Privacy Policy

Privacy Trabuzza

TraBuzza LLC Privacy Policy

Welcome to the TraBuzza LLC Privacy Policy (“Policy”)! This document explains how we collect, store, protect, and share your information, and with whom we share it. We recommend reading this in conjunction with our Terms and Conditions of Use.

While you’re enjoying the TraBuzza LLC mobile application (including the desktop version) (“App”), our websites and microsites (such as TraBuzza.com) or using our digital products and services (such as our competitions or surveys) (collectively referred to in this Privacy Policy as our “Sites”), we collect certain information about you. Additionally, you may choose to use the App or Sites to share information with other users, including your friends and contacts (“Users”). We may also need to share your information from time to time.

The App and Sites are global, and your information will be transmitted to and used in the United States and the UK regardless of your country of residence. This Policy outlines how we protect your personal data when transferring it overseas, so please read it carefully!

Who We Are

The App and Sites are operated by TraBuzza LLC (also referred to in this policy as “we” or “us”). TraBuzza LLC is the controller of personal information collected and processed through the TraBuzza App and Sites.

TraBuzza LLC has designated a Data Protection Officer who can be contacted via email at feedback@dpo.trabuzza.com or by post at the following address: 10601 Clarence Dr., Suite 250, Frisco, TX 75033, United States.

1. COLLECTION OF INFORMATION

Registration Information

When you download the App and create an account (“Account”), we may collect certain information (“Registration Information”) about you, such as:

- Name;

- Username;

- Email address;

- Mobile number;

- Gender identity;

- Date, time, and location of birth;

- Sexual preference;

- Photographs;

- Location; and

- Login information for social media accounts connected to your TraBuzza Account (e.g., Facebook and Instagram). For more information on this, see “Linking Other Accounts to TraBuzza” in section 7 below.

Once registered, you can review and update your information anytime by logging into TraBuzza (except for your date of birth and location, which are automatically updated based on your device’s location if you’ve granted TraBuzza access). It is your responsibility to keep your account details up to date. If your phone number changes, please update it in your account.

The information we collect helps enhance the App and verify our Users (robots are not welcome!). Registration Information such as your sexual preference, name, and username may be visible to other Users viewing your profile page.

For Users who are California residents, the data we may collect falls within the following categories of “personal information,” as defined by the California Consumer Privacy Act (CCPA):

- A. Identifiers, such as name and location;

- B. Personal information, as defined in California customer records law, such as contact (including email and telephone number) and financial information;

- C. Characteristics of protected classifications under California or federal law (if you choose to provide them), such as age, gender identity, marital status, sexual orientation, race, ancestry, national origin, religion, and medical conditions;

- D. Commercial information, such as transaction information and purchase history;

- E. Biometric information;

- F. Internet or network activity information, such as browsing history and interactions with our Sites and App;

- G. Geolocation data, such as mobile device location;

- H. Audio, electronic, visual and similar information, such as photos and videos;

- I. Professional or employment-related information, such as work history and prior employer;

- J. Non-public education information; and

- K. Inferences drawn from any of the personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.

Profile Information

We recommend and encourage you (and all our members) to carefully consider the information you disclose about yourself. We do not recommend including email addresses, URLs, instant messaging details, phone numbers, full names, addresses, credit card details, national identity numbers, driver’s license details, and other sensitive information on your profile, as they may be subject to misuse

When you post information about yourself or use the messaging function to communicate with other Users, the amount of personal information you share is at your own risk. Please see Section 4 below for more information on who can access what you post on TraBuzza.

Profile Verification Information (Including Biometric Information)

For safety and security and to ensure the best user experience, we require Users to verify their accounts. This might involve providing your phone number and, in some cases, performing photo verification. We want to ensure you are not a robot and to prevent the creation of fake TraBuzza accounts, which can be used for malicious activities and cybercrime—threatening the TraBuzza network and impacting everyone.

Verification may be required for fraud prevention. You can also verify your photo on a voluntary basis (to add the blue ‘verified’ badge to your profile).

If you choose to verify your profile photo, we will scan each submitted photo. This scan may use facial recognition technology to compare the submitted photo to your profile photo to ensure authenticity. Verification photos are not added to your profile. We retain the scans for verification purposes and record-keeping until we no longer need them or for three years after your last interaction with us, whichever is sooner. After the applicable retention period expires, we take commercially reasonable steps to permanently and securely delete the scans from our systems.

Purchases Information

If you decide to purchase any of our premium services, we will process your payment information and securely retain it for the prevention of fraud and for audit/tax purposes.

TraBuzza LLC uses automated decisions to prevent fraudulent payment transactions as part of its anti-fraud procedures. Our systems check payment transactions for behavior indicating breaches of our Terms and Conditions of Use. If a transaction meets specific criteria suggesting a likely breach of the Terms and Conditions of Use and appears to be fraudulent, the transaction may be automatically blocked. If a transaction is blocked, you will be notified that your transaction cannot be processed, and affected Users can contact TraBuzza LLC to contest the decision.

Please note that if your account is blocked for any reason, any account(s) you have on other TraBuzza LLC platforms/applications may also be blocked as part of our anti-spam and anti-fraud procedures.

Geolocation Information

If you have given TraBuzza LLC access to your location in your device settings, we will collect information about WiFi access points, as well as other location data such as longitude and latitude, and may save your device’s coordinates to offer certain features. This information helps us identify your physical location and personalize the App, making it easier for you to interact with other Users by displaying general locality information on your profile and showing you profiles of other Users who are near you.

If you wish to turn off location access, you can do so by the following methods:

- iPhone app — Settings, Privacy, Location Services, TraBuzza

- Android — Settings, Location, TraBuzza, Permissions, Location

Device and Photos Information

We may collect information about your device when you use the App, including the unique device identifier, device model, and operating system, for various purposes outlined in this policy. Additionally, if you allow us, the App may access your device’s address book solely to add someone to your contacts.

We also collect data about your photos, such as which photos users spend time on or which have the best lighting, etc. This data may be used to rearrange your profile photos to position them favorably. You may opt-out of this feature through our app settings.

Links

We may track your interactions with links available on TraBuzza LLC, including third-party services, by redirecting clicks or other means. We may share aggregate click statistics, such as how many times a particular link was clicked.

TraBuzza LLC Success Stories, Surveys, and Other Contributions

From time to time, we conduct surveys for research purposes and may contact you to see if you would like to participate. We may also reach out to ask if you would like to provide feedback, a testimonial, or participate in marketing campaigns (for example, if you indicate that you have found a match on the App, we may contact you to ask if you would be interested in featuring in advertising for TraBuzza LLC). Participation in surveys and marketing campaigns is optional, and more information will be provided at the point of contact. If you prefer not to be contacted for surveys or marketing campaigns, please contact our Customer Support Team via our Feedback Page.

When You Contact Customer Support

If you contact our Customer Support team via our Feedback Page, we will receive your email address, may track your IP address, and review the information you send to help resolve your query. We will keep records of our communications with you, including any complaints received from you about other Users (and from other Users about you) for 6 years after your account is deleted.

Cookies and Similar Technologies

When you visit our Sites or use our App, we may collect personal data automatically using cookies or similar technologies. A cookie is a small file placed on your device or browser that allows us to recognize and remember you.

To learn more about cookies, including how we use them and your available choices, please refer to our Cookie Policy.

2. USE OF YOUR INFORMATION

Our primary goal is to ensure your experience on TraBuzza LLC is enjoyable and safe. To deliver a satisfying experience, we may use your Registration and other information to:

- Offer you our services and features.

- Contact you with information about the App (e.g., updates and new features).

- Personalize the App/Sites and the content we deliver to you.

- Conduct research and analytics on how you use and interact with the App/Sites.

- Test new technologies and processes designed to enhance and improve the App/Sites.

- Resolve disputes, troubleshoot problems, and enforce our Terms & Conditions.

- Investigate fraud, protect our legal rights, and enforce our Terms & Conditions.

- Send you information about promotions and offers we have available (e.g., specifying the types of goods/services/offers provided via direct marketing) if you’ve opted into our communications or otherwise consented. We will not use your information for email direct marketing unless you provide consent during the Account creation process or via Settings in the App (you can withdraw from marketing at any time via Settings in the App or by using the opt-out mechanisms and links provided in each message).

- Protect our Users and third parties from harm.

The legal basis for processing profile and proximity information is that it is necessary for the provision of our contractual services to you under Article 6(1)(b) GDPR. Processing information about your app activity is based on our legitimate interests under Article 6(1)(f) GDPR, specifically our interest in generating personalized and relevant recommendations. If you include sensitive information in your profile, such as beliefs, the processing of this data is based on your voluntary and explicit consent.

Moderation Practices

We use a combination of automated systems and human moderators to monitor and review accounts (including photos and other information uploaded to profiles) and messages for content that may breach our Terms and Conditions of Use. If an account or message meets criteria indicating a breach, the relevant account may receive a warning and the user’s access may be restricted or blocked. Affected Users can contact TraBuzza LLC to contest the decision.

If you post content that violates our Terms and Conditions of Use, we reserve the right to terminate or restrict access to your Account.

Lawful Basis

Under EU and UK data protection laws, we are required to inform you of our lawful basis for using your data, as outlined in the table below. Where the legal basis is consent, you can withdraw consent at any time. Where the basis is legitimate interests, you have the right to object to our use of your data. We explain in the relevant sections of this Policy how you can withdraw consent or opt-out of certain data uses.

| Purpose for which data is used | Data | Source | Legal Basis |

| --------------------------------- | -------- | ---------- | --------------- |

| To provide you with the TraBuzza LLC social networking service | Name, email address, date of birth, location (CCPA Categories A and B) | You provide this information. Location data is obtained from your device. | Contractual necessity |

| To facilitate networking opportunities on the TraBuzza LLC App | Optional information you provide in your profile, including through profile verification or adding TraBuzza LLC badges (CCPA Categories B, C, H, I, J) | You provide this information. | Contractual necessity and our legitimate interests; explicit consent for sensitive data. |

| To verify your identity, prevent fraud, and ensure safety | Phone number, photo for profile verification, photo of Government ID (if age verification required), geolocation and device information (CCPA Categories A, B, C, E, F, G, H) | You provide this information, except for geolocation and device info, which is obtained from your device. | Legitimate interests – safeguarding Users and preventing fraud |

| To take payment for premium services (not applicable for payments via Apple App Store) | Payment card details (CCPA Categories B and D) | You provide this information. | Contractual necessity |

| To send marketing information about our events, offers, and services | Name, email address, postal address, Instagram handle, mobile phone number (CCPA Categories A and B) | You provide this information. | Consent or legitimate interests; in accordance with marketing laws. |

| To carry out research and analysis to improve the App and test new technologies | Log and usage data, including IP address, browser type, referring domain, pages accessed, mobile carrier, search terms, images, videos, registration, and profile information (CCPA Categories A, F, H) | You provide photos and videos. Log and usage information is obtained from your device. | Legitimate interests – improving services and testing new technologies |

| To respond to correspondence and queries, including social media queries | Email address, IP address, social media name, phone number (CCPA Categories B and F) | You provide this information. IP address is obtained from your device. | Legitimate interests – providing good service and troubleshooting |

| To investigate and block Users for reported infringements of our Terms and Conditions | Name, user registration details, profile information, message content, photographs, usage and device data (CCPA Categories A, B, C, F, H) | You provide registration details, profile information, messages, and photographs. Other data is obtained from your device. | Legitimate interests – maintaining service integrity and safety |

| To improve your experience on the App | Data about profile photos, such as interaction metrics | Obtained from user interaction with the App and profile photos. | Legitimate interests – enhancing user experience |

| To enable Users to create and enhance their TraBuzza LLC profile and log in via third-party accounts | Data from Facebook and other third-party accounts (CCPA Categories A, B, C, H) | Obtained from Facebook or other third-party account providers. | Legitimate interests – facilitating access to services |

| To block payment transactions as part of anti-fraud procedures | Name, IP address, email address, mobile number, cardholder name, payment details, user ID, country (CCPA Categories A, B, D) | You provide name, email address, mobile number, and card details. IP address and payment information are obtained from your interactions with our service. | Legitimate interests – preventing fraudulent transactions and maintaining security |

| To serve promo cards and advertisements on the App | Location, gender, age, profile information (CCPA Categories A, C, G) | Obtained from your profile and device. | Legitimate interests – targeting relevant advertisements and generating advertising revenue |

| To serve advertisements on third-party networks and measure effectiveness | Data about your visit, IP address (and estimated location), age, gender, device ID (CCPA Categories B, C, G, F, K) | Obtained from your device or browser. | Consent – as indicated in Privacy Settings/Cookies Settings preferences |

| To contact you for surveys and feedback, and marketing campaigns | Email address, mobile phone number (CCPA Category B) | You provide this information. | Legitimate interests – conducting research and improving the service |

| To enable video and audio call functions, and sending images and videos | Video and audio call usage data, images, videos (CCPA Categories F and H) | Obtained from your device. | Legitimate interests – providing these functionalities |

| To defend legal claims, protect legal rights, and prevent harm | Relevant information depending on the issue | Information may be obtained from you, your device, or third parties. | Legitimate interests – protecting legal rights and preventing harm |

Purpose for which data is used

Data

Source

Legal basis

To provide you with the TraBuzza social networking service

Name, email address, date of birth, location (CCPA Categories A and B)

You provide your name, email address and date of birth to us. We obtain location data from the device that you use to access the service

Contractual necessity

To facilitate networking opportunities on the TraBuzza App

Optional information that you choose to provide in your profile, including through profile verification, or adding TraBuzza badges, which may include information about your sexual preferences, non-binary gender, religion, ethnic background, photos, interests, etc. (CCPA Categories B, C, H, I, J)

You provide this information to us

Contractual necessity and our legitimate interests – it is in our legitimate interests to facilitate networking opportunities in the TraBuzza app. For special category/sensitive personal data, we rely on your explicit consent.

To verify your identity and prevent fraud and to ensure the safety and security of Users

Phone number and if requested or permitted, photo provided as part of profile verification and for users based in countries where age verification is required by law: photo of Government ID + geolocation and device information (CCPA Categories A, B, C, E, F, G and H)

You provide this information to us, except for the geolocation and device information, which we obtain from the device that you use to access the service

Legitimate interests – it is in our legitimate interests to ensure that accounts are not set up fraudulently and to safeguard Users of the site

To take payment for premium services (not applicable for Users making payments via the Apple App Store)

Payment card details (CCPA Categories B and D)

You provide this information to us

Contractual necessity

To send you marketing information about our events, offers and services

Name, email address, postal address, Instagram handle and mobile phone number (CCPA Categories A and B)

You provide this information to us

Consent or legitimate interests and in accordance with the laws applying to our marketing activities. We have a legitimate interest in promoting our business and products

To carry out research and analysis to help us improve the App and to test new technologies and processes designed to enhance and improve the App/Sites

Log and usage data, including IP address, browser type, referring domain, pages accessed, mobile carrier and search terms, images and video, registration information, profile information (CCPA Categories A, F and H)

You provide photos and videos to us. We obtain the log and usage information from the device that you use to access the service

Legitimate interests – it is in our legitimate interests to analyse the way in which Users are accessing and using our services and to test new technologies so that we can further develop the App, implement security measures and improve the service

To respond to correspondence and queries that you submit to us, including social media queries

Email address and IP address, social media name, phone number (CCPA Categories B and F)

You provide your email address, social media name and phone number to us when you contact us and we obtain your IP address from the device that you use to contact us

Legitimate interests – it is in our legitimate interests to respond to your queries to ensure that we provide a good service to Users and troubleshoot problems

To investigate and block Users for reported infringements of our Terms and Conditions of Use

Name and user registration details, profile information, content of messages and photographs + usage and device data such as IP address and IP session information (CCPA Categories A, B, C, F, and H)

You provide your registration details, profile information, messages and photographs to us. We obtain the other information from the device that you use to access the service.

Legitimate interests - it is in our legitimate interests to prevent unauthorised behaviour and to maintain the safety and integrity of our services

To improve your experience on the App

Data about profile photos such as whether the first profile photo is scrolled on or not and whether the vote is a yes or a no

We obtain this information from the way users interact with the App and the profile photos of other users

Legitimate interest - it is in our legitimate interest to improve our users’ experience

To enable Users to create and enhance their TraBuzza profile and log into the App via third party accounts

Data from Facebook and other third-party accounts (see section 7 of this Privacy Policy for more details) (CCPA Categories A, B, C, and H)

We obtain this information from Facebook, or the providers of any other accounts you use to log in or connect with your TraBuzza account

Legitimate interests – it is in our legitimate interests to facilitate access to our services

Processing We Perform To Improve Services For Students

What We’re Doing:

We process personal data to identify users who may be in college or university. To achieve this, we analyze historic location data to determine if your device’s coordinates align with general university or college areas. This involves reviewing recent historic data related to when you accessed the TraBuzza app and maintaining a simple “at campus yes/no” result based on our analysis.

What We Don’t Do:

We do not track your real-time movements for this activity, nor do we identify or store information about your specific study location. To protect your privacy, we do not retain any location data used for this activity, and it is permanently deleted once the results are generated.

Why We’re Doing This:

We use the results of this processing, combined with other relevant information, for the following purposes:

- To send tailored offers, events, and features to the right users.

- To understand which TraBuzza events are popular among students and which are less effective.

- To improve the design of the App to better meet the needs of students.

The legal basis for this processing is our legitimate interests. We have a legitimate interest in providing a more tailored app experience for student users and optimizing their chances of finding suitable connections. This data processing specifically applies to TraBuzza App users who indicated the United States or Canada as their location during registration (excluding users in Quebec) and who are aged 18 to 24.

3. DISCLOSURE OF INFORMATION

Our policy is to not disclose your Registration Information or personal data, except in the limited circumstances described here:

Circumstances Where Data May Be Disclosed

1. Service Providers

- Disclosed Data: All data, including all CCPA Categories listed above.

- Purpose: We engage trusted third parties to perform functions and provide services to us. We may share your Registration Information or personal data with these third parties solely for performing these functions and providing such services.

2. Moderators

- Disclosed Data: Name and user registration details, profile information, content of messages, and photographs (CCPA Categories A, B, C, H).

- Purpose: To monitor activity on the App and approve content.

3. Payment Processing and Telecommunications Companies

- Disclosed Data: Cardholder name, cardholder address, card number, payment amount, transaction date/time (CCPA Categories A, B, D).

- Purpose: To facilitate payments for our premium services.

4. Law and Harm

- Disclosed Data: Any personal data that TraBuzza holds about you, including all CCPA Categories listed above.

- Purpose: We cooperate with law enforcement and other third parties as necessary to enforce rights or comply with legal obligations. This includes:

- Compliance with court orders or lawful requests.

- Protection of individual safety.

- Addressing fraud, security, or technical issues.

- Protecting our rights, property, or those of third parties.

5. Business Transfers

- Disclosed Data: All personal data that TraBuzza holds about you, including all CCPA Categories listed above.

- Purpose: In the event of a business transition, such as a merger, acquisition, reorganization, or sale of assets, or in case of insolvency, we may be required to disclose your personal data.

6. Marketing Services Providers

- Disclosed Data: Advertising identifier associated with your device (Device ID), estimated location (based on IP address), age, gender, data about your visit to our Sites or App, and hashed email address (for ‘custom audiences’ only) (CCPA Categories B, C, G, F, K).

- Purpose: To help us serve marketing and advertising on third-party websites and applications, and to measure the effectiveness of our advertising campaigns.

7. Anti-Spam and Anti-Fraud

- Disclosed Data: Email address, phone number, IP address, IP session information, social network ID, username, user agent string, and transaction and payment data (CCPA Categories B, F, D).

- Purpose: To block accounts and suspected fraudulent transactions as part of anti-spam and anti-fraud procedures.

8. Aggregated Information

- Disclosed Data: Aggregated information that includes personal data but does not identify you directly, along with log data for industry analysis and demographic profiling.

- Purpose: For industry analysis and demographic profiling.

More Information About Disclosures

Service Providers

We use various trusted third parties to perform functions and provide services, such as:

- Billing Services: To facilitate purchases of paid features (e.g., Google Play).

- Authentication Services: To authenticate accounts (e.g., Twilio).

- Social Media Providers: To connect your TraBuzza account with social media accounts (e.g., Facebook, Instagram, Spotify).

- Product Improvement and Market Research: For customer surveys and market research (e.g., Typeform, Kantar).

- IT Services: For community management and support inquiries (e.g., Khoros).

We ensure due diligence on all Service Providers to guarantee they have adequate data protection measures. We only provide them with the personal data necessary for their services and enforce strict data retention limits.

7. LINKING OTHER ACCOUNTS TO TRABUZZA

Using Your Social Media Details to Sign In to TraBuzza

- Facebook: When you sign in to our App using your Facebook account, you authorize Facebook to share your name and profile picture with us. Unless you opt out, Facebook will also share your email address (if associated with your Facebook account), date of birth, profile photos, gender, Page likes, and current city/town.

- Apple ID: If you register or sign in with your Apple ID, you give Apple permission to share your Apple login, a name (which you can edit), and an email address. You may choose to hide your email, and Apple will create a random email address to keep your personal email private. This email address will be used to manage your TraBuzza account.

We will use this personal data to create your TraBuzza account. If you remove TraBuzza from your Facebook settings or Apple ID, we will lose access to this data, but we will retain the personal data collected during the initial setup of your account. To fully remove this data, you must delete your TraBuzza account.

Linking Social Media Accounts to Your TraBuzza Account

- Instagram, Facebook, or Spotify: You may link your TraBuzza account with Instagram, Facebook, or Spotify. This allows you to share information (such as Instagram photos or your top Spotify artists) directly to your TraBuzza account.

We only receive the information that Instagram, Facebook, or Spotify allow to be transferred, as detailed by these platforms and agreed upon when you connect your accounts.

To unlink your TraBuzza account from Instagram, Facebook, or Spotify, visit the settings in your Instagram, Facebook, or Spotify account and follow the instructions to revoke access permissions. Note that information already added to your TraBuzza account from these platforms will remain unless deleted within your TraBuzza account.

8. INFORMATION FOR BFF MEMBERS

Profile Sharing on TraBuzza For Friends

- Profile Visibility: If you are a member, your profile will be visible on both mode in TraBuzza and on our separate app. Profile sharing applies only in jurisdictions where TraBuzza is available.

9. YOUR CALIFORNIA PRIVACY RIGHTS*

For California residents, you have the following rights under the California Consumer Privacy Act:

- Disclosure Request: You can request information on how we have collected, used, and shared your personal information over the past 12 months.

- Deletion Request: You can request the deletion of your personal information collected from you, with certain exceptions.

- Shine the Light Law: California’s Civil Code section 1798.83 requires businesses to respond to requests from California customers about practices related to disclosing personal information to third parties for direct marketing. To inquire about these practices, contact us at feedback@trabuzza.com.

- Joint Promotions: In some promotions, we may disclose your contact information to third parties for marketing purposes if you participate. We will inform you of this before you enter the promotion. Follow the third parties’ instructions to unsubscribe from their messages.

- Do Not Track: We do not track your personal information over time and across third-party online services. We also do not permit third parties to collect personal information about your online activities over time and across different online services through our App.

10. YOUR RIGHTS

Depending on the privacy laws applicable in your country, you may have the following rights:

- Right to be Informed: Information about what personal data we process and why (provided in this Privacy Policy).

- Right of Access: Request a copy of your data.

- Right of Rectification: Correct inaccurate data.

- Right to Erasure: Request deletion of your data in certain circumstances.

- Right to Restrict Processing: Request to stop processing but retain data.

- Right to Data Portability: Request data in a machine-readable format to transfer to another provider.

- Right to Object: Object to processing based on legitimate interests or for marketing.

- Rights Related to Automated Decision-Making: Ensure human intervention in decisions made solely on automated processing.

Exercising Your Rights

To exercise any of these rights, please visit our Feedback Page or email our Data Protection Officer at feedback@dpo.trabuzza.com. You can also contact us by post at:

TraBuzza LLC

10601 Clarence Dr. Suite 250

Frisco, TX 75033

For security reasons, we may request specific information to confirm your identity before processing your request.

If you have concerns about how we’ve handled your request or your personal data, contact us via the details provided. If unresolved, you can file a complaint with the Information Commissioner’s Office (ICO) in the UK, or with your local data protection regulator if you reside in the EU, EEA, or another jurisdiction.

EU Representative

Under Article 27 of the GDPR, TraBuzza LLC has appointed Helix Ltd as its GDPR representative in the EU. If you reside in an EU Member State, you can contact Helix Ltd regarding GDPR matters by:

- Online Request Form: Nathan Trust: Ireland's Trusted Partner for Corporate Services, Accounting and Tax.

- Postal Address: 23 St Johns, Cork, Ireland

11. DATA LOCATIONS

At TraBuzza, we aim to provide you with access to our services no matter where you are in the world. To achieve this, we operate a global network of servers, including in the US, UK, EU, and, for users located in Russia, within Russia. While our hardware is located in third-party data centers, it is owned by TraBuzza LLC. Data collected by our Advertising Partners and other Service Providers may also be stored outside the UK and the European Economic Area. We ensure that such data is protected through valid legal mechanisms, including EU-approved model clauses and robust contractual standards. For more information about the safeguards we have in place, please email feedback@dpo.trabuzza.com.

12. DATA RETENTION AND DELETION

We retain your personal information only as long as necessary for the legal bases outlined in Section 2 above and as permitted by applicable law. Please refer to “Profile Verification Information (Including Biometric Information)” in Section 1 for details on our retention policy regarding biometric information.

When you delete your Account, it is no longer viewable in the App. However, it can be restored within 28 days if deleted accidentally. After 28 days, we start the process of deleting your personal information from our systems, unless:

- We need to retain it to comply with applicable law (e.g., personal data related to purchases made within the App may be kept for tax and accounting purposes);

- We must retain it to demonstrate our compliance with applicable law (e.g., information related to account blocks may be kept for evidential purposes in case of queries or legal claims);

- There is an outstanding issue, claim, or dispute that requires us to keep the information until it is resolved; or

- The information needs to be kept for legitimate business interests, such as fraud prevention and user safety and security (e.g., to prevent a banned user from opening a new account).

Warning: Even after you remove information from your profile or delete your Account, copies of that information may still be viewable and/or accessible if it has been shared with others, copied, or stored by others. We cannot control this, nor do we accept liability for it. If you have granted third-party applications or websites access to your personal information, they may retain it according to their own terms of service or privacy policies.

13. CHANGES TO THIS POLICY

As TraBuzza evolves, we may update this Privacy Policy from time to time. The most current version will govern our use of your information and will always be available at trabuzza.com/privacy. If we make any material changes to this policy, we will notify you, for example, via an email to the address associated with your Account or by posting a notice within the TraBuzza App.

Effective Date

This Privacy Policy was last updated on: 21 September 2024