Privacy Policy

Last Updated: October 16, 2026

1. Overview / Who We Are

Shmoozer Inc. ("Company," "we," "us," or "our") is a Delaware corporation that operates a platform through which Smoozers, including influencers and other individuals with their own audiences, offer paid access to interact with them via audio calls, video calls, and messaging.

This Privacy Policy describes how we collect, use, disclose, and protect your information when you visit our website at shmoozer.com, use our mobile application or the Portal, or otherwise interact with our services (collectively, the "Services"). This Policy applies to all users of our Services, including:

"Users": individuals who access the Services to purchase or receive paid calls, messaging, or other offerings from Smoozers;
"Smoozers": individuals approved to offer paid calls, messaging, and other offerings to Users through our Platform; and
"Referral Participants": individuals to whom the Company has issued a referral link, whether or not they have been approved as Smoozers. This Policy also applies to individuals who join our waitlist, create a prelaunch account, or sign up through another participant’s referral link.

Additional defined terms used in this Policy:

"Smoozer Page" means a Smoozer's public profile page or link through which Users may view the Smoozer's profile and purchase the Smoozer's offerings.
"Earnings Schedule" means the Smoozer Earnings Schedule posted in the Portal, which describes Smoozer offering formats, revenue share, payouts, and the Referral Program.
"Messages" means text-based communications sent through our in-app messaging feature.
"Platform" means the Company's mobile application, website, Portal, and related technology infrastructure.
"Referral Program" means the program through which participants receive a unique referral link and may earn referral commissions for referring new Smoozers to the Platform, as described in our Terms of Service and the Earnings Schedule.
"Portal" means the online portal, including account dashboards, through which Smoozers and Referral Participants manage their accounts, offerings, earnings, referrals, and payouts.

By using our Services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with our practices, please do not use our Services.

2. Information We Collect

We collect information in several ways: directly from you, automatically when you use our Services, and from third-party sources.

2.1 Information You Provide

Prelaunch Accounts and Waitlist:

If you create a prelaunch account or sign up for our waitlist, we collect your full name, email address, account login credentials, and any other information requested on the signup form. Before launch, prelaunch accounts provide access to a limited referral dashboard and information about the anticipated launch.

Referral Program Information:

Your unique referral link or code, and a record of your acceptance of the referral program conditions and the Terms of Service (including the date, time, and version accepted)
Referral attribution information, such as which referral link was used to sign up, the date and time of account creation, and the referring participant
Referral status and commission records, including whether a referral qualified, the commission period applicable to each referral, and the referral commissions accrued, paid, withheld, or reversed
Information used to detect and prevent referral fraud, such as device identifiers, IP address, and signals indicating self-referrals or duplicate accounts
If you are eligible to receive referral commissions, tax documentation (IRS Form W-9), your selected payout provider, and payout information submitted through Stripe Connect, PayPal, or Venmo (see Section 2.5)

If you share your referral link with others, we do not receive information about those individuals unless they visit or sign up through your link.

User Account Information:

Account registration information, including email address
Information from Google Sign-In (if you choose this registration method), which may include your name and email address
Profile information such as display name, profile photo, gender, date of birth, and interests
Searches you run on the Platform for Smoozers
Ratings and reviews you provide about Smoozers
Reports you submit about Smoozers or other Users
Purchase information, such as the Smoozer offerings you purchase (including subscriptions, bundles, and pay-as-you-go calls), your remaining subscription allotment or bundle balance, your usage of call time and Messages, and your purchase, renewal, cancellation, and refund history
Communications with our customer support team

Smoozer Onboarding and Account Information:

Full legal name and contact information
Identity and age verification information, including government-issued identification and a selfie submitted through Persona to verify your identity and confirm that you are at least 18. We use Persona to support verification and Smoozer onboarding. Information processed in connection with verification may include information you submit and verification results.
Profile information and display name
Tax documentation (IRS Form W-9)
Your selected payout provider and payout information submitted through Stripe Connect, PayPal, or Venmo (see Section 2.5)
Smoozer Page information, such as your display name, profile photo, bio, and any social media links you add
Smoozer offering settings, such as the offerings you make available (subscriptions, bundles, and pay-as-you-go calls), the allotments included in each, your rates, whether you offer audio calls, video calls, or Messages, and when you are available
Earnings records, such as revenue from your offerings, platform fees, processing fees, refunds and chargebacks, balances held before they become available for payout, and payouts
Communications with our support team

2.2 Information Collected Automatically

When you use our Services, we automatically collect certain information, including:

Device and Technical Information: IP address, device type, operating system, unique device identifiers, app version, browser type, and mobile network information.
Usage Information: How you interact with our Services, including features used, actions taken, time and duration of use, and navigation paths.
Analytics Data: We use Mixpanel and may use Google Analytics to collect analytics information about your use of the Services.
Location Information: We may collect approximate location based on IP address.
Cookies and Similar Technologies: On our website, we may use cookies, pixels, and similar technologies to collect information (including to attribute sign-ups to the referral link used) and improve our Services.

2.3 Call and Message Data

Call Data:

No Call Recording: We do not record the audio or video content of calls conducted through the Services. Audio and video are transmitted in real time through our call infrastructure provider to connect the call.
Call Metadata: We collect information about calls, including date, time, duration (including connected call time used to measure subscription and bundle usage and to calculate pay-as-you-go charges), participants, and ratings. We do not create transcripts or AI-generated summaries of calls.

Message Data:

Message Content: The content of Messages you send and receive through the Services. Messages are stored in encrypted form.
Message Metadata: Date, time, and participants of Messages, and, where Messages are purchased, the number of Messages used for billing and to measure subscription and bundle usage.

2.4 Message Monitoring, Automated Review, and Enforcement

Users and Smoozers may choose to share personal or contact information through Messages. Sharing this information is at your own risk, and we do not control communications that take place outside the Platform. To help enforce our Terms of Service, maintain the quality of the Services, and keep the Services safe, we (and our service providers) may use automated tools, including artificial intelligence systems, to review Messages and to detect, flag, block, remove, or limit Messages that appear to contain prohibited content, spam, fraud, abuse, or violations of applicable law.

The Services may automatically detect Messages that appear to contain personal or contact information and notify you, or the person you are messaging, when such information is shared.

In addition, authorized personnel may access and review Messages (and related metadata), such as to: (a) respond to customer support requests; (b) investigate reports or suspected violations of our Terms of Service or policies; (c) address safety concerns; (d) conduct quality control; (e) comply with applicable law or legal process; or (f) protect the rights, safety, and security of the Platform, our users, and the public. We may take action based on automated detection, human review, or both, as appropriate.

2.5 Payment and Payout Data

User Payments:

Depending on how you make a purchase, your payment is processed by one of the following: (a) Apple or Google, for in-app purchases made through the Apple App Store or Google Play Store, in which case Apple or Google collects your payment information under its own terms and privacy policy and we receive limited transaction information, such as confirmation of the purchase and the item purchased; or (b) Stripe, for purchases made on our website or otherwise through Stripe, in which case Stripe collects your payment information (such as credit card number and billing address) directly and we receive limited transaction information (such as confirmation of payment, transaction amount, and last four digits of your card). Apple Pay and Google Pay may be available as payment methods within these flows. The Company does not store full payment card details.

Smoozer Payouts and Referral Commissions:

Smoozers receive payouts of their earnings, and Referral Participants receive referral commissions, through the payout provider they select: Stripe (through Stripe Connect), PayPal, or Venmo. As part of payout onboarding, your payout provider may collect sensitive information, including bank account details, Social Security number, date of birth, and government-issued identification for identity verification purposes. This information is collected and processed by your payout provider; the Company does not directly store full bank account numbers or Social Security numbers collected by Stripe, PayPal, or Venmo. We receive information needed to make and track payouts, such as your payout account status and the amount and status of each payout.

Stripe's collection and processing is subject to the Stripe Privacy Policy, and PayPal's and Venmo's collection and processing is subject to their respective privacy statements. We encourage you to review your payout provider's privacy practices.

3. How We Use Information

We use the information we collect for the following purposes:

Provide and Operate the Services: To create and manage accounts (including prelaunch accounts), host Smoozer Pages, enable Users to search for Smoozers, enable Smoozers to set up and manage their offerings, rates, and availability, enable voice/video calls and messaging, and deliver the core functionality of the Platform.
Process Payments and Payouts: To process User payments, administer subscriptions, bundles, and pay-as-you-go calls, measure usage against subscription allotments and bundle balances, allocate revenue between Smoozers and the Company, calculate Smoozer earnings, hold earnings until they become available for payout, process refunds, chargebacks, and payment disputes, and facilitate payouts through Stripe Connect, PayPal, or Venmo.
Administer the Referral Program: To issue referral links, attribute sign-ups to the correct referrer, determine whether referrals qualify, calculate and pay referral commissions, prevent self-referrals, duplicate accounts, and other referral fraud, and communicate with you about your referral status.
Onboard Smoozers: To verify Smoozer identity, age, and eligibility through Persona and manage the onboarding process.
Safety and Moderation: To investigate reports, enforce our Terms of Service and policies, detect and prevent fraud, and protect the safety of Users, Smoozers, and others.
Enforce Messaging Rules and Prevent Abuse: To enforce our Terms of Service and policies, detect and prevent spam and fraud, and promote safety and trust on the Platform.
Quality Control and Model Improvement: To review Messages and other content, including through automated tools and artificial intelligence systems, for quality control, and to train or improve our algorithms and safety systems.
Analytics and Improvement: To understand how our Services are used, identify trends, and improve and develop new features and functionality.
Customer Support: To respond to your inquiries, troubleshoot issues, and provide assistance.
Legal Compliance: To comply with applicable laws, regulations, and legal processes, and to respond to lawful requests from public authorities.
Communications: To send you transactional and administrative communications, such as account notifications, service updates, security alerts, and support messages, as well as updates about the Platform's launch and your referral status.

4. How We Share Information

We share information in the following circumstances:

4.1 Between Users and Smoozers; Smoozer Pages

To facilitate the Services, we share certain information between Users and Smoozers:

Display name or legal first name (you can choose which to show) and profile information
Star ratings
Message content exchanged between Users and Smoozers
Information exchanged between Users and Smoozers during voice and video calls
Profile photos, if collected

Communications between Users and Smoozers are intended to be private as between you and your conversation partner, subject to this Policy, our Terms, reports, safety reviews, and legal requirements.

Smoozer Pages are public and may be shown in search results on the Platform. If you are a Smoozer, the information on your Smoozer Page, such as your display name, profile photo, bio, offerings, rates, and availability, and any social media links you add, may be visible to anyone who visits it, including people who do not have an account.

4.2 Referral Program

If you sign up through another participant's referral link, we may share with that participant limited information needed to administer the Referral Program, such as your name or display name, whether you joined through their link, whether your referral qualified, and information about referral commissions. This information may be displayed in the referring participant's referral dashboard, including before the Platform's launch. Depending on the information displayed, your referrer may be able to infer information about your activity or revenue on the Platform. We do not share your contact information, Messages, or identity verification information with your referrer. If you participate in the Referral Program, your referral link and related sign-up pages may identify you, such as by your name or display name, to the people with whom you share it.

4.3 Service Providers

We share information with third-party service providers who perform services on our behalf, subject to contractual obligations to protect your information. Our service providers include:

QuickBlox: Voice and video call infrastructure (WebRTC)
Amazon Web Services (AWS): Cloud hosting and data storage (including AWS S3)
Stripe / Stripe Connect: Payment processing, payout processing, and identity verification
PayPal and Venmo: Payout processing
Persona: Identity and age verification
Apple / Apple Pay / Apple App Store and Google / Google Pay / Google Play Store: Payment processing, in-app purchases
Mixpanel: Product analytics
Analytics and attribution: providers such as Google Analytics or Adjust
Customer Support Tools: We provide support via email and may use customer support tools/service providers (e.g. Zendesk) from time to time.
Website, waitlist, and referral services: Providers that host our website and waitlist and support referral tracking and attribution.
Automated review services: Providers that support the automated message review described in Section 2.4.

4.4 Legal, Safety, and Compliance

We may disclose information if we believe in good faith that such disclosure is necessary to:

Comply with applicable law, regulation, legal process, or governmental request
Enforce our Terms of Service and other agreements
Protect the safety, rights, or property of the Company, our users, or others
Investigate reports, potential violations, or suspected fraud
Respond to an emergency involving danger of death or serious physical injury

4.5 Business Transfers

If the Company is involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of assets, your information may be transferred as part of that transaction. We will provide notice if your information becomes subject to a different privacy policy.

4.6 No Sale of Personal Information

We do not sell your personal information. We do not share your personal information with third parties for cross-context behavioral advertising purposes.

5. Retention and Deletion

5.1 Message Retention

Messages are stored in encrypted form. We retain Messages and message metadata while your account is active for safety, quality control, dispute resolution, legal compliance, and enforcement purposes. If you permanently delete your account, we delete Messages and message metadata from our active systems promptly, subject to the retention exceptions below. Copies may persist in backups for a limited period.

We may retain Messages, message metadata, and related records for longer (for example, reports, enforcement actions, and audit logs) where reasonably necessary to: (a) investigate reports or suspected violations; (b) enforce our Terms of Service and policies; (c) comply with law, legal process, or lawful requests; (d) resolve disputes; or (e) protect the rights, safety, and security of the Platform, our users, and others.

5.2 Account Data Retention

We retain account information for as long as your account is active and for a reasonable period thereafter to fulfill the purposes described in this Policy, comply with legal obligations, resolve disputes, and enforce our agreements. We retain transaction, earnings, and payout records, including records of purchases, subscriptions, bundles, usage-based charges, refunds, chargebacks, and revenue allocations between Smoozers and the Company, for as long as necessary to process payments and payouts, resolve disputes, and comply with tax, accounting, and recordkeeping obligations.

We retain Referral Program records, including referral attribution, commission, tax, and payout records, for as long as necessary to administer the Referral Program, calculate and pay referral commissions, resolve disputes, prevent fraud, and comply with tax and recordkeeping obligations, which may extend beyond the closure of your account. We retain prelaunch account and waitlist information to maintain your account, provide launch updates, and administer your participation in the Services. You may request deletion as described in Section 5.3, subject to the retention exceptions described in this Policy.

Even after account deletion, certain information may persist in our backup systems for a limited period and may be retained as necessary for legal, safety, or compliance purposes.

5.3 Deletion Requests

You may request deletion of your account and personal information through the app or by contacting us at support@smoozer.com. Deletion requests are subject to legal holds, ongoing investigations, and other retention requirements described in this Policy. If you request deletion while earnings or referral commissions are pending, we may retain the information needed to calculate, pay, or account for those amounts, as described in our Terms of Service and the Earnings Schedule.

6. Your Choices and Rights

6.1 Account Information

You may update your account information and preferences through your account settings in the app or the Portal. If you need assistance, contact us at support@smoozer.com.

6.2 Account Deletion

You may delete your account through the app or request deletion by contacting us at support@smoozer.com. Deleting your account also cancels your subscriptions. Deleting the app from your device does not delete your account or cancel your subscriptions. Please note that deletion is subject to the retention requirements described in Section 5.

6.3 Analytics Opt-Outs

You may be able to limit certain analytics collection through the following methods:

Device Settings: Your mobile device may offer settings to limit ad tracking or analytics collection.
Browser Settings: You can control cookies through your browser settings.
Mixpanel: You can learn about Mixpanel's data practices and opt-out options through Mixpanel's privacy documentation.
Google Analytics: If we use Google Analytics, you can use the Google Analytics Opt-Out Browser Add-on or adjust your device's advertising settings.

6.4 Communications Preferences

We send transactional and administrative communications that are necessary for the operation of the Services. These include account notifications, security alerts, and service updates, as well as notices of changes to our Terms of Service or the Earnings Schedule. You cannot opt out of these communications while you maintain an account. If you join our waitlist or participate in the Referral Program, we will also send you communications about the Platform's launch and your referral status and commissions.

7. Security

We use reasonable administrative, technical, and physical safeguards designed to protect your personal information from unauthorized access, use, alteration, and disclosure, including encryption of stored Messages. However, no method of transmission over the internet or electronic storage is completely secure, and we cannot guarantee the absolute security of your information.

8. Children's Privacy

The Services are not intended for individuals under the age of 18. We do not knowingly collect personal information from anyone under 18. If we learn that we have collected personal information from a child under 18, we will take steps to delete that information as quickly as possible. If you believe we have collected information from a child under 18, please contact us at support@smoozer.com.

9. U.S. State Privacy Disclosures

This section provides additional information for residents of California and other states with comprehensive privacy laws.

9.1 Categories of Personal Information

In the preceding 12 months, we have collected the following categories of personal information:

Identifiers: Name, email address, IP address, device identifiers, account credentials, referral link or code
Personal Information (Cal. Civ. Code § 1798.80(e)): Name, telephone number (if collected by a payout provider for verification), Social Security or taxpayer identification number (on IRS Form W-9, for Smoozers and Referral Participants eligible for payouts). Identity verification may also involve government-issued identification information processed by Persona.
Commercial Information: Transaction history, purchase records (including subscriptions, bundles, and pay-as-you-go calls), refunds and chargebacks, Smoozer offering and rate settings, Smoozer earnings and revenue share records, referral activity, and referral commission and payout records
Internet or Network Activity: Usage data, search and browsing history within the Services, device information
Geolocation Data: We do not collect precise geolocation data, but may infer approximate location from IP address for security/fraud prevention and to enforce U.S.-only availability of the Platform.
Audio and Visual Information: Profile photos, identification images and selfies submitted for identity verification, and other images you upload. We do not record calls.
Inferences: Preferences and characteristics derived from the above

9.2 Purposes for Collection and Use

We collect and use personal information for the business and commercial purposes described in Section 3 of this Policy, including providing the Services, processing payments and payouts, ensuring safety, quality control, analytics, and legal compliance.

9.3 Categories of Recipients

We disclose personal information to the categories of recipients described in Section 4, including:

Other users (Users and Smoozers, as applicable), and the public (for information Smoozers display on their Smoozer Pages)
Referral Participants (limited referral status and commission information, as described in Section 4.2)
Service providers (hosting, payments, payouts, analytics, website hosting, and referral tracking)
Government and law enforcement (when required by law)
Business transaction parties (in connection with corporate transactions)

9.4 Retention

We retain personal information as described in Section 5, generally for as long as necessary to provide the Services, comply with legal obligations, and resolve disputes.

9.5 Your Rights

Depending on your state of residence, you may have the following rights:

Right to Know: Request information about the categories and specific pieces of personal information we have collected about you.
Right to Delete: Request deletion of your personal information, subject to certain exceptions.
Right to Correct: Request correction of inaccurate personal information.
Right to Opt-Out of Sale/Sharing: We do not sell personal information or share it for cross-context behavioral advertising. If this changes, we will provide an opt-out mechanism.
Right to Non-Discrimination: We will not discriminate against you for exercising your privacy rights.

To exercise your rights, contact us at support@smoozer.com. We may need to verify your identity before processing your request.

9.6 Authorized Agents

You may designate an authorized agent to submit requests on your behalf. Authorized agents must provide proof of authorization (such as a power of attorney or written permission signed by you), and we may still require you to verify your identity directly with us.

10. International Users

The Services are currently intended for users located in the United States. If you access the Services from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States, where our servers are located and our central database is operated. By using the Services, you consent to such transfer, storage, and processing.

11. Changes to This Policy

We may update this Privacy Policy from time to time. If we make material changes, we will notify you by posting the revised Policy on our website and app and updating the "Last Updated" date above. We may also notify you by email or through the application. Your continued use of the Services after any changes indicates your acceptance of the updated Policy.

12. Contact Us

If you have any questions about this Privacy Policy or our privacy practices, please contact us at:

Shmoozer Inc.

8 The Green, Dover, DE, 19901, United States

Email: support@smoozer.com