Privacy Policy
Last Updated on March, 2022
This Policy describes our privacy practices in
plain language, keeping legal and technical jargon to a minimum. Thank you for taking the time to read it.
This Privacy Policy applies beginning 1/14/2022.
EFFECTIVE DATE: 1/14/2022
1. WHO WE ARE
2. WHERE THIS PRIVACY POLICY APPLIES
3. INFORMATION WE COLLECT
4. COOKIES AND OTHER SIMILAR DATA COLLECTION TECHNOLOGIES
5. HOW WE USE INFORMATION
6. HOW WE SHARE INFORMATION
7. CROSS-BORDER DATA TRANSFERS
8. YOUR RIGHTS
9. RESIDENTS OF CALIFORNIA
10.HOW WE PROTECT YOUR INFORMATION
11. HOW LONG WE RETAIN YOUR INFORMATION
12.CHILDREN’S PRIVACY
13.PRIVACY POLICY CHANGES
14.HOW TO CONTACT US
FOR CALIFORNIA CONSUMERS
Please see our California Privacy Statement to learn about California privacy rights.
1. WHO WE ARE
The company that is responsible for your information under this Privacy Policy (the “data
controller”) is:
Right Stuff App, Inc
3230 E Imperial Hwy, Suite 300
Brea, CA 92821
2. WHERE THIS PRIVACY POLICY APPLIES
This Privacy Policy applies to websites, apps, events and other services operated by The Right
Stuff. For simplicity, we refer to all of these as our “services” in this Privacy Policy. To make it
extra clear, we’ve added links to this Privacy Policy on all applicable services.
Some services may require their own unique privacy policy. If a particular service has its own
privacy policy, then that policy -- not this Privacy Policy -- applies.
3. INFORMATION WE COLLECT
It goes without saying, we can’t help you develop meaningful connections without some
information about you, such as basic profile details and the types of people you’d like to meet. We
also collect information generated as you use our services, for example access logs, as well as
information from third parties, like when you access our services through a social media account.
If you want additional info, we go into more detail below.
Information you give us
You choose to give us certain information when using our services. This includes:
o When you create an account, you provide us with at least your login credentials, as well as
some basic details necessary for the service to work, such as your sex and date of birth.
o When you complete your profile, you can share with us additional information, such as details
on your personality, lifestyle, interests and other details about you, as well as content such as
photos and videos. To add certain content, like pictures or videos, you may allow us to access
your camera or photo album. Some of the information you choose to provide us may be
considered “special” or “sensitive” in certain jurisdictions, for example your racial or ethnic origins,
sexual orientation and religious beliefs. By choosing to provide this information, you consent to
our processing of that information.
o When you participate in surveys, focus groups or market studies, you give us your insights into
our products and services, responses to our questions and testimonials.
o When you choose to participate in our promotions, events or contests, we collect the
information that you use to register or enter.
o If you contact our customer care team, we collect the information you give us during the
interaction. Sometimes, we monitor or record these interactions for training purposes and to
ensure a high quality of service.
o If you ask us to communicate with or otherwise process information of other people (for
example, if you ask us to send an email on your behalf to one of your friends), we collect the
information about others that you give us in order to complete your request.
o Of course, we also process your chats with other users as well as the content you publish, as
part of the operation of the services.
Information we receive from others
In addition to the information you provide us directly, we receive information about you from
others, including:
o Other Users
Other users may provide information about you as they use our services. For instance, we may
collect information about you from other users if they contact us about you.
o Other Partners
We may receive info about you from our partners, for instance where The Right Stuff ads are
published on a partner’s websites and platforms (in which case they may pass along details on a
campaign’s success).
Information collected when you use our services
When you use our services, we collect information about which features you’ve used, how you’ve
used them and the devices you use to access our services. See below for more details:
o Usage Information
We collect information about your activity on our services, for instance how you use them (e.g.,
date and time you logged in, features you’ve been using, searches or search parameters, clicks
and pages which have been shown to you, referring webpage address, advertising that you click
on) and how you interact with other users (e.g., users you connect and interact with, time and
date of your exchanges, number of messages you send and receive).
o Device information
We collect information from and about the device(s) you use to access our services, including:
o hardware and software information such as IP address, device ID and type, device-specific and
apps settings and characteristics, app crashes, advertising IDs (such as Google’s AAID and
Apple's IDFA, both of which are randomly generated numbers that you can reset by going into
your device’ settings), browser type, version and language, operating system, time zones,
identifiers associated with cookies or other technologies that may uniquely identify your device or
browser (e.g., IMEI/UDID and MAC address); and
o information on your wireless and mobile network connection, like your service provider and
signal strength.
o Other information with your consent
If you give us permission, we will be able to collect your precise geolocation (latitude and
longitude) in order to offer you features that make use of it. Such geolocation is collected through
various means, depending on the service and device you’re using, including GPS, Bluetooth or
Wi-Fi connections. If you decline permission for us to collect your geolocation, we will not collect
it.
Similarly, if you consent, we may collect your photos and videos (for instance, if you want to
publish a photo, video or streaming on the services).
4. COOKIES AND OTHER SIMILAR DATA
COLLECTION TECHNOLOGIES
We use and may allow others to use cookies and similar technologies (e.g., web beacons, pixels)
to recognize you and/or your device(s). You may read our Cookie Policy for more information on
why we use them (such as authenticating you, remembering your preferences and settings,
analyzing site traffic and trends, delivering and measuring the effectiveness of advertising
campaigns, allowing you to use social features) and how you can better control their use, through
your browser settings and other tools.
Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) have a “Do Not
Track” (“DNT”) feature that tells a website that a user does not want to have his or her online
activity tracked. If a website that responds to a DNT signal receives a DNT signal, the browser
can block that website from collecting certain information about the browser’s user. Not all
browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many
businesses, including The Right Stuff, do not currently respond to DNT signals.
5. HOW WE USE INFORMATION
The main reason we use your information is to deliver and improve our services. Additionally, we
use your info to help keep you safe and to provide you with advertising that may be of interest to
you. Read on for a more detailed explanation of the various reasons we use your information,
together with practical examples.
To administer your account and provide our services to you
o Create and manage your account
o Provide you with customer support and respond to your requests
o Communicate with you about our services
To help you connect with other users
o Analyze your profile and usage behavior and that of other users to recommend meaningful
connections. For more information on our profiling and automated decision-making, please see
our FAQ
o Show users’ profiles to one another
To ensure a consistent experience across your devices
o Link the various devices you use so that you can enjoy a consistent experience of our services
on all of them. We do this by linking devices and browser data, such as when you log into your
account on different devices or by using partial or full IP address, browser version and similar
data about your devices to help identify and link them
To serve you relevant offers and ads
o Administer sweepstakes, contests, discounts or other offers
o Develop, display and track content and advertising tailored to your interests on our services and
other sites
o Communicate with you by email, phone, social media or mobile device about products or
services that we think may interest you
To improve our services and develop new ones
o Administer focus groups and surveys
o Conduct research and analysis of users’ behavior to improve our services and content (for
instance, we may decide to change the look and feel or even substantially modify a given feature
based on users’ behavior)
o Develop new features and services (for example, we may decide to build a new interests-based
feature further to requests received from users)
To prevent, detect and fight fraud or other illegal or unauthorized activities
o Address ongoing or alleged misbehavior on and off-platform
o Perform data analysis to better understand and design countermeasures against these activities
o Retain data related to fraudulent activities to prevent against recurrences
To ensure legal compliance
o Comply with legal requirements
o Assist law enforcement
o Enforce or exercise our rights, for example our Terms
To process your information as described above, we rely on the following legal bases:
o Provide our service to you: Most of the time, the reason we process your information is to
perform the contract that you have with us. For instance, as you go about using our service to
build meaningful connections, we use your information to maintain your account and your profile,
to make it viewable to other users and recommend other users to you.
o Legitimate interests: We may use your information where we have legitimate interests to do so.
For instance, we analyze users’ behavior on our services to continuously improve our offerings,
we suggest offers we think might interest you, and we process information for administrative,
fraud detection and other legal purposes.
o Consent: From time to time, we may ask for your consent to use your information for certain
specific reasons. You may withdraw your consent at any time by contacting us at the address
provided at the end of this Privacy Policy.
6. HOW WE SHARE INFORMATION
Since our goal is to help you make meaningful connections, the main sharing of users’
information is, of course, with other people, as per your privacy settings. We also share some
users’ information with service providers and partners who assist us in operating the services,
with other companies and, in some cases, legal authorities. Read on for more
details about how your information is shared with others.
o With other people
We share your information with other people as per your privacy settings (and in the case of any
sharing features available on The Right Stuff, the individuals or apps with whom you may choose
to share your information with) when you voluntarily disclose information on the service (including
your public profile). Please be careful with your information and make sure that the content you
share is stuff that you’re comfortable being publicly viewable since neither you nor we can control
what others do with your information once you share it.
If you choose to limit the audience for all or part of your profile or for certain content or information
about you, then it will be visible according to your settings.
o With our service providers and partners
We use third parties to help us operate and improve our services. These third parties assist us
with various tasks, including data hosting and maintenance, analytics, customer care, marketing,
advertising, payment processing and security operations.
We may also share information with partners who distribute and assist us in advertising our
services. For instance, we may share limited information on you in hashed, non-human readable
form to advertising partners.
We follow a strict vetting process prior to engaging any service provider or working with any
partner. All of our service providers and partners must agree to strict confidentiality obligations.
o For corporate transactions
We may transfer your information if we are involved, whether in whole or in part, in a merger,
sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change
of ownership or control.
o When required by law
We may disclose your information if reasonably necessary: (i) to comply with a legal process,
such as a court order, subpoena or search warrant, government / law enforcement investigation
or other legal requirements; (ii) to assist in the prevention or detection of crime (subject in each
case to applicable law); or (iii) to protect the safety of any person.
o To enforce legal rights
We may also share information: (i) if disclosure would mitigate our liability in an actual or
threatened lawsuit; (ii) as necessary to protect our legal rights and legal rights of our users,
business partners or other interested parties; (iii) to enforce our agreements with you; and (iv) to
investigate, prevent, or take other action regarding illegal activity, suspected fraud or other
wrongdoing.
o With your consent or at your request
We may ask for your consent to share your information with third parties. In any such case, we
will make it clear why we want to share the information.
We may use and share non-personal information (meaning information that, by itself, does not
identify who you are such as device information, general demographics, general behavioral data,
geolocation in de-identified form), as well as personal information in hashed, non-human readable
form, under any of the above circumstances. We may also share this information with other companies,
acting as our service providers, and other third parties (notably advertisers) to
develop and deliver targeted advertising on our services and on websites or applications of third
parties, and to analyze and report on advertising you see. We may combine this information with
additional non-personal information or personal information in hashed, non-human readable form
collected from other sources. More information on our use of cookies and similar technologies
can be found in our Cookie Policy.
7. CROSS-BORDER DATA TRANSFERS
Sharing of information laid out in Section 6 sometimes involves cross-border data transfers, for
instance to the United States of America and other jurisdictions. As an example, where the
service allows for users to be located in the European Economic Area (“EEA”), their personal
information is transferred to countries outside of the EEA. We use standard contract clauses
approved by the European Commission or other suitable safeguard to permit data transfers from
the EEA to other countries. Standard contractual clauses are commitments between companies
transferring personal data, binding them to protect the privacy and security of your data.
8. YOUR RIGHTS
We want you to be in control of your information, so we have provided you with the following
tools:
o Access / Update tools in the service. Tools and account settings that help you to access, rectify
or delete information that you provided to us and that’s associated with your account directly
within the service. If you have any questions on those tools and settings, please contact our
customer care team for help here.
o Device permissions. Mobile platforms have permission systems for specific types of device data
and notifications, such as phone book and location services as well as push notifications. You can
change your settings on your device to either consent or oppose the collection of the
corresponding information or the display of the corresponding notifications. Of course, if you do
that, certain services may lose full functionality.
o Deletion. You can delete your account by using the corresponding functionality directly on the
service.
We want you to be aware of your privacy rights. Here are a few key points to remember:
o Reviewing your information. Applicable privacy laws may give you the right to review the
personal information we keep about you (depending on the jurisdiction, this may be called right of
access, right of portability or variations of those terms). You can request a copy of your personal
information by submitting a request at the address below.
o Updating your information. If you believe that the information we hold about you is inaccurate or
that we are no longer entitled to use it and want to request its rectification, deletion or object to its
processing, please contact us at the address below.
For your protection and the protection of all of our users, we may ask you to provide proof of
identity before we can answer the above requests.
Keep in mind, we may reject requests for certain reasons, including if the request is unlawful or if
it may infringe on trade secrets or intellectual property or the privacy of another user. If you wish
to receive information relating to another user, such as a copy of any messages you received
from him or her through our service, the other user will have to contact our Privacy Officer to
provide that party's written consent before the information is released.
Also, we may not be able to accommodate certain requests to object to the processing of
personal information, notably where such requests would not allow us to provide our service to
you anymore. For instance, we cannot provide our service if we do not have your date of birth.
o Uninstall. You can stop all information collection by an app by uninstalling it using the standard
uninstall process for your device. If you uninstall the app from your mobile device, the unique
identifier associated with your device will continue to be stored. If you re-install the application on
the same mobile device, we will be able to re-associate this identifier to your previous
transactions and activities.
o Accountability. In certain countries, including in the European Union, you have a right to lodge a
complaint with the appropriate data protection authority if you have concerns about how we
process your personal information. The data protection authority you can lodge a complaint with
may be that of your habitual residence, where you work or where we are established.
9. RESIDENTS OF CALIFORNIA
If you are a California resident, you can request a notice disclosing the categories of personal
information about you that we have shared with third parties for their direct marketing purposes
during the preceding calendar year. To request this notice, please submit your request at the address below.
Please allow 30 days for a response. For your protection and the protection of all of our users, we
may ask you to provide proof of identity before we can answer such a request.
10. HOW WE PROTECT YOUR INFORMATION
We work hard to protect you from unauthorized access to or alteration, disclosure or destruction
of your personal information. As with all technology companies, although we take steps to secure
your information, we do not promise, and you should not expect, that your personal information
will always remain secure.
We regularly monitor our systems for possible vulnerabilities and attacks and regularly review our
information collection, storage and processing practices to update our physical, technical and
organizational security measures.
We may suspend your use of all or part of the services without notice if we suspect or detect any
breach of security. If you believe that your account or information is no longer secure, please
notify us immediately here.
11. HOW LONG WE RETAIN YOUR INFORMATION
We keep your personal information only as long as we need it for legitimate business purposes
(as laid out in Section 5 and as permitted by applicable law.
In practice, we delete or anonymize your information upon deletion of your account, unless:
1. we must keep it to comply with applicable law;
2. we must keep it to evidence our compliance with applicable law;
3. there is an outstanding or potential issue, claim or dispute requiring us to keep
the relevant information until it is resolved; or
4. the information is kept for our legitimate business interests, such as fraud
prevention and enhancing users' safety and security. For example, information
may need to be kept to prevent a user who was banned for unsafe behavior or
security incidents from opening a new account.
Keep in mind that even though our systems are designed to carry out data deletion processes
according to the above guidelines, we cannot promise that all data will be deleted within a specific
timeframe due to technical constraints.
12. CHILDREN’S PRIVACY
Our services are restricted to users who are 18 years of age or older. We do not permit users
under the age of 18 on our platform and we do not knowingly collect personal information from
anyone under the age of 18. If you suspect that a user is under the age of 18, please use the
reporting mechanism available through the service.
13. PRIVACY POLICY CHANGES
Because we’re always looking for new and innovative ways to help you build meaningful
connections, this policy may change over time. We will notify you before any material changes
take effect so that you have time to review the changes.
14. HOW TO CONTACT US
If you have questions about this Privacy Policy, here’s how you can reach us: If you live in the
European Union:
Online: here
By post:
Privacy Officer
Right Stuff App, Inc
3230 E Imperial Hwy, Suite 300
Brea, CA 92821
Copyright 2022 TheRightStuff, LLC. All rights reserved.
