Privacy Policy

How We Collect Personal Data

We collect Personal Data from two primary sources:

• Directly from You
  • When you create an account, build your profile, or set preferences
  • When you upload content (including files, screenshots, and images)
  • When you interact with our Services through surveys, free-form text fields, or other inputs
  • Through automatic collection when you use our Services, including via Cookies (see "Tracking Tools, Advertising and Opt-Out" section)
  • When you contact us directly
• From Third Parties
  • Platform Providers: Apple, Google, and similar platforms when delivering Services or processing support and payment requests
  • Other Users: When they share information about you through the Services
  • Service Providers: Analytics and customer support vendors that help us understand and improve your experience
  • Law Enforcement: When investigating suspected illegal activity or complaints

Why We Collect Personal Data

• Service Delivery and Enhancement
  • Managing your account and processing transactions (except direct purchases through Apple or Google)
  • Customizing the Services based on your profile and preferences (including to offer tailored advice to improve your social and dating conversations)
  • Meeting or fulfilling the reason you provided the information to us
  • Providing support and assistance for the Services
  • Improving the Services, including through research, testing, analytics, and AI model training
  • Personalizing communications based on your preferences
  • Ensuring security, fraud prevention, and debugging
  • Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws.
• Communicating and Marketing.
  • Marketing our Services, including through email campaigns and social media
  • Responding to your inquiries and sending requested information
  • Sending communications according to your preferences
• Legal and Safety Compliance
  • Conducting safety reviews per our risk and moderation policies
  • Meeting obligations under third-party agreements (including with Third-Party AI and LLM providers)
  • Complying with laws, law enforcement, regulations, and legal processes
  • Protecting rights, property, and safety of all parties
  • Enforcing agreements and resolving disputes
  • Addressing third-party rights violation

How We Share Your Personal Data

We disclose your Personal Data to the service providers and third parties listed below. Some of these disclosures may constitute a "sale" under certain state laws. See state-specific sections for details.

• Service Providers. These parties help us provide the Services or perform business functions on our behalf. They include:
  • Third-party AI and LLM providers
  • Hosting, technology and communication providers.
  • Security and fraud prevention consultants.
  • Support and customer service vendors.
• Advertising and Analytics Partners. These parties provide analytics on web traffic and help us measure, place, and optimize advertisements. They include:
  • Companies that track how users found or were referred to the Services
  • Companies that deliver targeted advertisements on our behalf, such as Google Ads and Meta (Facebook/Instagram Ads)
  • Companies that track how users interact with the Services
  • Companies that measure advertising campaign performance and conversion rates
  • Companies that help us understand user demographics and interests for advertising purposes
• Legal Obligations. We may share any Personal Data that we collect with third parties in conjunction with any of the activities set forth under “Meeting Legal Requirements and Enforcing Legal Terms” in the “Our Commercial or Business Purposes for Collecting Personal Data” section above.
• Business Transfers. All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.

How We Train Models

We may use Personal Data to develop, fine-tune, and evaluate our models and improve our Services. We do not use training data to contact individuals for marketing purposes, and we do not sell Personal Data used for training except as described in the “How We Share Your Personal Data” section. While we don't actively seek Personal Data from the content you share with the Services (such as photos and screenshots), these files may contain embedded Personal Data that could be incidentally included in our training processes. Where we engage third-party AI/LLM providers, we do so under written data processing agreements that restrict their use of Personal Data and require appropriate technical and organizational safeguards.

Why Does SmoothSpeak Collect Location Data?

SmoothSpeak may use location information to provide you and our users with contextual suggestions(e.g., nearby date locations/ideas), user segment profiles, and analytics about the Services . We may derive this location information from our chats in the Services, your IP address, or, if authorized, geolocation data via your mobile device. If you share geo-location data via your mobile device, you can manage or revoke that permission in your mobile device settings.

Data that is Not Personal Data

We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build and improve the Services (including to improve our algorithmic models) and promote our business, provided that we will not share such data in a manner that could identify you.

Tracking Tools, Advertising and Opt-Out

The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser, tell us how and when you visit and use our Services, analyze trends, learn about our user base and operate and improve our Services. Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s). Please note that because of our use of Cookies, the Services do not support “Do Not Track” requests sent from a browser at this time.

We use the following types of Cookies:

• Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and services unavailable.
• Functional Cookies. Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These Cookies help us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Performance/Analytical Cookies. Performance/Analytical Cookies allow us to understand how visitors use our Services. They do this by collecting information about the number of visitors to the Services, what pages visitors view on our Services and how long visitors are viewing pages on the Services. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns to help us improve our campaigns and the Services’ content for those who engage with our advertising.

You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work.

To explore what Cookie settings are available to you, look in the “preferences” or “options” section of your browser’s menu. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/.

Data Security and Retention

We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.

We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you with our Services. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

Eligibility

As noted in the Terms of Service, we do not knowingly collect or solicit Personal Data for individual sunder 18 years of age. If you are under the age of 18, please do not attempt to register for or otherwise use the Services or send us any Personal Data.

Additionally, in accordance with our practices to comply with the Children’s Online Privacy Protection Act, if we learn we have collected Personal Data from a child under 13 years of age, we will delete that information as quickly as possible. If you believe that a child under 13 years of age may have provided Personal Data to us, please contact us at support@smoothspeak.ai.

State Law Privacy Rights

California Resident Rights

If you live in California, please visit our California Privacy Notice, which supplements this Privacy Policy.

Additionally, under California Civil Code Sections 1798.83-1798.84, California residents are entitled tocontact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketingpurposes; in order to submit such a request, please contact us at support@smoothspeak.ai.

Nevada Resident Rights

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. You can exercise this right by contacting us atsupport@smoothspeak.ai with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account.

Colorado, Connecticut, Montana, Oregon, Texas, Utah and Virginia Rights

If you reside in Colorado, Connecticut, Montana, Oregon, Texas, Utah, or Virginia, applicable state laws grant you specific rights regarding your Personal Data, including the right to:

• Access and obtain a copy of your Personal Data;
• Correct inaccuracies in your Personal Data;
• Delete your Personal Data, subject to certain exceptions;
• Opt out of targeted advertising, the sale of your Personal Data, or certain profiling decisions.

To exercise these rights or to learn more, please contact us at support@smoothspeak.ai. We will verify your request and respond as required by applicable state laws.

Changes to this Privacy Policy

We’re constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time, but we will alert you to any such changes by placing a notice on the Services website, by sending you an email and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes. Use of information we collect is subject to the Privacy Policy in effect at the time such information is collected.

Contact Information

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at support@smoothspeak.ai.