Second Innings Privacy Policy

KEY POINTS

• What this covers. This Privacy Policy explains how Second Innings, Inc. collects, uses, discloses, and retains personal information when you use the Services, as that term is defined in our Terms of Service.
• Sensitive information is optional. Many profile and questionnaire fields ask about topics such as religion, ethnicity, sexual orientation, gender identity, relationship history, children, health, wellbeing, income, and lifestyle. You choose whether to provide them. If you do, we use them to build your profile, show compatibility, and help you match, and some may be visible to other members.
• Face analysis. With the consent you give at signup, we and our service providers analyze your profile photos and selfies for safety, fraud prevention, duplicate-account detection, age assurance, and verification, as described in our Biometric Data Policy.
• Advertising. Free experiences of the app show ads. We do not sell your personal information. Some information is disclosed to advertising partners in ways that some US state laws call "sharing" or "targeted advertising." You can opt out in the app under Settings > Your Privacy Choices > Do Not Sell or Share My Personal Information, and on our website with a Global Privacy Control signal.
• AI. We use AI Features, including AI model providers that process data under contract and are not permitted to train their models on it. We do not use your private messages, your Inputs, or your sensitive personal information to train generalized AI models. Your AI Companion chat history is stored on your device, not on our servers.
• Messages are not end-to-end encrypted. Messages pass through our systems, may be scanned, held, delayed, or not delivered by moderation, and may be reviewed by authorized personnel for safety, support, and legal reasons.
• Deletion. You can delete your account in the app. Deletion has a 14-day grace period, after which we erase or anonymize your information, except for limited records we keep for the periods described in Section 11.
• Your rights. Depending on where you live, you may have rights to access, correct, delete, export, and limit or object to uses of your information. Contact privacy@secondinnings.app or use the tools in the app.

1. WHO WE ARE AND WHAT THIS POLICY COVERS

1.1 Controller. Second Innings, Inc., a Delaware corporation, 9206 Sunshine Pl, Downey, CA 90240, USA ("Second Innings," "we," "us," or "our"), is responsible for the personal information described in this Privacy Policy. For purposes of the EU and UK General Data Protection Regulation and similar laws, Second Innings is the controller. For purposes of India's Digital Personal Data Protection Act, 2023, Second Innings is the Data Fiduciary.

1.2 Scope. This Privacy Policy applies to personal information we process in connection with the Services, including the Second Innings mobile applications, the website at secondinnings.app and its subdomains, our communications, and our AI Features. It applies to members, website visitors, people who pre-register or contact us, and anyone else whose personal information we process in connection with the Services. Capitalized terms that are not defined here, such as "Services," "Agreement," "AI Features," "Inputs," "Insight Features," "Paid Features," and "User Content," have the meanings given in our Terms of Service.

1.3 Related policies. The following policies supplement this Privacy Policy and are part of it:

• Cookie and Tracking Technologies Policy - secondinnings.app/cookie-policy
• Biometric Data Policy - secondinnings.app/biometric-policy
• Consumer Health Data Privacy Policy - secondinnings.app/consumer-health-data-policy
• AI Features Disclosure and Crisis Safety Protocol - secondinnings.app/ai-disclosure
• Law Enforcement Guidelines - secondinnings.app/law-enforcement

Where a supplement addresses a topic in more detail, the supplement controls for that topic. As stated in Section 1.4 of our Terms of Service, this Privacy Policy and its supplements control on how we handle personal information.

1.4 What this policy does not cover. This Privacy Policy does not cover the practices of third parties that we do not control, such as Apple, Google, Meta, or other members, even when you reach them through the Services. Their own privacy policies apply.

1.5 Definitions. "Personal information" means information that identifies, relates to, describes, or can reasonably be linked to an individual or device, and includes "personal data" and similar terms under applicable law. "Sensitive personal information" means the categories described in Section 2.3 and any information treated as sensitive under applicable law. "Members" means people who have an account on the Services.

2. CATEGORIES OF PERSONAL INFORMATION WE COLLECT

The information we collect depends on how you use the Services, the features you choose, your device settings, and the choices you make. The categories below are illustrative, not exhaustive.

2.1 Information you provide

• Account and contact information, such as your email address, mobile phone number and country code, and, if you sign in with Apple, Google, or Facebook, the account identifier and the information that provider shares with us (for example, your name, email address, and profile photo).
• Identity and profile information, such as your first, middle, and last name, name pronunciation, date of birth, gender, other gender description, pronouns, the genders you are interested in meeting, relationship or marital status (for example, divorced, separated, widowed, or single), whether you have or want children, height, body type, education, profession, income, languages, interests, hobbies, lifestyle habits (such as drinking, smoking, diet, fitness, and pets), zodiac sign, cultural background, and free-text sections such as "About Me," "My Story," "Life Summary," and "My Ideal Soulmate."
• Questionnaire answers, including multiple-choice, range, and free-text answers to optional questions about values, beliefs, background, relationship history (for example, how and why a prior relationship or marriage ended), family, finances, communication, emotional wellbeing, and the qualities you want in a partner.
• Partner preferences and filters, such as age range, distance, gender, relationship status, religion, ethnicity, language, children, and lifestyle preferences.
• Photos and media, such as profile photos, and any metadata embedded in them (for example, EXIF data, which may include the date, device, and location where a photo was taken).
• Verification and age assurance information, such as selfies, short selfie videos or sequences of frames, gesture prompts, and timing information captured during photo or liveness verification, and any age range or age signal your device or app store provides. If we ask you to provide a government-issued identification document or other documents (for example, to verify your age, resolve an appeal, or investigate fraud), we collect what you provide.
• Astrology information, such as your date of birth, time of birth, place of birth, birth coordinates, preferred astrology system (for example, Vedic or Western), and preferred language.
• Messages and communications with members, such as the content of messages you send and receive, message requests, and related information such as timestamps, delivery status, read receipts, and typing indicators.
• AI Inputs, such as the questions and messages you send to the AI Companion or other AI Features.
• Purchase information, such as the subscriptions, add-ons, boosts, credits, and other Paid Features you buy, product identifiers, transaction and order identifiers, purchase tokens, prices, currency, and promotional or offer codes. Payments are processed by Apple or Google; we do not receive your full payment card number.
• Communications with us, such as support requests, contact forms, screenshots or images you attach, survey responses, in-app ratings and reviews, feedback, bug reports, help-center reactions, and the reasons you give for deactivating or deleting your account.
• Reports, blocks, and appeals, such as the reasons and descriptions you provide when you report or block another member or appeal a decision.
• Website and pre-registration information, such as your name, email address, phone number, date of birth, gender, the gender you want to meet, address, and message when you pre-register, subscribe, contact us, or update your email preferences on our website.
• Settings and preferences, such as language, units of measurement, notification preferences (including marketing preferences and message previews), privacy choices, and consent records.

2.2 Information you provide about other people

You may provide information about other people, for example in messages, reports, free-text profile sections, or AI Inputs. Information about your children, former partners, or other people should be limited to what you are comfortable sharing and have the right to share. Please do not upload photos of children or share identifying information about them.

2.3 Sensitive personal information

Some of the information described above is sensitive personal information under applicable law. Depending on what you choose to provide and the features you use, this may include:

Providing optional sensitive information is your choice. If you choose to provide it, you consent to its use as described in this Privacy Policy, including for matching, compatibility, and display to other members where the feature indicates. You can change, hide where the feature allows, or delete optional answers at any time in the app, and you can withdraw consent as described in Section 15.

2.4 Information collected automatically

• Device and app information, such as device model, operating system and version, app version and build number, language, time zone (sent with each request), screen and network information, and push notification tokens.
• Device and account identifiers, such as a persistent device identifier (on Android, the Android ID; on iOS, an identifier stored in your device keychain that may persist after the app is deleted), Firebase installation identifiers, push tokens, app integrity attestations (for example, from Google Play Integrity, Apple App Attest, or DeviceCheck), and, subject to your device settings and choices, mobile advertising identifiers (the Apple IDFA and the Google advertising ID).
• IP address and network information, such as your IP address, the approximate location derived from it, user agent, and request metadata. We collect IP addresses with requests to our servers, sign-in and one-time code requests, security checks, uploads, consent records, and location updates.
• Location information. If you allow location access, we collect your device's location (which may be precise enough to identify a street or block), and we may derive a street address, city, state, postal code, and country from it. We may update your location when you open or return to the app. If you do not allow location access, we use an approximate location derived from your IP address, or a city you enter. We keep a record of location updates over time, including the source of each update (for example, device, IP address, or city entry) and the associated IP address.
• Usage and activity information, such as the screens you view and the order in which you view them, session start and end times, the profiles you view, like, skip, save, or revisit, your matches and conversations, how you interact with notifications, in-app messages, pop-ups and campaigns, features you use, daily usage counts and quotas, searches and filters, and the time and frequency of your activity.
• Diagnostics and performance information, such as crash reports, error logs, stack traces, records of failed requests (with credentials and contact details redacted), performance traces of network requests, and app health information.
• Information from cookies, pixels, SDKs, and similar technologies, as described in Section 9 and our Cookie and Tracking Technologies Policy.
• App presence information. On some devices, the app checks whether WhatsApp or WhatsApp Business is installed so that we can choose how to send your one-time code. On Android, the app may also offer your phone number through Google's Phone Number Hint feature. The app may read your device's region, SIM or network country, time zone, and locale on your device to suggest your country code.

2.5 Information from other sources

• Sign-in providers (Apple, Google, Meta), as described in Section 2.1.
• Other members, for example when they report you, block you, send you messages, describe you in a message, or request a compatibility or astrology report that uses information from your profile.
• Service providers, such as verification and face analysis results, age estimates, image and text moderation results, reverse image search results, fraud and bot detection scores, phone number lookup and formatting results, message delivery status, IP-based location results, and geocoding results.
• App stores and payment platforms (Apple and Google), such as transaction, renewal, cancellation, refund, and subscription status information, and age signals your device or store account provides.
• Advertising and analytics partners, such as information about the ad or campaign that led you to the Services, app install attribution, and aggregated measurement reports.
• Publicly available sources, for example where a reverse image search finds a profile photo published elsewhere online.
• Business transferees or successors, in connection with a transaction described in Section 8.7.

2.6 Information we create or infer

We and our automated systems create information about you, which may include:

• match scores, compatibility percentages, match labels, Match Meter results, "why this match" explanations, and ReMatch AI recommendations;
• preference signals learned from your activity (for example, the ages, distances, and relationship statuses of profiles you tend to like), and engagement signals, such as how often other members like or respond to your profile;
• trust, safety, quality, and moderation signals, such as moderation status, verification status, spam or fraud scores, and records of possible duplicate accounts;
• age estimates and approximate location;
• astrology charts and derived attributes, such as signs, doshas, and compatibility readings; and
• aggregated or de-identified information that does not reasonably identify you.

3. HOW WE USE PERSONAL INFORMATION

We use personal information for the purposes below. A single piece of information may be used for more than one purpose.

3.1 Providing the Services. To create and maintain your account; authenticate you and send one-time codes; build and display your profile; show you profiles and show your profile to others; provide matching, discovery, filters, Smart Match, ReMatch AI, Match Meter, astrology, boosts, and other features; deliver messages, notifications, and in-app messages; provide AI Features; process purchases, renewals, credits, and entitlements; and provide support.

3.2 Matching, ranking, and recommendations. To decide which profiles to show you and in what order, and to show your profile to others, as described in Section 4.3 of our Terms of Service and Section 5 below. This may use your profile, questionnaire answers, preferences and filters (including sensitive attributes you choose to provide or filter by), location and distance, activity and engagement, verification and moderation status, and whether a member has purchased a visibility feature.

3.3 Safety, integrity, and moderation. To verify that photos match the person using the account; detect and prevent fraud, scams, spam, impersonation, catfishing, bots, duplicate or banned accounts, and underage use; review, scan, filter, hold, delay, restrict, or remove content and accounts; investigate reports; enforce the Agreement and our Community Guidelines; protect members and others; and respond to emergencies.

3.4 Age assurance. To confirm that members are 18 or older, including by checking the date of birth you declare, using age signals from your device or app store, and estimating age from selfies.

3.5 Communications. To send service, account, security, safety, transactional, and legal messages, and, subject to your choices, promotional messages, surveys, and offers by push notification, email, SMS, in-app message, or in the official Second Innings chat.

3.6 Advertising and marketing. To show ads in free experiences of the app, to promote the Services on other websites, apps, and platforms, and to measure the effectiveness of our ads and campaigns, subject to your choices described in Section 9.

3.7 Analytics, research, and improvement. To understand how the Services are used, test features, measure performance, diagnose and fix errors, develop new features, and improve our matching, safety, and AI Features.

3.8 Security. To protect the Services, our systems, and our members, including through access controls, logging, monitoring, rate limits, app integrity checks, and bot detection.

3.9 Legal and compliance. To comply with law, legal process, and requests from authorities; to report apparent child sexual exploitation and other unlawful activity where required or permitted by law; to keep records of consents, purchases, and safety decisions; to establish, exercise, or defend legal claims; and for tax, accounting, audit, and corporate purposes.

3.10 Business operations and transactions. To manage our business, and to evaluate or carry out a financing, merger, acquisition, sale, transfer, reorganization, wind-down, or similar transaction.

3.11 With your consent or at your direction. For any other purpose we describe to you when we collect the information, or with your consent.

4. LEGAL BASES FOR PROCESSING (EEA, UK, SWITZERLAND, AND SIMILAR LAWS)

Where the GDPR, the UK GDPR, the Swiss Federal Act on Data Protection, or a similar law applies, we rely on the following legal bases:

Where we rely on consent and you withdraw it, some features may no longer be available to you. Where we rely on legitimate interests, you may object as described in Section 14.

5. AUTOMATED DECISION-MAKING AND PROFILING

5.1 We use automated processing. The Services rely on automated systems, including rule-based systems, statistical models, machine learning, and AI models, to make or support decisions. These include:

• Matching, ranking, and recommendations. Automated systems select and order the profiles you see and decide when and where your profile is shown. Factors may include your preferences and filters; profile information and questionnaire answers; age and distance; activity, engagement, and how recently members were active; how other members respond to profiles; verification status; safety, trust, and moderation signals; randomization and testing; and paid visibility features, such as boosts, spotlight, or "I Am Ready," which cause a profile to be shown more often or ahead of others. Compatibility scores, match labels, and explanations are generated automatically and are described further in Section 10 of our Terms of Service.
• Moderation. Automated tools review profile text, photos, and messages and may approve, hold for human review, restrict, or remove them. New and edited profiles may be hidden from other members until reviewed, and the app tells you when your profile is under review. Messages to or from accounts under review may be held, delayed, or not delivered. Automated tools may also flag content for child-safety review and escalation.
• Verification and age assurance. Automated tools compare selfies to profile photos, check for liveness and spoofing, estimate age, check whether a photo appears elsewhere online or depicts a public figure, and identify possible duplicate accounts.
• Fraud and security. Automated tools assess bot risk, abuse, unusual activity, and whether a device, email address, or phone number is associated with a banned account.

5.2 Effects. These automated processes determine what you see and how visible you are within a social discovery service, and they may lead to restrictions while content or accounts are reviewed. They do not produce legal effects concerning you or similarly significant effects, such as decisions about financial or lending services, housing, insurance, education, employment, criminal justice, health care, or access to essential goods or services. Possible duplicate-account matches are reviewed by people and do not lead to automatic action against an account, and we may use human review before taking other actions, including suspensions and bans.

5.3 Human review and contesting a decision. If you believe an automated process has affected you incorrectly, for example that your profile, photo, message, or verification result was wrongly restricted, you can ask for human review, express your point of view, and contest the decision by contacting support@secondinnings.app, or privacy@secondinnings.app for privacy questions. You can also appeal moderation decisions as described in Section 6.6 of our Terms of Service. Where the law gives you a right to opt out of profiling or automated decision-making that produces legal or similarly significant effects, we do not engage in that kind of processing, but you may still contact us with any concern.

6. ARTIFICIAL INTELLIGENCE

6.1 AI Features. As described in Section 9 of our Terms of Service, the Services include AI Features, which may include the AI Companion, matching and compatibility insights, explanations of why a match was suggested, astrology insights, photo and liveness checks, age estimation, translation, fraud and spam detection, and content moderation. Some AI Features combine AI models with rule-based logic and templates. Our AI Features Disclosure and Crisis Safety Protocol provides more detail.

6.2 Information used. AI Features may process your Inputs and the resulting outputs, and, depending on the feature, your profile text, questionnaire answers, photos, selfies, activity, and other information described in Section 2. For example, profile text you write (which may include your name) may be reviewed by an AI model for moderation, and the messages you send to the AI Companion are sent to an AI model to generate a reply.

6.3 AI model providers. Some AI Features use AI models hosted by service providers, such as OpenRouter and OpenAI. These providers process data on our behalf under contracts that limit their use of the data to providing services to us, and they are not permitted to train their models on it. AI providers may retain data for limited periods under their own terms, for example for abuse monitoring or legal compliance. Other AI Features run on systems we operate or on your device.

6.4 AI Companion history. Your AI Companion chat history is stored only on your device, not on our servers. Your messages are transmitted through our servers to our AI model providers to generate a response and are not kept by us as a chat history. Our systems may keep limited technical and security logs as described in Section 11.4. You can clear the history on your device in the app, and signing out removes locally stored messages. We keep counts of AI Companion use (for example, for daily limits), and when the AI Companion displays crisis resources, we count that event without its content, for safety reporting.

6.5 No training of generalized models on private data; no sale. We do not sell Inputs. We do not use your private messages with other members, your Inputs, or your sensitive personal information to train generalized AI models that are made available to third parties. We may use aggregated or de-identified information, information about how features perform, and information about your activity to evaluate, maintain, personalize, and improve the Services, including our own matching and safety systems.

6.6 Crisis language. If you use language in the AI Companion that suggests a risk of harm, the AI Companion may stop its normal reply and show crisis resources. The AI Companion is not monitored in real time. See Section 8 of our Terms of Service and our AI Features Disclosure and Crisis Safety Protocol.

7. FACE ANALYSIS AND BIOMETRIC INFORMATION

7.1 With the consent you give when you check the box at signup, we and our service providers analyze your profile photos and selfies. This may include: detecting faces and facial features; creating face templates from profile photos and searching them against templates from other accounts to detect possible duplicate or banned accounts; checking whether a photo depicts a well-known public figure; comparing selfies with your profile photos; checking selfies and selfie videos for liveness and spoofing (including on your device); and estimating age from selfies.

7.2 We use these results for safety, fraud prevention, age assurance, and verification, including the "Photo verified" badge. A verification badge is not an identity check or a background check (see Section 6 of our Terms of Service).

7.3 Our Biometric Data Policy describes the biometric information we collect, our service providers, how long we keep it, and how we destroy it, including that face templates indexed from a profile photo are deleted when you delete that photo and when your account is erased. If you live in Illinois, Texas, Washington, or another place with biometric privacy laws, the Biometric Data Policy contains information required by those laws.

8. HOW WE DISCLOSE PERSONAL INFORMATION

We disclose personal information as described below. We require service providers to protect personal information and to use it only for the services they provide to us, except where this section says otherwise.

8.1 Other members and the public

Your profile is designed to be seen by other members. Depending on the feature and your settings, other members may see:

• your first name and the initial of your last name, your age (not your full date of birth), photos, gender, pronouns, city, state, and country, and your approximate distance (not your exact location);
• your profile sections, interests, and questionnaire answers that are shown on your profile or used in features such as Match Meter, which may display your answers next to theirs, and sensitive information that you choose to display (for example, religion, ethnicity, income, relationship status, or children);
• your verification badge, whether you are active today, whether you are featured or boosted, and whether you have liked them or sent a message request;
• astrology results that compare your birth data with theirs. If another member requests an astrology compatibility report with you, we may use your date of birth and, where you have not provided astrology birth details, your profile or approximate location, and may show that member derived results such as signs, doshas, and compatibility readings; and
• messages you send them.

Information you share with other members may be copied, screenshotted, or shared by them, and we cannot control or retrieve it. If you delete your account, members you have messaged may continue to see the messages you exchanged, attributed to "Deleted user." Blocking a member stops further interaction but does not remove what they already received.

8.2 Service providers and processors

We use service providers to operate the Services. They may receive the personal information needed for their function. The table names our principal providers by category; we may use others that perform similar functions, and providers may change over time.

8.3 Advertising and analytics partners

Advertising partners and some analytics partners may collect information directly through their SDKs, pixels, and cookies, and may combine it with information from other sources and use it for their own purposes, such as improving their services and personalizing ads, under their own terms and privacy policies. See Section 9 and our Cookie and Tracking Technologies Policy.

8.4 Partners at your direction

When you choose to use a third-party service with the Services, such as signing in with Apple, Google, or Facebook, buying through an app store, opening a link, or sharing content outside the Services, we disclose information to that third party as needed to carry out your request.

8.5 Legal, safety, and law enforcement

We may access, preserve, and disclose personal information, including messages and other content, if we believe in good faith that doing so is reasonably necessary to: comply with law, regulation, legal process, or a governmental request; respond to an emergency involving risk of death or serious physical injury; report apparent child sexual exploitation to the National Center for Missing and Exploited Children (NCMEC) or other authorities, including as required by law; protect the rights, property, or safety of Second Innings, our members, or others; detect, prevent, or address fraud, security, or technical issues; enforce the Agreement; or establish, exercise, or defend legal claims. See our Law Enforcement Guidelines.

8.6 Affiliates

We may disclose personal information to current or future parents, subsidiaries, and affiliates under common control, who will use it consistent with this Privacy Policy.

8.7 Business transfers

We may disclose and transfer personal information in connection with, or during negotiations of, any financing, merger, acquisition, reorganization, sale of all or part of our assets or of the Services, transfer of the Services to a new operator, joint venture, bankruptcy, insolvency, receivership, dissolution, or wind-down of our business. In such a case, personal information may be among the assets transferred, and the recipient may continue to use it as described in this Privacy Policy. Where required by law, we will provide notice or obtain consent.

8.8 With your consent

We may disclose personal information for other purposes with your consent or at your direction.

8.9 Aggregated and de-identified information

We may disclose aggregated or de-identified information that does not reasonably identify you for any lawful purpose. Where we maintain de-identified information, we will not attempt to re-identify it, except as permitted by law.

9. ADVERTISING, "SALE," "SHARING," TARGETED ADVERTISING, AND YOUR OPT-OUT CHOICES

9.1 Ads in the app. Free experiences of the app display ads. On iOS, ads are served by Google AdMob; on Android, ads are served by InMobi. These advertising partners may collect device identifiers (including your mobile advertising identifier, where available), IP address, device and app information, and information about your interactions with ads, and may use it to select, personalize, and measure ads. Paid plans may reduce or remove ads as described at the point of purchase.

9.2 Measurement and promotion. We send app events, such as installs, registrations, profile completion, subscriptions, and purchases (including product, price, currency, and order identifier), to Meta and Google to measure and improve our advertising. On our website, tags from Google, Meta, TikTok, AppsFlyer, and Vibe collect information about your visit and the pages and links you view, to measure our campaigns and show our ads to you on other services.

9.3 No sale for money; "sharing" and targeted advertising. We do not sell personal information in exchange for money. Some of the disclosures described in Sections 9.1 and 9.2 may be considered "sharing" for cross-context behavioral advertising under California law, "targeted advertising" under other US state laws, or a "sale" under the broad definitions of some state laws. The categories involved are identifiers (such as device and advertising identifiers and IP address), internet or other electronic network activity, and commercial information (such as purchase events), and advertising partners may associate general demographic information with them. We do not intentionally provide your sensitive personal information, your messages, or your questionnaire answers to advertising partners for targeted advertising. We do not knowingly sell or share the personal information of anyone under 18.

9.4 Do Not Sell or Share My Personal Information. You can opt out of the sale or sharing of your personal information and of targeted advertising:

• In the app: go to Settings > Your Privacy Choices > Do Not Sell or Share My Personal Information and turn it on. Your choice is saved to your account. When it is on, we request non-personalized ads and restricted data processing from Google AdMob, send an opt-out signal to InMobi, and enable Meta's Limited Data Use for app events.
• On our website: use a browser or extension that sends a Global Privacy Control signal (see Section 9.5), or adjust your choices in the cookie banner or Cookie Settings.
• By email: contact privacy@secondinnings.app with the subject "Do Not Sell or Share."

Opting out does not stop ads. You may still see ads that are not personalized, and we may still use information for purposes that are not sale, sharing, or targeted advertising, such as contextual ads, frequency capping, security, and aggregate measurement.

9.5 Global Privacy Control. We treat a Global Privacy Control (GPC) signal that we detect from your browser on our website as a valid request to opt out of the sale or sharing of personal information and of targeted advertising for that browser. Because GPC is sent by your browser, you should also use the in-app setting to opt out on your mobile devices. We do not respond to "Do Not Track" browser signals, because there is no common standard for them.

9.6 Consent in the EEA, UK, and Switzerland. Where required, the app asks for your consent to personalized advertising using Google's consent form before ads are requested, and passes your choice to our advertising partners. You can review your choice at Settings > Your Privacy Choices > Manage ad consent where that option is shown.

9.7 Device controls. On iOS, the app asks for permission to track through Apple's App Tracking Transparency prompt. You can change this at any time in your device settings. On Android, you can reset or delete your advertising ID in your device settings. Our Cookie and Tracking Technologies Policy describes more choices, including industry opt-out tools.

10. YOUR CHOICES AND CONTROLS

10.1 Profile and visibility. You can edit your profile, delete photos, change or delete optional answers, hide certain answers from your profile where the feature allows, change your preferences and filters, and pause your account ("Take a Break" or "Hide Profile") as described in Section 21.2 of our Terms of Service.

10.2 Location. You can allow or deny location access in your device settings. If you deny it, we use an approximate location based on your network (IP address) or a city you enter, and some features may be less accurate.

10.3 Camera and photos. You can control camera and photo library access in your device settings. Some features, such as verification, require camera access.

10.4 Message previews. In Settings > Notifications, you can choose whether push notifications for messages show the message text. By default, they show only the sender's name.

10.5 Communications and marketing. See Section 17.

10.6 Advertising and tracking. See Section 9.

10.7 Account deletion. You can delete your account in the app settings. See Section 11.2.

11. HOW LONG WE KEEP PERSONAL INFORMATION

11.1 General rule. We keep personal information for as long as your account is active or paused, and afterwards for as long as needed for the purposes described in this Privacy Policy, including to provide the Services, maintain safety and security, prevent banned users from returning, comply with legal, tax, and accounting obligations, resolve disputes, and enforce our agreements. When deciding how long to keep information, we consider its nature and sensitivity, the purposes for which we use it, legal requirements, and the risk of harm from unauthorized use. We may suspend, deactivate, or delete accounts that have been inactive for an extended period.

11.2 Account deletion and the 14-day grace period. When you request deletion, your account is hidden from other members right away and you are signed out. For 14 days, you can cancel the deletion by signing in again. After the grace period, we erase your account: we delete or anonymize the personal information in your account, delete your photos, selfies, and verification media from storage, delete face templates from our face analysis service, and instruct our matching and astrology systems to delete your data. Deletions in external systems are retried automatically until they succeed. Deleting your account does not cancel a subscription purchased through Apple or Google.

11.3 What we keep after deletion. We keep the following limited records:

11.4 Other retention periods.

• Messages held by moderation may be deleted if they are not approved.
• Data export files are available through a download link that expires after 7 days.
• Logs and analytics data are kept for limited periods that vary by system (for example, some activity logs are kept for about 30 days and some compatibility results for about 90 days); security, request, and audit logs may be kept longer.
• Backups and archives expire on their own schedules, so copies of deleted information may remain in backups or archives for a period until they are deleted in the ordinary course.
• Website pre-registration and enquiry records are kept until they are no longer needed for the purpose for which they were collected.
• Third-party SDKs and service providers keep data according to their own retention settings and terms.
• Biometric information is kept and destroyed as described in our Biometric Data Policy.

11.5 Exceptions. We may keep information longer where required or permitted by law, to comply with a legal hold, preservation request, or investigation, to resolve disputes, to enforce our agreements, or to protect the safety of members and others.

12. SECURITY

We use administrative, technical, and organizational measures designed to protect personal information, which may include encryption in transit, encryption of certain information at rest, certificate pinning in the app, encryption of message content and sensitive settings stored on your device, role-based access controls, mandatory multi-factor authentication for administrative access, logging, rate limiting, and app integrity checks. Authorized personnel with role-based access may view personal information, including messages, photos, selfies, and verification records, for safety, moderation, support, security, and legal reasons. No method of transmission or storage is completely secure, and we cannot guarantee the security of your information. You are responsible for keeping your devices, one-time codes, and accounts secure. If we learn of a security incident affecting your personal information, we will notify you and authorities where required by law.

13. INTERNATIONAL TRANSFERS

The Services are operated from the United States. We and our service providers store and process personal information in the United States and other countries, which may include India and other countries where our service providers operate. These countries may have data protection laws that differ from, and may be less protective than, the laws where you live. When we transfer personal information from the EEA, the UK, Switzerland, or another place that restricts transfers, we use safeguards permitted by law, such as the European Commission's Standard Contractual Clauses (with the UK Addendum or Swiss amendments where applicable), adequacy decisions, or other lawful transfer mechanisms. You can request more information about these safeguards by contacting privacy@secondinnings.app.

14. YOUR PRIVACY RIGHTS BY REGION

Your rights depend on where you live and are subject to exceptions and limits under applicable law. Section 15 explains how to exercise them.

14.1 United States: state privacy laws

If you live in a US state with a comprehensive consumer privacy law (such as California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia), you may have the right to:

• Know and access the personal information we have about you, and in some states the categories or specific third parties to which we disclosed it;
• Correct inaccurate personal information;
• Delete personal information;
• Portability, to receive a copy of personal information in a portable format;
• Opt out of the sale of personal information, targeted advertising, and profiling in furtherance of decisions that produce legal or similarly significant effects (see Sections 5 and 9);
• Consent and limit regarding sensitive personal information, including to withdraw consent you have given;
• Appeal our decision on your request (see Section 15.5); and
• Not be discriminated against for exercising these rights.

14.2 California

This section supplements this Privacy Policy for California residents under the California Consumer Privacy Act, as amended by the California Privacy Rights Act, and its regulations (the "CCPA").

(a) Notice at Collection. The table below describes the categories of personal information we collect, and have collected in the preceding 12 months, the sources, our business or commercial purposes, the categories of recipients to which we disclose it for a business purpose, and whether we sell or share it. Retention is described in Section 11.

We do not collect non-public education information as defined by the CCPA. We may also disclose any category to recipients described in Sections 8.5 (legal and safety) and 8.7 (business transfers).

(b) Sensitive personal information and the right to limit. We use and disclose sensitive personal information to provide the Services you request (including matching and features you choose to use), to ensure security and integrity, to prevent fraud and illegal activity, to ensure physical safety, for short-term transient use, to perform services on our behalf, to verify and maintain the quality and safety of the Services, and for other purposes permitted by Section 7027(m) of the CCPA regulations. We do not use or disclose sensitive personal information to infer characteristics about you for purposes other than those permitted. Because we limit our use in this way, the CCPA right to limit the use of sensitive personal information does not apply to our processing. You can still control your sensitive information by not providing it, hiding or deleting optional answers, denying location or camera access, deleting photos, or contacting privacy@secondinnings.app to ask us to limit its use, and we will act on your request to the extent required by law.

(c) Automated decision-making technology. We do not use automated decision-making technology to make significant decisions about you, as defined in the CCPA regulations (decisions that result in the provision or denial of financial or lending services, housing, education, employment, or health care services). Section 5 describes the automated processing we do use. You may ask us about it at privacy@secondinnings.app.

(d) Your CCPA rights. You have the rights to know, access, correct, delete, and opt out of the sale or sharing of personal information, the right to limit described above, and the right not to receive discriminatory treatment for exercising your rights. We do not offer financial incentives in exchange for your personal information. If we do in the future, we will provide any required notice.

(e) Minors. We do not knowingly sell or share the personal information of consumers under 16, and the Services are only for people 18 and older.

(f) Disclosure for direct marketing. California residents may request information under California Civil Code Section 1798.83 by contacting privacy@secondinnings.app.

14.3 Consumer health data: Washington, Nevada, and Connecticut

If you live in Washington, Nevada, or Connecticut, or your consumer health data is collected in Washington, our Consumer Health Data Privacy Policy describes the consumer health data we collect, how we use and share it, and your rights, including to access and delete it and to withdraw consent.

14.4 Nevada

Nevada residents may submit a request to opt out of the sale of covered information under Nevada Revised Statutes Chapter 603A by contacting privacy@secondinnings.app, although we do not sell covered information as defined in that law.

14.5 European Economic Area, United Kingdom, and Switzerland

If the GDPR, the UK GDPR, or Swiss data protection law applies to you, you have the right to: access your personal data and receive a copy; correct inaccurate data; erase your data; restrict processing; object to processing based on legitimate interests, including profiling, and to object at any time to direct marketing; data portability; withdraw consent at any time, without affecting the lawfulness of processing before withdrawal; and not be subject to a decision based solely on automated processing that produces legal or similarly significant effects (see Section 5). You also have the right to lodge a complaint with your local data protection supervisory authority, or in the UK, the Information Commissioner's Office. We would appreciate the chance to address your concerns first at privacy@secondinnings.app.

14.6 India

If you are in India, the Digital Personal Data Protection Act, 2023 and its rules, to the extent in force, give you the right to: obtain a summary of the personal data we process and the processing activities; obtain the identities of other Data Fiduciaries and Data Processors with whom your data has been shared, and a description of the data shared; correct, complete, update, and erase your personal data; withdraw consent at any time, as easily as you gave it; have a readily available means of grievance redressal; and nominate another individual to exercise your rights in the event of your death or incapacity. Grievance Officer: Amit Pandya, privacy@secondinnings.app, Second Innings, Inc., 9206 Sunshine Pl, Downey, CA 90240, USA. We will acknowledge and respond to grievances within the time required by law. If you are not satisfied with our response, you may complain to the Data Protection Board of India. You agree not to submit false or frivolous grievances.

14.7 Canada

If you are in Canada, you may have the right under the Personal Information Protection and Electronic Documents Act and applicable provincial laws, including Quebec's Act respecting the protection of personal information in the private sector, to access and correct your personal information, withdraw consent (subject to legal or contractual restrictions), request deletion or de-indexing where applicable, receive information about automated decisions, and receive computerized personal information in a technological format. You can contact the person in charge of privacy at privacy@secondinnings.app, and you may complain to the Office of the Privacy Commissioner of Canada or your provincial privacy regulator.

14.8 Australia

If you are in Australia, you may request access to and correction of your personal information under the Privacy Act 1988 (Cth) and the Australian Privacy Principles. Your personal information is likely to be disclosed to recipients in the United States, India, and other countries where our service providers operate. You may complain to us at privacy@secondinnings.app, and if you are not satisfied with our response, to the Office of the Australian Information Commissioner.

14.9 Brazil

If you are in Brazil, the Lei Geral de Proteção de Dados (LGPD) gives you the right to: confirmation of processing; access; correction of incomplete, inaccurate, or outdated data; anonymization, blocking, or deletion of unnecessary or excessive data or data processed unlawfully; portability; deletion of data processed with consent; information about the entities with which we share data; information about the possibility of not giving consent and its consequences; revocation of consent; and review of decisions made solely on the basis of automated processing. You can contact our data protection contact at privacy@secondinnings.app, and you may file a complaint with the Autoridade Nacional de Proteção de Dados (ANPD).

14.10 Other locations

If you live elsewhere, you may have similar rights under local law. Contact privacy@secondinnings.app and we will respond as required by the law that applies to you.

15. HOW TO EXERCISE YOUR RIGHTS

15.1 Tools in the app. You can:

• view and edit most of your information in your profile and settings;
• request a copy of your data at Settings > Your Privacy Choices > Download my data. We prepare a file in a commonly used, machine-readable format (JSON) containing your account and profile information, answers, photos (as download links), astrology profile, messages you sent, your activity, reports and blocks you filed, purchases, consent records, device information, and location records, and send a link to the email address on your account, or an in-app message if your account has no email address. The link expires after 7 days, and you can make one request every 24 hours. The export does not include other members' messages or content, and it may exclude information we are not required to provide, such as security and fraud signals;
• opt out of sale, sharing, and targeted advertising (Section 9.4), manage ad consent (Section 9.6), and manage notifications (Section 17); and
• delete your account (Section 11.2).

15.2 By email. Send requests to privacy@secondinnings.app. Please tell us what right you want to exercise, and include the email address or phone number associated with your account. You can also write to Second Innings, Inc., Attn: Privacy, 9206 Sunshine Pl, Downey, CA 90240, USA.

15.3 Verification. To protect you, we will verify your identity before acting on a request, for example by asking you to make the request from the app while signed in, or by confirming control of the email address or phone number on your account. For some requests, such as requests for specific pieces of information or for sensitive information, we may ask for additional information. We will use information provided for verification only for that purpose. If we cannot verify your identity, we may deny or limit the request. You do not need to verify your identity to opt out of sale, sharing, or targeted advertising, but we may deny an opt-out request that we believe is fraudulent.

15.4 Authorized agents. Where the law allows, you may use an authorized agent to submit a request. The agent must provide signed written permission from you, or a valid power of attorney, and we may ask you to verify your identity directly with us and confirm that you gave the agent permission.

15.5 Appeals. If we decline to take action on your request, you may appeal by replying to our response or by emailing privacy@secondinnings.app with the subject line "Privacy Request Appeal" within a reasonable period after our decision. We will respond within the time required by law. If you are not satisfied with the outcome of your appeal, you may contact your state attorney general or other regulator.

15.6 Timing and fees. We respond within the time required by applicable law and may extend that time where the law allows. We do not charge a fee unless a request is manifestly unfounded, excessive, or repetitive, where the law permits a fee.

15.7 Limits. Some rights are subject to exceptions. For example, we may keep information we need to complete a transaction, prevent fraud and abuse, comply with law, or establish or defend legal claims, as described in Section 11, and we may decline requests that would reveal other people's personal information or compromise safety or security.

15.8 No discrimination. We will not discriminate against you for exercising your privacy rights. Some features may not work without certain information, for example matching without a location or verification without a selfie.

16. CHILDREN AND AGE ASSURANCE

16.1 18 and older only. The Services are only for adults 18 and older. We do not knowingly collect personal information from anyone under 18. We do not accept a declared date of birth under 18, and we may use age signals from your device or app store and automated age estimation from selfies, as described in Section 2.3 of our Terms of Service.

16.2 If we learn a member is under 18. If we believe an account belongs to someone under 18, we may restrict, suspend, or terminate it and delete its information, except that we may keep the minimum information needed to prevent re-registration and to comply with law. If you believe a minor is using the Services, contact support@secondinnings.app or report the profile in the app.

16.3 Child safety. We do not tolerate child sexual abuse or exploitation. See our Child Safety Standards.

17. COMMUNICATIONS AND MARKETING CHOICES

17.1 Service messages. We send service, account, security, safety, transactional, and legal messages, such as one-time codes, purchase confirmations, and notices about your account. You cannot opt out of these while you have an account, except by turning off push notifications on your device.

17.2 Push notifications. You can turn push notifications on or off in your device settings, and turn off marketing and certain other notification types at Settings > Notifications. Message notifications show only the sender's name unless you turn on message previews.

17.3 Marketing. We may send promotional messages by push notification, email, in-app message, and in the official Second Innings chat. You can turn marketing off at any time in Settings in the app. When marketing is off, we stop sending promotional messages on those channels.

17.4 Email. Our marketing emails include an unsubscribe link. You can also manage email categories on the email preferences page linked from our emails.

17.5 SMS and WhatsApp. If you provide a mobile number, we send one-time codes and service messages by SMS or WhatsApp. We send marketing text messages only with your consent where required by law. Consent to marketing is not a condition of purchase. Reply STOP to opt out of marketing texts, or HELP for help. Message and data rates may apply, and message frequency varies.

17.6 Effect of opting out. Opting out of marketing does not stop service messages. It may take a short time for your choice to take effect in all systems.

18. LAW ENFORCEMENT AND LEGAL REQUESTS

Law enforcement and government agencies should follow our Law Enforcement Guidelines at secondinnings.app/law-enforcement and send requests to legal@secondinnings.app. We review each request and respond as required by law, as described in Section 8.5.

19. THIRD-PARTY SERVICES AND LINKS

The Services may contain links to, or integrations with, third-party websites, apps, and services, including ads. We are not responsible for their privacy practices. Please review their privacy policies before providing personal information to them.

20. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. We will post the updated version in the Services and update the "Last Updated" date. If we make material changes, we will notify you in advance through the Services or by email, push notification, or in-app notice where required by law or where we consider it appropriate, and, where required by law, we will ask for your consent, including by asking you to accept the updated version in the app. Changes take effect on the date stated in the notice or, if none, when posted.

21. CONTACT US

• Privacy questions and requests, and India Grievance Officer (Amit Pandya): privacy@secondinnings.app
• General support: support@secondinnings.app
• Legal notices, security reports, and law enforcement: legal@secondinnings.app

Second Innings, Inc., Attn: Privacy, 9206 Sunshine Pl, Downey, CA 90240, USA

If you need this Privacy Policy in an alternative format, contact support@secondinnings.app.