our Terms of Service prohibit use by individuals under 13 (or under 16 if you are a resident of the European Economic Area). If we discover that an individual under 13 has provided us with "personal information" as defined by the Children's Online Privacy Protection Act ("COPPA"), we will close the account and delete the personal information as required by COPPA. Where permitted by law, we may retain certain information internally for the purposes described in this Policy.

8. Security

MatelinkAi employs technical, administrative, and physical security measures designed to protect the information we collect from loss, misuse, unauthorized access, disclosure, alteration, or destruction. However, no internet or email transmission can be guaranteed to be absolutely secure or error-free. Therefore, we do not promise, and you should not expect, that your information or communications will always remain secure.

9. Data Retention

Generally, we retain your information for as long as necessary to fulfill the processing purposes. The length of time we retain information depends on the purposes for which we collect and use it and your choices, after which we may delete and/or aggregate the information. We may also retain and use the information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Popular Characters. If a character you create and set as "Public" achieves a certain level of popularity, we reserve the right to retain the character's attributes and keep it active in the Services even if you delete your data and account. We do this to avoid disrupting the experience of other users, as popular characters inherently involve active interaction with thousands of users.

10. Consent to Transfer

Our Services are global, and your information may be stored and processed in the United States and in other countries outside the United States. Data protection laws in these countries may differ from those in your country, and in some cases, law enforcement and national security authorities may have access to your data. By using the Services or providing any information to us, you consent to the collection, processing, maintenance, and transfer of such information to the United States and other applicable countries. Privacy laws in these countries may not be as comprehensive or protective as the laws in the country where you live and/or are a citizen.

11. Third-Party Website Links

The Services may contain links to third-party websites or services. We are not responsible for the content or practices of these websites or services. Any collection, use, and disclosure of your information by third parties will be governed by their respective privacy policies, not this Policy.

12. Changes to This Policy

We may modify this Policy to reflect changes in the law, how we process information, or features of the Services. The date of the most recent revision will be indicated in this Policy. If we make material changes to this Policy, we will provide appropriate notice to you as required by law. Your continued use of the Services constitutes your reading and understanding of the most recent version of this Policy.

13. Contact Us

If you have any questions about our privacy policy or how we process information, please contact us at contact@spicylovers.io.