Privacy Policy

Effective Date: July 12, 2025

Introduction

Keldam Digital Ltd ("Company," "we," "us," "our") operates a membership-based online community platform (the "Platform" or "Service") that serves as a venue for consenting adults to connect and form mutually beneficial relationships. We understand that privacy is paramount to our members, and we are committed to protecting your personal information.

This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our Platform, including our website and mobile applications. By using our Service, you consent to the data practices described in this Privacy Policy.

1. Information We Collect

1.1 Information You Provide Directly

Account Registration:

  • Full legal name
  • Email address
  • Phone number
  • Date of birth
  • Gender and preferences
  • Location (city, state, country)
  • Government-issued identification (for verification)
  • Photographs and videos
  • Biography and personal descriptions
  • Relationship preferences and interests

Profile Information:

  • Education and occupation
  • Lifestyle preferences
  • Income range (optional)
  • Net worth range (optional)
  • Personal interests and hobbies
  • Social media handles (optional)

Verification Information:

  • Government-issued photo ID
  • Selfie photographs for identity verification
  • Additional documentation as required for manual verification

Communications:

  • Messages between members
  • Support tickets and correspondence
  • Feedback and survey responses

Payment Information:

  • We use third-party payment processors (Stripe, PayPal, etc.)
  • We do not store complete credit card numbers
  • We retain transaction history and billing information

1.2 Information Collected Automatically

Device and Usage Information:

  • IP address
  • Device type and identifiers
  • Operating system and version
  • Browser type and version
  • Mobile carrier
  • Time zone settings
  • Language preferences

Activity Information:

  • Pages viewed and features used
  • Click data and interactions
  • Search queries
  • Time spent on Platform
  • Login frequency and patterns
  • Profile views and matches

Location Information:

  • Approximate location from IP address
  • GPS data (with your permission)
  • Location preferences and settings

1.3 Information from Third Parties

Analytics Services:

We use analytics providers including:

  • Segment (data routing platform)
  • Google Analytics (usage analytics)
  • Amplitude (product analytics)
  • Customer.io (communication analytics)

Social Media:

  • Information from linked social accounts (with your permission)
  • Public profile information

Identity Verification Services:

  • Results from third-party verification providers
  • Background check information (where applicable)

1.4 Cookies and Tracking Technologies

We use cookies, pixels, and similar technologies to:

  • Maintain your session
  • Remember your preferences
  • Analyze Platform usage
  • Prevent fraud
  • Deliver targeted content

Types of Cookies:

  • Essential Cookies: Required for Platform functionality
  • Analytics Cookies: Help us understand usage patterns
  • Preference Cookies: Remember your settings
  • Marketing Cookies: Deliver relevant content

2. How We Use Your Information

2.1 Platform Operations

  • Create and manage your account
  • Facilitate member matching and introductions
  • Display your profile to other members
  • Enable communication features
  • Process payments and subscriptions

2.2 Safety and Security

  • Verify member identities
  • Detect and prevent fraud
  • Investigate violations of our Terms
  • Protect member safety
  • Enforce Platform rules

2.3 Improvements and Analytics

  • Analyze usage patterns
  • Develop new features
  • Optimize matching algorithms
  • Conduct research and testing
  • Generate aggregated insights

2.4 Communications

  • Service-related notifications
  • Security alerts
  • Marketing communications (with consent)
  • Member success stories (anonymized)
  • Platform updates and features

2.5 Legal Compliance

  • Comply with legal obligations
  • Respond to legal requests
  • Protect our legal rights
  • Prevent illegal activities

3. How We Share Your Information

3.1 With Other Members

  • Profile information visible to matched members
  • Messages sent to other members
  • Location (if you enable this feature)
  • Verification status

3.2 With Service Providers

We share information with vendors who help us operate:

  • Cloud hosting providers
  • Payment processors
  • Analytics services (Segment, Google Analytics, Amplitude, Customer.io)
  • Identity verification services
  • Email and SMS providers
  • Customer support tools
  • Security and fraud prevention services

3.3 For Legal Reasons

We may disclose information when required:

  • To comply with legal obligations
  • To respond to subpoenas or court orders
  • To cooperate with law enforcement
  • To protect rights and safety
  • To prevent fraud or illegal activities

3.4 Business Transfers

  • In connection with mergers or acquisitions
  • During business negotiations
  • In bankruptcy proceedings

3.5 Aggregated Information

  • We share anonymized, aggregated data
  • This data cannot identify individuals
  • Used for industry research and marketing

3.6 With Your Consent

  • When you explicitly authorize sharing
  • For features requiring third-party integration

4. Your Privacy Rights

4.1 Access and Portability

You have the right to:

  • Access your personal information
  • Receive a copy of your data
  • Understand how we use your information

4.2 Correction and Deletion

You can:

  • Update inaccurate information
  • Request deletion of your account
  • Remove specific content

4.3 Communication Preferences

You may:

  • Opt out of marketing emails
  • Manage push notifications
  • Control SMS preferences

4.4 Regional Rights

California Residents (CCPA):

  • Right to know categories of data collected
  • Right to deletion
  • Right to opt-out of "sale" (we do not sell data)
  • Right to non-discrimination

EU/EEA/UK Residents (GDPR):

  • Right to rectification
  • Right to restriction of processing
  • Right to object to processing
  • Right to lodge complaints with supervisory authorities

Other US States:

Similar rights under state privacy laws including:

  • Colorado (CPA)
  • Connecticut (CTDPA)
  • Virginia (VCDPA)
  • Additional states as applicable

5. Data Security

5.1 Security Measures

We implement:

  • SSL/TLS encryption
  • Secure data centers
  • Access controls
  • Regular security audits
  • Incident response procedures
  • Employee training

5.2 Your Responsibilities

  • Maintain strong passwords
  • Keep login credentials confidential
  • Use secure networks
  • Report security concerns promptly

5.3 Breach Notification

  • We will notify affected users of breaches
  • Notifications sent within legally required timeframes
  • Information on steps to protect yourself

6. Data Retention

6.1 Active Accounts

  • Data retained while account is active
  • Regular purging of unnecessary data
  • Logs retained for security purposes

6.2 Deleted Accounts

  • 30-day recovery period
  • Safety-related data retained for 6 months
  • Legal compliance data as required
  • Complete deletion after retention periods

6.3 Communications

  • Messages retained while accounts active
  • Deleted with account deletion
  • May be retained if legally required

7. International Data Transfers

7.1 Data Location

  • Primary servers in United States
  • Global CDN for performance
  • Backups in multiple regions

7.2 Transfer Safeguards

  • Standard Contractual Clauses
  • Appropriate technical measures
  • Compliance with local laws

8. Children's Privacy

  • Platform strictly for 18+ users
  • We do not knowingly collect data from minors
  • Immediate deletion upon discovery
  • Report minors to: support@mutualmeets.com

9. Third-Party Links

  • We are not responsible for third-party privacy practices
  • Review privacy policies of linked sites
  • Exercise caution with external services

10. Analytics Services Details

10.1 Segment

  • Data routing and integration platform
  • Collects usage and behavioral data
  • Routes data to other analytics tools

10.2 Google Analytics

10.3 Amplitude

  • Product analytics and user behavior
  • Feature adoption tracking
  • User journey analysis

10.4 Customer.io

  • Communication analytics
  • Email and push notification tracking
  • User engagement metrics

11. Your Choices

11.1 Account Settings

  • Update profile information
  • Manage privacy settings
  • Control visibility options

11.2 Communication Controls

  • Email preferences in account settings
  • Push notifications in device settings
  • SMS opt-out via STOP command

11.3 Cookie Management

  • Browser settings for cookie control
  • Third-party opt-out tools
  • Mobile ad ID controls

11.4 Do Not Track

  • We do not respond to DNT signals
  • Use privacy settings for control

12. Changes to Privacy Policy

  • Updates posted with effective date
  • Material changes notified via email
  • Continued use constitutes acceptance
  • Review regularly for updates

13. Contact Information

13.1 General Inquiries

Keldam Digital Ltd

Nikis 1
Anthoupoli
2350 Nicosia CY

Email: privacy@mutualmeets.com

13.2 Data Protection Officer

Email: dpo@mutualmeets.com

13.3 Privacy Rights Requests

Email: privacy-rights@mutualmeets.com
Include "Privacy Rights Request" in subject

14. Legal Bases for Processing (GDPR)

We process your data based on:

  • Contract: To provide our Services
  • Legitimate Interests: Platform security and improvements
  • Legal Obligations: Compliance requirements
  • Consent: Marketing and optional features

15. Automated Decision Making

  • We use algorithms for member matching
  • No solely automated decisions with legal effects
  • You can request human review of decisions

16. Privacy Policy Acceptance

By using our Platform, you acknowledge that you have read and understood this Privacy Policy and agree to its terms. If you do not agree, please do not use our Service.

Last Updated: July 12, 2025