Privacy Policy

Effective Date: June 11, 2026

Last Updated: June 11, 2026

Company: Ember Relationship Labs, Inc. (Delaware C-Corp)

Contact: privacy@alura.love

INTRODUCTION

Welcome to Alura's Privacy Policy. This document explains how Ember Relationship Labs, Inc. ("Alura," "we," "us," or "our") collects, uses, stores, protects, and shares your personal information when you use our dating services, website, mobile application, and related services (collectively, the "Services").

We take your privacy seriously. This Privacy Policy should be read together with our Terms of Use, which govern your use of the Services. By accessing or using the Services, you acknowledge and agree to the data practices described in this Privacy Policy.

AI TRANSPARENCY NOTICE

Alura uses artificial intelligence to power our matchmaking services. Our AI analyzes:

Your profile information and conversational inputs
Questionnaire and personality quiz responses
In-app behavior and usage patterns
Voice recordings and biometric data
Compatibility answers and responses
Messages and communications with other users
Photos and visual information

Our AI uses this data to:

Generate your dating profile
Create personality assessments and visualizations
Recommend compatible matches
Personalize your experience
Improve our algorithms and Services

Important: AI-generated content may be inaccurate, incomplete, or reflect unintended biases. You have the right to:

Request an explanation of how AI recommendations are made
Request human review of significant AI-driven outcomes
Access and review your AI-generated profile
Correct inaccuracies in your data or AI-generated content

These rights are consistent with California SB-53 transparency standards and emerging AI regulation.

1. WHO WE ARE

Data Controller:

If you live in the United States, the company responsible for your personal data (the "data controller") is:

Ember Relationship Labs, Inc.
PO Box 355
Los Altos, California 94022
United States
Email: privacy@alura.love
Phone: (408) 638-9584

International Expansion (2026):

When Alura expands to the European Union and United Kingdom in 2026, we will:

Designate an EU/UK data controller representative
Update this Privacy Policy to include GDPR-compliant disclosures
Provide lawful bases for data processing (consent, legitimate interest, etc.)
Support full GDPR rights (access, rectification, erasure, portability, restriction, objection)
Establish EU/UK-specific contact and complaint channels
Implement Standard Contractual Clauses for international data transfers

Until international expansion, Alura processes all data under U.S. law (Delaware, Federal, and California CCPA/CPRA).

2. INFORMATION WE COLLECT

2.1 Information You Provide Directly

When you create an Alura account and use the Services, you provide:

Account and Registration Information:

Full name
Date of birth (to verify you are 18+)
Gender identity and pronouns
Email address
Phone number (for verification and notifications)
Password and login credentials
Location (city, state, ZIP code)

Profile Information:

Demographic information (ethnicity, religion, education, occupation)
Physical characteristics (height, body type)
Lifestyle information (smoking, drinking, exercise habits)
Dating preferences and relationship goals
Interests, hobbies, and personal values
Photos and images (including required in-app photo)
Responses to personality quizzes and assessments
Any other information you choose to share

Conversational Data with Alura’s AI Agent:

Text conversations and chat transcripts
Voice recordings and audio data
Responses to questions and prompts
Feedback and preferences expressed during conversations
Topics discussed and information shared

Payment Information:

Credit card or payment method details
Billing address
Transaction history and purchase records
Subscription and payment plan information

Communications:

Messages with matches
Communications with customer support
Feedback, surveys, and testimonials
Reports of inappropriate behavior

2.2 Information Collected Automatically

When you use the Services, we automatically collect:

Device Information:

Device type, model, and operating system
Unique device identifiers (IDFA, Android ID)
IP address
Browser type and version
Mobile carrier
Device settings and configurations

Usage Information:

Pages viewed and features used
Time spent on different sections
Click and navigation patterns
Search queries and filters applied
Matches viewed, liked, or passed on
Response rates and engagement metrics
Session duration and frequency
Referring and exit pages

Location Information:

Precise geolocation data (if you enable location services)
Approximate location based on IP address
Location history and patterns
Distance calculations for matching purposes

Cookies and Similar Technologies:

Cookies, web beacons, and pixel tags
Local storage and cache data
Analytics and tracking identifiers
Session and preference data

2.3 Biometric Information

Alura collects biometric information, including:

Voice Biometrics:

Voice recordings from conversations with Alura
Voiceprints and voice-derived characteristics
Speech patterns, tone, and inflection
Audio transcriptions and metadata

Facial Recognition Data:

Facial geometry and characteristics from photos
Facial recognition for identity verification
In-app photo analysis and verification
Photo authenticity and manipulation detection

Purpose of Biometric Collection:

Identity verification and fraud prevention
User authentication and account security
AI-driven personality assessment and matching
Photo verification and quality assurance
Improving AI accuracy and performance

Biometric Data Retention:

We retain biometric data only as long as necessary for the purposes described above
You may request deletion of biometric data at any time
We will permanently delete biometric data within three (3) years of your last interaction with the Services, or upon request, whichever comes first

Legal Notice for Illinois and California Residents: See Section 11 for specific biometric privacy rights under BIPA (Illinois) and CPRA (California).

2.4 Information from Third Parties

We may collect information about you from:

Social Media Platforms:

If you link your social media accounts (Facebook, Instagram, LinkedIn)
Public profile information, photos, and interests
Friend lists and social connections
Content you've shared publicly

Professional Networks:

LinkedIn profile and employment history
Educational background and credentials
Professional accomplishments and skills

Data Brokers and Public Sources:

Publicly available information (social media, professional profiles)
Public records and databases
Marketing and analytics providers
Demographic and interest data

Identity Verification Services:

Government-issued ID verification
Document authentication results
Identity validation and fraud detection data

Background Check Providers:

Criminal history records (if applicable)
Sex offender registry searches
Public records and court documents

Other Users:

Reports and complaints about your behavior
Feedback and reviews
Blocking and safety reports

Partner Portal Subscribers (Matchmakers):

Information shared by professional matchmakers about potential introductions
Client preferences and requirements
Feedback about dates and interactions

2.5 Inferred Information

Based on the data we collect, we may infer additional information about you, including:

Personality traits and characteristics
Compatibility factors with other users
Dating preferences and patterns
Likelihood of match success
Engagement and activity predictions
Communication style and preferences

3. HOW WE USE YOUR INFORMATION

3.1 Primary Purposes

We use your information to:

Provide and Operate the Services:

Create and maintain your account
Generate your AI-driven dating profile
Conduct personality assessments and create visualizations
Identify and recommend compatible matches
Facilitate introductions and connections
Enable messaging and communication features
Verify your identity and prevent fraud
Process payments and manage subscriptions

Personalize Your Experience:

Customize match recommendations based on preferences
Tailor content and features to your interests
Improve AI accuracy and relevance for your profile
Remember your settings and preferences
Provide personalized notifications and updates

Ensure Safety and Security:

Verify user identities and authenticate accounts
Detect and prevent fraud, abuse, and illegal activity
Conduct background checks and safety screenings
Investigate reports of misconduct or violations
Enforce our Terms of Use and community guidelines
Protect against security threats and vulnerabilities

Communicate with You:

Send match notifications and introduction alerts
Provide customer support and respond to inquiries
Send service updates and important notices
Request feedback and conduct surveys
Deliver promotional and marketing communications by email or in-app, with consent (Alura does not send marketing or promotional communications by SMS)

Improve and Develop Services:

Analyze usage patterns and user behavior
Test new features and functionalities
Conduct research and data analysis
Train and improve AI algorithms
Identify trends and insights
Optimize performance and user experience

Legal and Compliance:

Comply with legal obligations and regulations
Respond to legal requests and court orders
Protect our rights and property
Resolve disputes and enforce agreements
Maintain records for regulatory purposes

3.2 AI and Machine Learning

We use AI and machine learning for:

Profile Generation: Creating comprehensive dating profiles based on your conversational inputs and data
Personality Analysis: Assessing personality traits, values, and compatibility factors
Match Recommendations: Identifying potential matches based on compatibility algorithms
Natural Language Processing: Understanding and analyzing conversational data
Voice Analysis: Processing voice recordings to enhance profile accuracy
Photo Verification: Detecting photo manipulation and verifying authenticity
Predictive Modeling: Forecasting match success and user engagement
Content Moderation: Identifying inappropriate content and behavior
Algorithm Improvement: Training AI models to enhance accuracy and performance

Important Considerations:

AI decisions are not always perfect and may contain errors or biases
You have the right to request human review of significant AI-driven decisions
You can request explanations of how AI recommendations are made
AI-generated content should be reviewed for accuracy

3.3 Marketing and Advertising

With your consent, we may use your information to:

Send promotional emails and notifications about Alura features
Display personalized advertisements on third-party platforms
Conduct marketing campaigns and special offers
Share success stories and testimonials (with explicit permission)
Analyze marketing effectiveness and campaign performance

You can opt out of marketing communications at any time by:

Clicking "unsubscribe" in emails
Adjusting notification settings in your account
Contacting privacy@alura.love

Note: Your mobile phone number and SMS opt-in/consent data are excluded from all advertising and analytics sharing described above and are governed solely by the ‘SMS / Text Messaging (A2P 10DLC)’ section. They are not shared with advertising networks, social-media advertising partners, or analytics providers. You cannot opt out of transactional or service-related communications (account verification, billing notices, safety alerts).

4. HOW WE SHARE YOUR INFORMATION

4.1 Sharing with Other Users (Matches)

When you are matched with another user, we share:

Your AI-generated dating profile
Your photos (including in-app photo)
Your personality assessment results (in visual/text format)
Your approximate location (city/region)
Your preferences and interests
Your first name and age

We do NOT share with matches (unless you choose to share):

Your last name or full contact information
Your exact address or precise location
Your phone number or email address
Your payment information, except to the extent your subscription status is communicated on your profile or matching privileges
Your conversations with Alura, except to the extent information from your conversation is reflected in your profile or matching
Your private messages with other matches

After a mutual match, you control what additional information to share through in-app messaging.

4.2 Sharing with Partner Portal Subscribers (Professional Matchmakers)

Professional matchmakers who subscribe to our Partner Portal may access:

Your photos and AI-generated profile, including a profile summary and suggestions as to with whom you would best match, both which are intended only for subscribing matchmakers
Visual and textual representations of your personality assessments
Your dating preferences and relationship goals
Your demographic information (age, location, education, occupation, income, net worth)
Subscription status and purchase history
Your interests, values, and lifestyle information
Your activity status and engagement level

Matchmakers may access this information to:

Identify potential candidates for introduction to their own paying clients
Facilitate introductions between you and their clients
Offer or provide professional matchmaking services

Important Protections:

You can opt out of Partner Portal sharing at any time by contacting support@alura.love or adjusting your “Discovery” settings
If a matchmaker identifies you as a potential candidate, we will ask your permission before sharing your personal contact information unless you have already provided permission.
If we identify you as a potential paying client for a matchmaker, we will ask your consent before making an introduction unless you have already provided consent.
Matchmakers are contractually obligated to keep your information confidential and use it only for legitimate matchmaking purposes
Partner Portal subscribers are not Alura employees and have asserted that they are independent businesses,

4.3 Service Providers and Business Partners

We share information with trusted third-party service providers who help us operate the Services:

Technology and Infrastructure:

Cloud hosting providers (AWS, Google Cloud, etc.)
Large Language Model (LLM) providers (Anthropic, OpenAI)
Voice Technology companies (Eleven Labs)
Database and storage services
Content delivery networks (CDNs)
Software development and IT services

Payment Processing:

Payment processors and gateways (Stripe, PayPal, etc.)
Fraud detection and prevention services
Billing and subscription management platforms

Analytics and Performance:

Analytics providers (Google Analytics, Mixpanel, etc.)
A/B testing and optimization tools
Performance monitoring and error tracking
User behavior and engagement analysis

Identity Verification and Safety:

Identity verification services (Jumio, Onfido, etc.)
Background check providers
Facial recognition and biometric authentication services
Fraud detection and risk assessment tools

Communications:

Email service providers (SendBird, SendGrid, Mailchimp, etc.)
SMS and push notification services
Customer support platforms (Zendesk, Intercom, etc.)

Marketing and Advertising:

Advertising networks and platforms
Marketing automation tools
Social media advertising partners

AI and Machine Learning:

AI model training and hosting platforms
Natural language processing services
Voice transcription and analysis services

Important: All service providers are contractually obligated to:

Maintain appropriate security measures
Comply with applicable privacy laws

4.4 Legal Requirements and Safety

We may disclose your information when required or permitted by law:

Legal Obligations:

To comply with subpoenas, court orders, or legal processes
To respond to lawful requests from government authorities
To comply with applicable laws and regulations
To respond to claims of illegal activity or rights violations

Safety and Protection:

To protect the rights, property, and safety of Alura, our users, or the public
To prevent or investigate fraud, abuse, or illegal activity
To enforce our Terms of Use and other agreements
To protect against legal liability
To prevent harm or violence

Abuse Prevention:

If we suspect a user may be a victim of abuse, neglect, or domestic violence
To report suspected child abuse or elder abuse to appropriate authorities
To prevent imminent harm to individuals

4.5 Business Transfers

If Alura is involved in a merger, acquisition, sale of assets, bankruptcy, or other business transaction, your information may be transferred as part of that transaction. The acquiring entity will be required to:

Honor the commitments made in this Privacy Policy
Provide notice if there are material changes to data practices

You will be notified via email and/or prominent notice on the Services if such a transfer occurs.

4.6 Aggregated and De-Identified Data

We may share aggregated, anonymized, or de-identified data that cannot reasonably be used to identify you:

Statistical information about user demographics and behavior
Trends and insights about dating preferences and success rates
Research findings and industry reports
Business analytics and performance metrics

This data is used for research, marketing, industry analysis, and improving the Services.

4.7 With Your Consent

We may share your information with third parties when you explicitly consent, such as:

Sharing your success story or testimonial publicly (with your permission)
Connecting with third-party services you authorize
Participating in research studies or surveys
Promotional partnerships or sponsored features

You can revoke consent for optional sharing at any time.

4.8 SMS / Text Messaging (A2P 10DLC)

This section governs the text messages (SMS) Alura sends and supplements this Privacy Policy. If any general data-sharing provision elsewhere in this Privacy Policy conflicts with this section, this section controls with respect to your mobile phone number and SMS opt-in/consent data.

SMS data we collect. When you provide your mobile number and consent during signup, we collect your mobile phone number, a record of your consent (including the date, time, and version of the consent language you agreed to), and SMS interaction data such as message delivery status and your STOP, HELP, or other replies.

How we use it. We use your mobile number only to send transactional, service-related text messages — including application status, introductions, date scheduling and reminders, cancellations, and account or security alerts. Alura does not send marketing or promotional text messages of any kind. All marketing communications are sent only by email, under a separate opt-in.

No sharing for marketing. Alura will not share, sell, or rent your mobile phone number or your SMS opt-in/consent data to any third parties or affiliates for their marketing or promotional purposes. All other data-sharing categories described in this Privacy Policy, including sharing with matches, Partner Portal matchmakers, advertising networks, and analytics partners, exclude your text-messaging opt-in data and consent; this information will not be shared with any third parties.

Limited sharing to deliver messages. We share your mobile number only with the service providers that help us deliver these text messages (for example, our SMS provider, Twilio). These providers are bound by confidentiality obligations and may use your mobile number solely to deliver the messages you have requested.

Message frequency. Message frequency varies based on your account activity.

Message and data rates. Message and data rates may apply.

How you opt in. You opt in to SMS inside the Alura mobile app during account signup by entering your mobile number and tapping “Continue,” which records your affirmative consent.

How you opt out and get help. You can opt out at any time by replying STOP to any message; you will receive a confirmation and no further texts. Reply HELP for help, or contact privacy@alura.love.

5. DATA RETENTION

5.1 How Long We Keep Your Data

We retain your personal information only as long as necessary to:

Provide and improve the Services
Comply with legal obligations
Resolve disputes and enforce agreements
Maintain records for legitimate business purposes
Fulfill the purposes described in this Privacy Policy

Retention Periods:

Active Accounts:

While your account is active, we retain all profile data, conversations, matches, and usage information
Voice recordings and conversational data are retained for AI training and service improvement
Payment information is retained as required for billing and tax purposes

Inactive Accounts:

If you do not log in for 12 consecutive months, we may consider your account inactive
You may reactivate your account at any time before deletion

Deleted Accounts:

When you delete your account, most personal information is deleted within 30 days
Some information may be retained for legal, security, or operational purposes:
- Transaction records (7 years for tax/accounting purposes)
- Legal compliance data (as required by law)
- De-identified data for analytics and research
- Safety reports and investigations
- Backup systems (deleted within 90 days)

Biometric Data:

Voice recordings: Retained for 3 years from last interaction or until you request deletion
Facial recognition data: Retained while your account is active and for 90 days after deletion (unless you request earlier deletion)
You may request deletion of biometric data at any time

Partner Portal Data:

Matchmakers who have accessed your information may retain it according to their own retention policies
We contractually require matchmakers to delete data when no longer needed for matchmaking purposes

5.2 Factors in Determining Retention Periods

When determining how long to retain data, we consider:

The amount, nature, and sensitivity of the information
The purposes for which we collected and processed the data
Whether we can fulfill those purposes through other means
Applicable legal, regulatory, or contractual requirements
The risk of harm from unauthorized use or disclosure
User expectations and reasonable retention periods for the type of data

5.3 Deleting Your Data

You can request deletion of your data at any time by:

Using the account deletion feature in your settings
Contacting privacy@alura.love with a deletion request

What happens when you delete your account:

Your profile is removed from public view
Your matches and messages become inaccessible
Your photos and profile information are deleted within 30 days
Your voice recordings and biometric data are deleted (unless retained for legal compliance)
Some data may be retained as described in Section 5.1

Note: Deletion is permanent and cannot be undone. Consider downloading your data before deletion.

6. DATA SECURITY

6.1 Our Security Measures

We implement commercially reasonable technical, administrative, and organizational safeguards to protect your personal information:

Technical Safeguards:

Encryption of data in transit (TLS/SSL)
Encryption of sensitive data at rest
Secure authentication and access controls
Regular security audits and vulnerability assessments
Intrusion detection and prevention systems
Firewalls and network security measures
Secure coding practices and code reviews

Administrative Safeguards:

Employee security training
Strict access controls and need-to-know policies
Confidentiality agreements with employees and contractors
Incident response and data breach procedures
Regular security policy reviews and updates

Organizational Safeguards:

Security and privacy team
Data protection impact assessments
Privacy by design principles
Regular compliance monitoring
Vendor security requirements and audits

6.2 Your Security Responsibilities

You play a critical role in protecting your information:

Use strong, unique passwords and change them regularly
Enable two-factor authentication if available
Keep your login credentials confidential and never share them
Log out after using the Services on shared devices
Be cautious about what you share in messages and profiles
Report suspicious activity immediately
Keep your device and apps updated with the latest security patches

6.3 Security Limitations

No system is 100% secure. Despite our security measures:

Data transmission over the internet carries inherent risks
Unauthorized access, hacking, or data breaches may occur
You transmit information to us at your own risk
We cannot guarantee absolute security of your data

In the event of a data breach:

We will notify affected users as required by law
We will take steps to mitigate harm and prevent future breaches
We will cooperate with law enforcement and regulators
We will provide information about the breach and available remedies as required by law

6.4 Third-Party Security

We are not responsible for the security practices of:

Other users who may receive your information
Partner Portal subscribers (matchmakers)
Third-party services and websites
Social media platforms you link to your account

Review the security and privacy policies of any third parties with whom you share information.

7. YOUR RIGHTS AND CHOICES

7.1 Access and Portability

You have the right to:

Access your personal information and receive a copy of the data we hold about you
Request a portable copy of your data in a structured, commonly used format (CSV, JSON)
Review your AI-generated profile and personality assessments

To exercise these rights:

Access most of your data directly in your account settings
Request a data download by contacting privacy@alura.love
We will provide your data within 45 days of a verified request (may be extended by 45 days if necessary)

What you can access:

Profile information and photos
Personality quiz results and assessments
Match history and preferences
Messages and conversations (with matches)
Account settings and preferences
Transaction and payment history
Voice recording transcripts (upon request)

7.2 Correction and Updates

You have the right to:

Correct inaccurate or incomplete information in your profile
Update outdated information to keep it current
Request correction of AI-generated content that is inaccurate

How to make corrections:

Update most information directly in your account settings
Contact Alura to update conversational data or AI-generated content
Contact privacy@alura.love for assistance with corrections

We will make reasonable efforts to correct inaccuracies within 30 days.

7.3 Deletion

You have the right to:

Delete your account and request deletion of your personal information
Request deletion of specific data (such as voice recordings or photos)
Withdraw consent for data processing where consent is the legal basis

To delete your data:

Use the account deletion feature in settings
Contact privacy@alura.love with a deletion request
Be specific about what data you want deleted if not deleting your entire account

Limitations on deletion:

Some data may be retained for legal, security, or operational reasons (see Section 5.1)
We cannot delete data that has been shared with matches or matchmakers
Deletion may prevent us from providing certain Services to you

7.4 Opt-Out of Marketing

You can opt out of marketing communications by:

Clicking "unsubscribe" in promotional emails
Adjusting email preferences in your account settings
Contacting privacy@alura.love

Note: You cannot opt out of transactional or service-related communications (account verification, safety alerts, billing notices).

7.5 Opt-Out of Partner Portal Sharing

To opt out of having your profile shared with professional matchmakers:

Adjust your Partner Portal privacy settings in your account
Contact support@alura.love or privacy@alura.love
Your profile will be removed from the Partner Portal within 7 business days

Note: Matchmakers who have already accessed your information may retain it according to their own policies.

7.6 Limit Use of Sensitive Information

You have the right to limit the use of sensitive personal information, including:

Biometric data (voice recordings, facial recognition)
Precise geolocation data
Racial or ethnic origin, religious beliefs, sexual orientation
Health or genetic information

To limit sensitive data use:

Disable location services in your device settings
Contact privacy@alura.love to opt out of voice recording analysis
Request deletion of biometric data
Limit what you share in conversations and profile

Note: Some limitations may affect the quality of our Services or matching recommendations.

7.7 Object to Processing

To the extent required by law, you have the right to object to:

Processing of your data for direct marketing purposes
Processing based on legitimate interests
Automated decision-making and profiling (in certain circumstances)

To object:

Contact privacy@alura.love with your objection
Specify which processing activities you object to
We will evaluate your objection and respond within 30 days

7.8 Third-Party Data

If you are a California resident, you have the right to:

Know what third-party sources we obtained your data from
Request deletion of data obtained from third parties
Opt out of future collection from third-party sources

To exercise these rights:

Contact privacy@alura.love
We will provide information about third-party sources within 45 days

7.9 No Discrimination

We will not discriminate against you for exercising your privacy rights. This means we will not:

Deny you access to the Services
Charge different prices or fees
Provide a different level or quality of service
Suggest that you will receive a different price or quality of service

Note: Some rights may require us to verify your identity, which may involve requesting additional information.

8. COOKIES AND TRACKING TECHNOLOGIES

8.1 Types of Technologies We Use

Cookies: Small text files stored on your device that help us recognize you and remember your preferences.

Web Beacons/Pixels: Tiny graphics that track user activity and measure campaign effectiveness.

Local Storage: Browser-based storage for data that persists across sessions.

Mobile Identifiers: Device-specific identifiers (IDFA, Android ID) used for analytics and advertising.

Session Storage: Temporary storage that expires when you close your browser.

8.2 How We Use These Technologies

Essential Cookies (Required):

Authentication and account access
Security and fraud prevention
Load balancing and performance
Maintaining your session

Functional Cookies (Required):

Remembering your preferences and settings
Providing personalized features
Enabling specific functionality

Analytics Cookies (Required):

Understanding how users interact with the Services
Measuring traffic and usage patterns
Identifying popular features and content
A/B testing and optimization

Advertising Cookies (Optional):

Delivering personalized advertisements
Measuring ad campaign effectiveness
Retargeting and remarketing
Cross-device tracking

8.3 Managing Cookies

You can control cookies through:

Browser settings: Most browsers allow you to refuse or delete cookies
Opt-out tools: Industry opt-out tools like NAI and DAA
Mobile settings: Limit ad tracking in iOS or opt out of personalized ads in Android
Our cookie preferences: Adjust cookie settings in your account (where available)

Note: Disabling essential cookies may affect your ability to use the Services.

8.4 Do Not Track

Some browsers have "Do Not Track" (DNT) features. Currently, there is no industry standard for responding to DNT signals. We do not respond to DNT browser signals, but you can control cookies and tracking as described above.

8.5 Third-Party Analytics and Advertising

We use third-party analytics and advertising services that may use cookies and similar technologies:

Google Analytics: Web analytics service (see Google's Privacy Policy)
Facebook Pixel: Advertising and measurement tool (see Facebook's Data Policy)
Other providers: May be added or removed from time to time

These third parties may collect information about your online activities over time and across different websites.

9. INTERNATIONAL DATA TRANSFERS

9.1 Data Transfer to the United States

The Services are hosted in the United States. If you access the Services from outside the U.S., your information will be transferred to, stored, and processed in the United States.

By using the Services, you consent to:

Transfer of your data to the United States
Processing of your data under U.S. law
Application of this Privacy Policy

Important: Data protection laws in the United States may differ from those in your country and may not provide the same level of protection.

9.2 Safeguards for International Transfers

To protect your data during international transfers, we use:

Standard Contractual Clauses (SCCs): European Commission-approved contract terms that provide safeguards for personal data transferred outside the EU/EEA.

Adequacy Decisions: Where available, we rely on determinations by the European Commission that certain countries provide adequate protection.

Other Mechanisms: Binding corporate rules, consent, or other lawful transfer mechanisms as appropriate.

9.3 European Union and United Kingdom (2026)

When we expand to the EU and UK in 2026, we will:

Implement full GDPR compliance measures
Designate an EU/UK data protection representative
Provide EU/UK-specific privacy notices and rights
Establish compliant data transfer mechanisms
Update this Privacy Policy accordingly

10. CHILDREN'S PRIVACY

10.1 Age Restriction

The Services are intended for users age 18 and older. We do not knowingly collect personal information from anyone under 18 years of age.

10.2 Verification

We implement age verification measures during registration, including:

Requiring users to confirm they are 18+
Date of birth request
Identity verification (in some cases)

10.3 Parental Rights

If we learn that we have collected personal information from someone under 18, we will:

Delete the information immediately
Terminate the account
Take steps to prevent future access

Parents or guardians: If you believe we have collected information from a minor, contact us immediately at privacy@alura.love.

11. STATE-SPECIFIC PRIVACY RIGHTS

11.1 California Residents (CCPA/CPRA)

California residents have specific rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):

Right to Know:

What personal information we collect
Sources of personal information
Purposes for collecting personal information
Categories of third parties we share with
Specific pieces of personal information we hold about you

Right to Delete:

Request deletion of personal information (subject to exceptions)

Right to Correct:

Request correction of inaccurate personal information

Right to Opt-Out:

Opt out of "sale" or "sharing" of personal information
Note: Alura does not "sell" personal information as traditionally defined, but sharing with Partner Portal subscribers may qualify as "sharing" under CPRA

Right to Limit:

Limit use and disclosure of sensitive personal information

Right to Non-Discrimination:

We will not discriminate against you for exercising your rights

Sensitive Personal Information:

Under CPRA, we collect the following categories of sensitive information:

Biometric information (voice recordings, facial recognition data)
Precise geolocation data (if you enable location services)
Racial or ethnic origin, religious beliefs (if you choose to provide)
Sexual orientation and gender identity
Account login credentials (password)

You have the right to limit the use of sensitive personal information to purposes necessary to provide the Services.

Categories of Personal Information We Collect:

Category

Examples

Collected?

Identifiers

Name, email, phone number, IP address

Yes

Personal characteristics

Age, gender, sexual orientation, ethnicity

Yes

Commercial information

Purchase history, subscription data

Yes

Biometric information

Voice recordings, facial recognition

Yes

Internet activity

Browsing history, usage data, clicks

Yes

Geolocation data

Precise or approximate location

Yes

Audio/visual information

Photos, voice recordings, videos

Yes

Professional information

Occupation, education, employer

Yes

Inferences

Personality traits, preferences, compatibility

Yes

How to Exercise Your Rights:

Email: privacy@alura.love with subject "California Privacy Rights"
Phone: (408) 638-9584
Online: Use the data request form in your account settings

Verification: We will verify your identity before processing requests. You may be asked to provide:

Email address and account information
Recent login activity
Answers to security questions
Government-issue