TaraDate privacy policy

DRAFT. Every item marked FILL IN must be replaced with an accurate fact before this policy takes effect.

Effective date: FILL IN: date. Last updated: FILL IN: date.

Summary

• TaraDate is a courtship service for adults 18 and older. We collect what you put in your profile, your messages, and the records we need to verify members and meet the legal requirements for international introductions.
• Other members see your profile. Your identity documents, screening results, and background answers stay private, except where U.S. law requires us to give a man's screening records to a woman before they can talk.
• Our systems and staff review messages and photos for safety. Some of that review and our translation feature use AI services that act on our behalf.
• We may use analytics and advertising tools to understand use of the site and measure and improve our advertising.
• You can see, download, correct, and delete your information. Members in the Philippines and in U.S. states with privacy laws have the rights described in their own sections below.
• Contact us at FILL IN: privacy@taradate.com. Our Data Protection Officer is at FILL IN: dpo@taradate.com.

1. Who we are

FILL IN: Company legal name ("TaraDate", "we") operates taradate.com. We are organized in FILL IN: state/country and located at FILL IN: postal address. We decide how and why your personal information is used, which makes us the controller of it under U.S. state law and the personal information controller under the Philippine Data Privacy Act of 2012.

This policy covers the TaraDate website and the services we provide through it.

2. Information we collect

Information you give us

Information for verification and legal compliance

Every member verifies their identity before contacting other members.

Payment information

Men pay a monthly membership fee. FILL IN: Payment processor collects your card details directly. We receive your billing name, the last four digits of your card, its expiry date, billing country, and your payment history. We do not receive or store full card numbers.

Information collected automatically

• IP address and country. We record your IP address when you sign in, sign out, or fail to sign in. We look up the country for an IP address in a database stored on our own servers, and we use it to show the right home page and to detect account misuse. No outside service receives your IP address for this lookup.
• Cookies. We use a session cookie to keep you signed in and a cookie that remembers which home page you chose. Both are necessary for the site to work.
• Website and advertising data. Analytics and advertising tools may use cookies and similar technology to collect information about your browser, device, pages visited, and actions on our site. We may use and share this information to understand site use and measure and improve advertising.
• Activity on TaraDate. Profiles you view, members you contact, and your responses to introductions, which we use to suggest matches.

Information from others

• Google, if you sign in with Google: your Google account identifier and email address.
• Our identity verification provider: the result of your verification and the data listed above.
• Our screening provider: registry and background search results about men.
• Other members: reports about you and messages they send you.

3. How we use your information

We use background questionnaire answers, screening results, and IMBRA consent records only to make the disclosures IMBRA requires, to decide whether a man meets our membership standard, and to answer lawful requests from courts and law enforcement. We do not use them for matching or marketing.

4. AI and automated processing

We use AI services in four places. FILL IN: AI provider(s) process this information for us under contract.

Matching uses your profile, preferences, and activity to order the members we show you. It affects whom you see, not whether you can be a member.

We do not use your profile, interview, or messages to train AI models, and our AI providers' contracts FILL IN: prohibit them from training on it / limit their retention to N days. We will tell you when you are interacting with an AI. You can ask a person to review any decision about your account by writing to us.

5. Identity verification and biometric information

FILL IN: Verification provider performs identity checks for us. You photograph your ID and take a selfie or short video, and we send them to FILL IN: Verification provider. It measures the geometry of your face in both images and compares them to confirm that you are the ID holder and a live person. Several U.S. state laws define that face geometry as biometric information.

• Before verification begins, we show you what we collect, why, and how long we keep it, and we ask for your signed consent, including consent to send your images to FILL IN: Verification provider.
• The face geometry is used only to verify your identity for TaraDate.
• We and our provider never sell, lease, rent, trade, or otherwise profit from biometric information. We disclose it only to FILL IN: Verification provider to perform the verification, or when required by law, a warrant, or a subpoena.
• Retention schedule: we and FILL IN: Verification provider permanently destroy face geometry within 30 days after verification is complete or abandoned, and in every case within 3 years after your last interaction with TaraDate.
• We protect biometric information at least as carefully as our other confidential information. If a security incident compromises it, we follow our incident response plan: we contain the incident, assess which members are affected, and notify them and the authorities the law requires.
• The ID image and selfie are photographs, kept for the periods in section 9. We keep them only as identity and age records, and we never measure or compare faces in them again after verification.
• If you prefer, you can ask for a staff member to review your ID and selfie instead of the automated face comparison. Staff review measures no face geometry.

6. Background screening and IMBRA disclosures

TaraDate is an international marriage broker under U.S. law. Before a man can message a woman, IMBRA requires us to:

1. Search the U.S. National Sex Offender Public Website for him.
2. Collect his signed answers to the background questionnaire in section 2.
3. Give the woman the search results, his questionnaire answers, and a U.S. government pamphlet on her legal rights, in her primary language.
4. Obtain her signed consent to share her contact information with him.

For men: your questionnaire answers and search results go to each woman you ask to contact, translated into her language. We remove the names and locations of any victims named in those records, as the law requires. We also run a criminal background check through FILL IN: screening provider, a consumer reporting agency, to meet our membership standard. We run it only after you sign a separate authorization. If we deny membership based on the report, we will tell you in writing and give you the agency's name, address, and toll-free number. We will also tell you that the agency did not make the decision, that you can get a free copy of the report from the agency within 60 days, and that you can dispute its accuracy with the agency.

For women: we keep a copy of the government ID you used to prove your age for seven years, as IMBRA requires. Your consent to each man is recorded with the date and time, the documents you received, and your signature. You can download your consent records, which you may need for a U.S. fiancee visa petition.

7. How we share information

• Other members. Members who can view your profile see your profile information and photos. A member you message sees your messages. Section 6 describes the IMBRA disclosures made to a woman.
• Service providers. These companies process information for us under contracts that limit their use of it to our instructions:
  • hosting and file storage: FILL IN: Oracle Cloud Infrastructure, region;
  • identity verification: FILL IN: Veriff;
  • sex offender and background screening: FILL IN: provider;
  • AI processing: FILL IN: provider(s);
  • payments: FILL IN: processor;
  • email delivery: FILL IN: provider;
  • translation of legal documents: FILL IN: provider.
• Google, to let you sign in with your Google account.
• Analytics and advertising partners. We may share the website and advertising data described in section 2 with providers that help us measure and improve our advertising.
• Legal and safety. We disclose information when we believe in good faith that it is required by law or legal process, or needed to protect someone from death or serious harm, to investigate fraud or requests for money, or to establish or defend legal claims. We share IMBRA records with law enforcement or courts only when legally required.
• Business transfer. If TaraDate is merged, acquired, or sells its assets, your information may transfer to the new owner, who must honor this policy. We will notify you before that happens.

Some advertising disclosures may count as a "sale" or "sharing" under U.S. state privacy laws, even when no money changes hands. FILL IN: applicable classification and prior-12-month history before publication.

8. Where your information is stored

We store your information in FILL IN: the United States. If you live in the Philippines, your information is transferred to the United States and to the service providers listed in section 7. Our contracts with those providers require them to protect it at a level comparable to the Philippine Data Privacy Act, and we remain responsible for it under section 21 of that Act. FILL IN: If staff are located in the Philippines: our staff in the Philippines can access member information to provide support and review reports.

9. How long we keep information

10. Your choices and rights

Every member can:

• see and edit their profile, photos, and preferences in their account;
• hide their profile from other members;
• block or hide another member;
• download a copy of their information;
• delete their account in settings;
• stop marketing emails through the link in any marketing email;
• ask us about any of this at FILL IN: privacy@taradate.com.

We will ask you to confirm requests from your signed-in account or your account email. If another member's information is involved, such as messages they sent you, they must make that request themselves.

Members in the Philippines

Under the Data Privacy Act of 2012 (Republic Act 10173), you have the right to:

1. be informed whether and how your personal information is processed;
2. object to processing, including processing for marketing, automated processing, and profiling;
3. access your personal information and learn its sources, recipients, the reasons for disclosure, and the automated processes used;
4. correct inaccurate or incomplete information;
5. have your information suspended, withdrawn, blocked, removed, or destroyed;
6. receive a copy of your information in a common electronic format;
7. withdraw your consent at any time, which does not affect processing done before you withdrew it;
8. be compensated for damages from inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorized use of your information;
9. file a complaint with the National Privacy Commission.

Withdrawing consent works the same way as giving it, in your account settings. If you withdraw consent to identity verification, you can no longer contact other members. If you withdraw consent to showing a sensitive profile detail, we remove it from your profile. Withdrawing consent for one purpose leaves your other choices unchanged.

Write to our Data Protection Officer at FILL IN: dpo@taradate.com or FILL IN: postal address. We answer within 30 working days, free of charge.

If you believe your information has been misused or your rights violated, you may file a complaint with the National Privacy Commission, 25th-27th Floors, The Upper Class Tower, Quezon Avenue corner Scout Reyes Street, Quezon City 1103; complaints@privacy.gov.ph; https://privacy.gov.ph.

Members in U.S. states with privacy laws

If you live in California, Colorado, Connecticut, Delaware, Minnesota, New Jersey, Oregon, Texas, Virginia, or another state with a consumer privacy law, you have the right to:

• know what personal information we collect, use, and disclose, and get a copy of it;
• correct inaccurate personal information;
• delete personal information;
• opt out of sale, sharing for targeted advertising, and profiling that produces legal or similarly significant effects;
• withdraw consent to our use of sensitive information;
• be free from discrimination for using these rights.

Sensitive information. Religion, ethnicity, sexual orientation implied by your preferences, government ID numbers, precise identity verification data, biometric information, and criminal history are sensitive under these laws. We collect sensitive information only with your consent or where the law requires it, and we use it only for the purposes in this policy. We do not use it to infer characteristics about you.

Making a request. Email FILL IN: privacy@taradate.com from your account email or use FILL IN: Settings > Privacy. We verify requests by matching them to your account. An authorized agent may make a request for you with your signed permission, and we may ask you to confirm your identity with us directly. We respond within 45 days, and we will tell you if we need up to 45 more.

Appeals. If we deny your request, reply to our decision to appeal. We will answer within 45 days (60 days in Colorado, Connecticut, and Texas) and explain our reasons. If we deny your appeal, you can complain to your state attorney general.

California categories. In the past 12 months we collected identifiers, personal records described in Cal. Civ. Code 1798.80(e), characteristics of protected classifications, commercial information, internet activity, geolocation at the country level, audio and visual information, biometric information, inferences about your preferences for matching, and sensitive personal information. Section 2 lists the specific items, section 7 lists who receives them, and section 9 lists how long we keep each one. We disclosed these categories only to the recipients in section 7, for the purposes in section 3.

11. Age requirement

TaraDate is for adults 18 and older. We verify every member's age with a government ID. If we learn that someone under 18 has created an account, we close it and delete their information, except the minimum we need to keep them from rejoining.

12. Security

We encrypt connections to TaraDate, store passwords only as secure hashes, limit staff access to the people who need it, and restrict each member's files to that member's account.

Staff members can sign in as a member to investigate a support request or a report. Each time they do, we record which staff member did it and when.

If a security breach puts your information at risk, we will notify you and the authorities the law requires, including the National Privacy Commission within 72 hours for members in the Philippines.

13. Changes to this policy

We will email you at least 30 days before a material change takes effect and show the change in your account. Where the change affects something you consented to, we will ask for your consent again. We review this policy at least once a year and list each version below.

14. Contact us

• Privacy questions and requests: FILL IN: privacy@taradate.com
• Data Protection Officer: FILL IN: name, FILL IN: dpo@taradate.com
• Mail: FILL IN: Company legal name, FILL IN: postal address