Privacy Policy

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1. Overview / Who We Are

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Shmoozer Inc. ("Shmoozer," "we," "us," or "our") is a Delaware corporation that operates a platform connecting individuals seeking companionship-style conversations with service providers who offer such conversations via voice 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 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 connect with Shmoozers for conversations; and

• "Shmoozers" – individuals who provide conversation services to Users through our platform.

Additional defined terms used in this Policy:

• "Call Recordings" means recordings of voice or video calls conducted through the Services.

• "Messages" means text-based communications sent through our in-app messaging feature.

• "Platform" means the Shmoozer mobile application, website, and related technology infrastructure.

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.

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2. Information We Collect

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

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2.1 Information You Provide

Website Waiting List:

If you sign up for our waiting list on shmoozer.com, we collect your full name and email address.

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

• Preferences and filter settings for matching with Shmoozers

• Ratings and reviews you provide about Shmoozers

• Reports you submit about Shmoozers or other Users

• Communications with our customer support team

Shmoozer Onboarding Information:

• Full legal name and contact information

• Profile information and display name

• Course completion and interview records

• Background check authorization and status

• Tax documentation (IRS Form W-9)

• Payout information submitted through Stripe Connect (see Section 2.5)

• 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 and improve our Services.

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2.3 Call and Message Data

Call Data:

• Call Recordings: All voice and video calls conducted through the Services are recorded. See Section 5 for details on retention.

• Call Metadata: We collect information about calls, including date, time, duration, participants, and ratings. We do not currently create transcripts or AI-generated summaries of calls, though we may implement such features in the future with appropriate notice.

Message Data:

• Message Content: The content of Messages you send and receive through the Services.

• Message Metadata: Date, time, and participants of Messages.

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2.4 Message Monitoring and Enforcement

We do not permit Users and Shmoozers to exchange personal contact information through Messages (such as phone numbers, email addresses, physical addresses, or social media handles). To help enforce our of Service and keep the Services safe, we (and our service providers) may use technical controls and automated tools to detect, block, remove, or limit Messages that appear to contain prohibited content, spam, fraud, abuse, or violation applicable law.

In addition, we may access and review Messages (and related metadata) in limited circumstances, 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) comply with applicable law or legal process; or (e) protect the rights, safety, and security of the Platform, our users, and the public. We do not undertake to routinely review all Messages, and we may take action based on automated detection or human review, as appropriate.

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2.5 Background Check Data (Shmoozers)

As part of the Shmoozer onboarding process, we require a background check conducted through our third-party provider, HireRight. When you authorize a background check:

• HireRight collects and processes personal information necessary to conduct the background check, which may include your name, phone number, Social Security number, date of birth, and address history.

• Shmoozer receives a status and limited summary results (such as pass/fail determinations) necessary to make vetting decisions.

• We retain background check status and limited results data as necessary for compliance, safety, and ongoing vetting purposes.

HireRight's collection and processing is subject to its own privacy policy. We encourage you to review HireRight's privacy practices.

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2.6 Payment and Payout Data

User Payments:

User payments are processed through Apple / Apple Pay / Apple App Store, Google / Google Pay / Google Play Store and Stripe. When you make a purchase, Stripe collects your payment information (such as credit card number and billing address) directly. Shmoozer receives limited transaction information from Stripe (such as confirmation of payment, transaction amount, and last four digits of your card) but does not store full payment card details.

Shmoozer Payouts:

Shmoozers receive payouts through Stripe Connect. As part of payout onboarding, Stripe Connect 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 Stripe; Shmoozer does not directly store full bank account numbers or Social Security numbers collected through Stripe Connect.

Stripe's collection and processing is subject to the Stripe Privacy Policy. We encourage you to review Stripe's privacy practices.

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3. How We Use Information

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We use the information we collect for the following purposes:

• Provide and Operate the Services: To create and manage accounts, facilitate matching between Users and Shmoozers, enable voice/video calls and messaging, and deliver the core functionality of the Platform.

• Process Payments and Payouts: To process User payments, calculate Shmoozer earnings, and facilitate payouts through Stripe Connect.

• Vet and Onboard Shmoozers: To verify Shmoozer eligibility, conduct background checks, administer training, 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, Shmoozers, and others.

• Enforce Messaging Rules and Prevent Abuse: To enforce our Terms of Service and policies (including restrictions on sharing contact information and limits designed to prevent unwanted messaging), detect and prevent spam/fraud, and promote safety and trust on the Platform.

• 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.

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4. How We Share Information

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We share information in the following circumstances:

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4.1 Between Users and Shmoozers

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

• Display name, real name (you can choose to show either your display name or real name) and profile information

• Star ratings

• Interest and filter preferences (e.g. interests, age, gender, star rating, as applicable to matching)

• Message content exchanged between you and Shmoozers

• Information you exchange with Shmoozers during voice and video calls

• Profile photos, if collected

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

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4.2 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

• Apple / Apple Pay / Apple App Store and Google / Google Pay / Google Play Store: Payment processing, in-app purchases

• HireRight: Background check services for Shmoozers

• 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.

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4.3 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 Shmoozer, our users, or others

• Investigate reports, potential violations, or suspected fraud

• Respond to an emergency involving danger of death or serious physical injury

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4.4 Business Transfers

If Shmoozer 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.

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4.5 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.

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5. Recording, Retention, and Deletion

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5.1 Call Recording

All voice and video calls conducted through the Services are recorded. We record calls for safety, quality assurance, dispute resolution, and enforcement purposes. By using the Services, you consent to the recording of your calls.

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5.2 Call Recording Retention

Call Recordings are retained as follows:

• Standard Retention: Call Recordings are retained for twenty-four (24) hours following the completion of a call and are then automatically deleted.

• Report-Based Retention: If either party files a report about a call, the relevant recording may be retained for a longer period as necessary to investigate the report and take appropriate action.

• Legal Retention: Recordings may be retained longer if required by law, legal process, or for ongoing legal matters.

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5.3 Message Retention

We retain Messages and message metadata while your account is active and until you permanently delete your account. If you permanently delete your account, we will delete Messages from our active systems within a reasonable period, but copies may persist in backups for a limited time.

We may retain Messages and/or related records (for example, reports, enforcement actions, and audit logs) for longer 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.

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5.4 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.

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.

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5.5 Deletion Requests

You may request deletion of your account and personal information by contacting us at support@shmoozer.com. Deletion requests are subject to legal holds, ongoing investigations, and other retention requirements described in this Policy.

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6. Your Choices and Rights

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6.1 Account Information

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

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6.2 Account Deletion

You may request deletion of your account by contacting us at support@shmoozer.com. Please note that deletion is subject to the retention requirements described in Section 5.

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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.

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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. You cannot opt out of these communications while you maintain an account.

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7. Security

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

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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@shmoozer.com.

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9. U.S. State Privacy Disclosures

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

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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

• Personal Information (Cal. Civ. Code § 1798.80(e)): Name, telephone number (if collected through Stripe for verification)

• Commercial Information: Transaction history, purchase records

• Internet or Network Activity: Usage data, 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: Call Recordings

• Professional Information: Background check status (Shmoozers)

• Inferences: Preferences and characteristics derived from the above

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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, ensuring safety, analytics, and legal compliance.

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9.3 Categories of Recipients

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

• Other users (Users and Shmoozers, as applicable)

• Service providers (hosting, payments, analytics, background checks)

• Government and law enforcement (when required by law)

• Business transaction parties (in connection with corporate transactions)

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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.

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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@shmoozer.com. We may need to verify your identity before processing your request.

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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.

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10. International Users

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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.

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11. Changes to This Policy

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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.

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12. Contact Us

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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@shmoozer.com