Cuddle Privacy Policy
Effective Date: May 8, 2026
1. Introduction, Scope, and Service Summary
1.1 Welcome to Cuddle
Welcome to Cuddle.
This Privacy Policy explains how Third Hub US, Inc., d/b/a Cuddle (“Cuddle,” “we,” “us,” or “our”) collects, uses, discloses, retains, protects, deletes, and otherwise processes personal information in connection with Cuddle.
Cuddle is an 18+ online dating and social connection service for eligible adults located in the United States. We help adults create profiles, discover other users, match or connect where supported, communicate with matched members, manage settings, use reporting and safety tools, contact support, access Free Access, and purchase optional Cuddle-operated digital functionality.
By accessing or using Cuddle, creating an account, communicating with a user, using checkout, making a purchase, submitting a report, contacting support, or submitting a privacy request, you acknowledge that Cuddle processes personal information as described in this Privacy Policy.
1.2 Scope of This Privacy Policy
This Privacy Policy applies to personal information processed in connection with Cuddle, including websites, applications, accounts, profiles, discovery, matching or connection features, messaging, visibility controls, reporting and blocking tools, safety and moderation systems, verification where used, support, checkout, billing, refund and statutory-cancellation processes, chargeback and payment-dispute support, cookies, analytics, security, fraud prevention, payment-risk management, legal notices, appeals, and related services.
In this Privacy Policy, the “Service” means Cuddle’s online dating and social connection service and related functionality provided by or on behalf of Cuddle.
This Privacy Policy does not apply to third-party services Cuddle does not own or control. Those third parties may have their own terms, privacy policies, and legal obligations.
1.3 United States Availability and Adults Only
Cuddle currently offers and markets the Service only to eligible adults located in the fifty states and the District of Columbia. U.S. territories and locations outside the United States are excluded unless Cuddle expressly states otherwise.
Access to or use of the Service from outside the supported area is not authorized, except for lawful support, privacy, billing, refund, statutory-cancellation, security, or legal communications concerning an existing account or purchase.
Cuddle is for adults only. Minors may not create accounts, access or use the Service, appear in content, communicate with users, submit content, purchase or use Paid Features, submit reports, submit privacy requests, or otherwise interact with Cuddle.
1.4 Service, Paid Features, and Payment Model
Cuddle may offer Free Access and optional Premium, Signature, promotional, or complimentary access.
Premium and Signature are currently offered only as one-month or three-month fixed-term, non-renewing purchases through Cuddle’s authorized direct checkout flow. Cuddle does not currently offer subscriptions, recurring billing, automatic renewal, automatic trial-to-paid conversion, automatic repurchase, external purchase channels, or twelve-month Paid Feature access.
Payments through Cuddle’s checkout are payments to Cuddle only for Cuddle-operated digital Service functionality. They are not payments to or for another user and do not provide user-to-user payments, stored value, wallets, virtual credits, cryptocurrency, payment facilitation, marketplace activity, or financial products or services.
Cuddle uses authorized third-party payment processors and payment-method providers for Cuddle purchases. Full payment card details are submitted through processor-hosted or processor-approved payment fields and are not intended to be received or stored on Cuddle-controlled systems.
1.5 Important Privacy and Safety Limits
Some information you provide may be visible to other users, depending on your settings, actions, and features used. Other users may copy, save, screenshot, record, forward, disclose, misuse, or distribute information or communications outside Cuddle.
Unless Cuddle expressly states otherwise for a specific feature, in-Service messaging is not end-to-end encrypted and should not be treated as a guaranteed secure channel for highly sensitive information.
Cuddle does not sell personal information, private messages, sensitive personal information, or payment-related personal information, and does not share personal information for targeted advertising.
1.6 Relationship to Other Terms
This Privacy Policy should be read together with Cuddle’s Terms of Service, Purchase, Billing, Cancellation & Refund Terms, Paid Features Terms, Prohibited Services, Payments & Commerce Policy, Community Guidelines, Safety Tips / Dating Safety Notice, Criminal Background Screening Disclosure, State-Specific Terms & Cancellation Notices, Cookie / Tracking Policy, Copyright / IP Complaints Policy, Contact / Legal Notices, checkout disclosures, purchase-specific terms, product disclosures, and applicable law.
If there is a conflict regarding personal-information processing, this Privacy Policy controls for that subject.
2. Who We Are, Addresses, and Contact Channels
2.1 Cuddle Operator
Cuddle is operated by:
Third Hub US, Inc., a Delaware corporation, d/b/a Cuddle
In this Privacy Policy, “Cuddle,” “we,” “us,” and “our” mean Third Hub US, Inc., d/b/a Cuddle, unless the context clearly requires otherwise.
Cuddle is responsible for the personal information it processes in connection with the Service, subject to applicable law, service-provider roles, payment-provider roles, and the limits described in this Privacy Policy.
Cuddle is an 18+ online dating and social connection service for eligible adults located in the United States. Cuddle is not an adult content platform, escort service, sexual-services platform, compensated dating service, sugar dating service, paid-companionship platform, user-payment service, payment facilitator, marketplace, stored-value provider, wallet provider, cryptocurrency service, money transmitter, bank, lender, broker, or other financial-services provider.
Cuddle may use internal, manual, non-liveness photo or selfie review and identity-document or government-ID review for limited verification, safety, fraud-prevention, payment-risk, account-integrity, legal, privacy, refund, statutory-cancellation, dispute, moderation, or enforcement purposes, as described in this Privacy Policy.
Cuddle does not currently use a third-party identity-verification vendor, government-ID verification vendor, biometric verification provider, liveness provider, facial-recognition provider, or face-matching provider.
Cuddle does not use liveness checks, facial-feature analysis, facial recognition, facial-geometry analysis, face templates, faceprints, fingerprints, voiceprints, biometric identifiers, biometric templates, or biometric verification for the Service.
2.2 Operating Address
Cuddle’s operating address is:
Third Hub US, Inc., d/b/a Cuddle
6900 Dallas Pkwy
Plano, TX 75024
United States
This is an office from which Cuddle conducts business operations.
This operating address is not a payment address, emergency address, ordinary support substitute, secure upload channel, registered-agent address, service-of-process address, subpoena address, law-enforcement request address, regulatory request address, or dedicated address for privacy requests, billing requests, refund requests, statutory-cancellation requests, appeals, security reports, copyright complaints, or formal legal notices.
Do not send or mail payments, passwords, authentication codes, full payment card numbers, card security codes, full bank credentials, private keys, wallet credentials, identity-document images, government identification documents, liveness data, face templates, faceprints, facial-geometry data, fingerprints, voiceprints, biometric identifiers, biometric templates, intimate content, information about minors, medical records, or other highly sensitive information to this address.
When Cuddle needs identity-document or government-ID information for a specific verification, safety, legal, privacy, refund, statutory-cancellation, account-recovery, dispute, Service-integrity, fraud-prevention, payment-risk, moderation, or enforcement process, Cuddle will provide a secure upload flow or specific instructions for that process.
Sending highly sensitive information to the operating address without using the method Cuddle provides may delay review, create privacy or security risk, and may not satisfy a legal deadline unless applicable law requires otherwise or Cuddle accepts the communication in writing.
2.3 Business Mailing Address
Cuddle’s business mailing address is:
Third Hub US, Inc., d/b/a Cuddle
1007 N Orange St, 4th Floor, Suite #5681
Wilmington, DE 19801
United States
This address may be used for general written correspondence where mail is appropriate and no more specific method is required.
The business mailing address is not necessarily Cuddle’s registered-agent address, service-of-process address, subpoena address, law-enforcement request address, regulatory request address, emergency address, payment address, refund address, statutory-cancellation address, privacy-request address, support substitute, or secure upload channel.
Do not send or mail payments, passwords, authentication codes, full payment card numbers, card security codes, full bank credentials, private keys, wallet credentials, identity-document images, government identification documents, liveness data, face templates, faceprints, facial-geometry data, fingerprints, voiceprints, biometric identifiers, biometric templates, intimate content, information about minors, medical records, or other highly sensitive information to this address unless a legally required process specifically requires mail and Cuddle provides specific instructions for that process.
For time-sensitive requests, use the specific official channel listed below or in the Contact / Legal Notices. Keep records showing when, where, and how you sent the request.
2.4 Privacy and Data-Rights Contact
For privacy questions, privacy requests, data-rights requests, consent-withdrawal requests, opt-out requests, sensitive-data questions, privacy appeals where available, authorized-agent requests, or questions about this Privacy Policy, contact:
privacy@cuddle-global.com
Please include enough information for Cuddle to identify your account, request, state of residence where relevant, and authority to act.
Cuddle may need to verify your identity, account ownership, residency, purchase details, or authority before responding, as described in Section 13. Verification may use account email, phone number, login status, account identifiers, purchase details, recent activity, signed declarations, authorized-agent documentation, identity-document or government-ID review where reasonably necessary, or other reasonable information.
Cuddle does not currently use a third-party identity-verification vendor, government-ID verification vendor, biometric verification provider, liveness provider, facial-recognition provider, or face-matching provider to verify privacy requests.
Cuddle does not use liveness checks, facial recognition, facial-feature analysis, facial-geometry analysis, face templates, faceprints, fingerprints, voiceprints, biometric identifiers, biometric templates, or biometric verification to verify privacy requests.
Do not send passwords, authentication codes, full payment card numbers, card security codes, full bank credentials, private keys, wallet credentials, identity-document images, government identification documents, liveness data, face templates, faceprints, facial-geometry data, fingerprints, voiceprints, biometric identifiers, biometric templates, intimate content, information about minors, medical records, or other highly sensitive information by ordinary email.
When Cuddle needs identity-document or government-ID information for a specific privacy, data-rights, authorized-agent, appeal, account-recovery, safety, legal, refund, statutory-cancellation, dispute, Service-integrity, fraud-prevention, payment-risk, moderation, or enforcement process, Cuddle will provide a secure upload flow or specific instructions for that process.
2.5 Other Official Contact Channels
Use the channel that best matches your request:
General Support: support@cuddle-global.com
Billing, Refunds, Duplicate Charges, Unauthorized Charges, Chargebacks, and Payment Disputes: billing@cuddle-global.com
Statutory Cancellation Requests: cancellations@cuddle-global.com
Safety Reports: safety@cuddle-global.com
Security Reports: security@cuddle-global.com
Formal Legal Notices: legal@cuddle-global.com
Eligible Enforcement Appeals: appeals@cuddle-global.com
Copyright Complaints: copyright@cuddle-global.com
Other IP and Rights Complaints: ip@cuddle-global.com
Arbitration Opt-Out and Material-Change Rejection: arbitrationoptout@cuddle-global.com
A general support request is not automatically a privacy request, data-rights request, refund request, statutory-cancellation request, safety report, security report, legal notice, copyright complaint, appeal, Notice of Dispute, arbitration opt-out notice, material-change rejection, subpoena response, law-enforcement request, regulatory request, or service-of-process communication.
Use the specific channel required by the applicable Privacy Policy, Terms, Purchase Terms, Paid Features Terms, State-Specific Terms, Contact / Legal Notices, checkout disclosure, purchase-specific term, court rule, or law.
Formal legal notices are different from support, billing, refund, statutory-cancellation, privacy, safety, security, rights, and appeal requests. Sending a document to an email address, operating address, or business mailing address does not by itself constitute valid service of process, acceptance of service, consent to jurisdiction, waiver of an objection, or agreement that a court, agency, or tribunal has authority over Cuddle.
Cuddle does not accept service of process through ordinary email, support tickets, in-Service messages, social media, reports, appeals, or third-party communications unless law requires otherwise or Cuddle expressly accepts it in writing.
2.6 Emergency and Sensitive-Information Limits
Cuddle contact channels are not emergency-response channels and may not be monitored in real time. If you are in immediate danger, believe another person is in immediate danger, or need emergency assistance, contact local emergency services immediately.
Do not send highly sensitive information by ordinary email, ordinary mail, ordinary messages, profile fields, reports, appeals, support channels, or general contact channels.
Highly sensitive information may include full payment card numbers, card security codes, passwords, authentication codes, full bank credentials, private keys, wallet credentials, identity-document images, government identification documents, liveness data, face templates, faceprints, facial-geometry data, fingerprints, voiceprints, biometric identifiers, biometric templates, intimate content, information about minors, medical records, health information, precise geolocation, or other information that could create material privacy, safety, payment, identity, account-security, legal, or personal risk.
When Cuddle needs identity-document or government-ID information for a specific verification, safety, legal, privacy, refund, statutory-cancellation, account-recovery, dispute, Service-integrity, fraud-prevention, payment-risk, moderation, or enforcement process, Cuddle will provide a secure upload flow or specific instructions for that process.
Cuddle does not request liveness data, face templates, faceprints, facial-geometry data, fingerprints, voiceprints, biometric identifiers, biometric templates, or biometric verification materials for ordinary account verification.
Cuddle does not currently use a third-party identity-verification vendor, government-ID verification vendor, biometric verification provider, liveness provider, facial-recognition provider, or face-matching provider.
Sending a request to the wrong channel may delay review and may not satisfy a legal deadline unless applicable law requires otherwise or Cuddle accepts the communication in writing.
2.7 Updates to Addresses, Channels, and Request Procedures
Cuddle may update addresses, contact channels, routing instructions, request forms, secure-upload instructions, verification procedures, privacy-request procedures, legal-notice procedures, support procedures, or Contact / Legal Notices by updating this Privacy Policy, the Contact / Legal Notices, a Legal page, an account notice, an in-Service notice, or another method permitted by law.
For time-sensitive requests, use the most current official channel available and retain records showing when, where, and how you sent the request.
If another Cuddle term, state-specific notice, privacy-rights notice, court rule, checkout disclosure, purchase-specific term, or applicable law requires a different method, that method controls instead.
No update to an address, contact channel, request form, verification procedure, secure-upload instruction, support process, or Legal page authorizes prohibited services, prohibited payments, user-to-user transfers of value, adult content monetization, adult live-chat, pornography sales, sexual services, escort services, compensated dating, sugar arrangements, paid companionship, payment facilitation, marketplace activity, financial services, abuse, exploitation, unsafe conduct, or unlawful activity.
3. Personal Information We Collect
3.1 Overview
Cuddle collects personal information to provide, operate, secure, support, and enforce the Service.
The information we collect depends on how you use Cuddle, the features you use, the information you provide, the purchases you make, the reports or requests you submit, any verification or review involved, and the devices, browsers, and payment methods you use.
Not every user provides, generates, or is associated with every category described in this Section.
3.2 Account, Eligibility, and Contact Information
We may collect information you provide when you create, access, verify, recover, update, or manage an account.
This may include your name, display name, username, profile identifier, email address, phone number, date of birth, age confirmation, account credentials, authentication information, password-reset information, account settings, notification settings, account status, language choices, state of residence, billing ZIP code, and eligibility information.
We may collect records relating to the eighteen-plus requirement, United States availability, account ownership, supported-area location, sanctions compliance, fraud prevention, payment-risk management, account integrity, Service security, email or phone verification, internal manual non-liveness photo or selfie review, identity-document or government-ID review, payment-method or billing verification, location or residency confirmation, transaction review, moderation review, and enforcement review.
We may also collect records showing acceptance of terms, consent choices, notice delivery, privacy choices, legal acknowledgments, checkout acknowledgments, purchase acknowledgments, and account-setting changes.
3.3 Profile, Preferences, Discovery, and User Content
We collect information you choose to include in your account or profile.
This may include profile text, prompts, bios, photos, videos if supported, display information, age or age range if displayed, approximate location or location preferences, dating preferences, discovery preferences, visibility settings, interests, lifestyle information, relationship-related information, and other profile content.
We may collect User Content that you create, upload, display, send, report, link to, or otherwise make available through Cuddle, including photos, videos if supported, prompts, messages, reactions, profile details, screenshots, evidence, reports, appeals, support communications, legal notices, rights complaints, verification submissions where used, and other materials you provide.
Profile photos and other images may be processed as User Content for display, safety, moderation, abuse prevention, fraud prevention, account-integrity review, support, and legal compliance. Cuddle does not use profile photos, selfie materials, identity-document images, or government-ID materials to create biometric templates, perform facial recognition, conduct liveness checks, personalize prices, rank users, match users, advertise, sell or share personal information, or provide financial products or services.
3.4 Messages, Interactions, Reports, Appeals, and Support
Because Cuddle is an online dating and social connection service, we process information about how users interact through the Service.
This may include likes, matches or connections, message content, message metadata, reactions, read receipt information where supported, limited message-deletion activity where supported, blocks, mutes, unmatches, discovery activity, visibility controls, reports, safety notes, appeal records, moderation records, enforcement records, and related timestamps.
Unless Cuddle expressly states otherwise for a specific feature, in-Service messaging is not end-to-end encrypted and should not be treated as a secure channel for highly sensitive information.
If you submit a report, appeal, safety concern, rights complaint, privacy request, security report, legal notice, refund request, statutory-cancellation request, chargeback communication, payment-dispute communication, account-recovery request, verification response, moderation response, or support request, we may collect information reasonably needed to review, route, verify, respond to, preserve, and document the matter.
3.5 Purchase, Checkout, Billing, Refund, and Payment-Dispute Information
If you purchase or use Paid Features, use checkout, request billing support, request a refund, submit a statutory-cancellation request, dispute a charge, or participate in a chargeback or payment-dispute process, we may collect purchase-related and billing-related information.
This may include access level, one-month or three-month access period, price, currency, taxes or fees, purchase date, authorization status, activation date, expiration date and time, receipt information, billing descriptor, payment method type, limited payment method details where available, billing information, transaction identifiers, refund records, statutory-cancellation records, chargeback records, dispute records, payment-risk signals, fraud-prevention signals, and related support communications.
Premium and Signature are offered only as fixed-term, non-renewing purchases through Cuddle’s authorized direct checkout flow. Cuddle does not currently offer subscriptions, recurring billing, automatic renewal, automatic trial-to-paid conversion, automatic repurchase, external purchase channels, or twelve-month Paid Feature access.
Full payment card details are submitted directly through processor-hosted or processor-approved payment fields or flows and are not intended to be received or stored on Cuddle-controlled systems.
3.6 Device, Usage, Location, Cookie, Fraud, and Security Information
We may collect information automatically when you access or use Cuddle.
This may include IP address, approximate location inferred from IP address or device signals, device type, browser type, operating system, app or web version, device, browser, session, cookie, and local storage identifiers, pages viewed, feature use, error logs, timestamps, language settings, diagnostic information, and similar technical information.
We may collect security, fraud-prevention, payment-risk, and account-integrity signals, including login patterns, device and browser changes, suspicious activity indicators, card-testing or payment-abuse signals, bot or automation signals, abuse reports, moderation signals, verification signals where used, and enforcement history.
We may use these signals to assess supported-area eligibility, state-specific notices, tax treatment, fraud prevention, sanctions compliance, payment-risk management, and Service integrity.
3.7 Verification, Identity-Document Review, Sensitive Information, and Information You Should Not Send
Where supported or reasonably necessary, Cuddle may request or process information for age confirmation, identity-document review, account ownership, supported-area location, residency, payment authority, billing, safety, fraud prevention, payment-risk management, legal compliance, account recovery, privacy-request verification, refund or statutory-cancellation review, dispute review, Service integrity, user protection, moderation, or enforcement.
This may include email or phone verification, age confirmation, internal manual non-liveness photo or selfie review, identity-document review, government-ID review, payment-method or billing verification, location or residency confirmation, device checks, IP-address review, account-history review, transaction review, support-based ownership review, and other non-biometric verification information.
Cuddle may use internal, manual, non-liveness photo or selfie review and identity-document or government-ID review to detect, prevent, investigate, and enforce against fake accounts, impersonation, scams, bots, account farms, prohibited commercial activity, prohibited payments, payment abuse, account takeover, age or location evasion, verification evasion, re-registration evasion, and other misuse.
Cuddle does not currently use a third-party identity-verification vendor, government-ID verification vendor, biometric verification provider, liveness provider, facial-recognition provider, or face-matching provider. Cuddle does not use liveness checks, facial-feature analysis, facial recognition, facial-geometry analysis, face templates, faceprints, fingerprints, voiceprints, biometric identifiers, biometric templates, or biometric verification.
Do not send full payment card numbers, card security codes, passwords, authentication codes, full bank credentials, identity-document images, government identification documents, liveness data, face templates, faceprints, facial-geometry data, fingerprints, voiceprints, biometric identifiers, biometric templates, medical records, minor-related information, intimate content, or other highly sensitive information by ordinary email, messages, profile fields, reports, appeals, support channels, or mail.
When Cuddle needs identity-document or government-ID information for a specific verification, safety, legal, privacy, refund, statutory-cancellation, account-recovery, dispute, Service-integrity, fraud-prevention, payment-risk, moderation, or enforcement process, Cuddle will provide a secure upload flow or specific instructions for that process.
3.8 Information From Other Sources and Generated Records
We may collect information from other users, service providers, payment processors, payment-method providers, banks, card networks, fraud-prevention vendors, payment-risk vendors, safety vendors, moderation vendors, security providers, analytics providers, communications providers, support tools, professional advisers, legal authorities, public sources where lawful, and other sources permitted by law.
Operational vendors are not treated as third-party identity-verification vendors merely because they help Cuddle host, secure, route, support, or provide tools for Cuddle-managed systems used in connection with internal manual review, support, moderation, fraud prevention, payment-risk management, privacy-request processing, disputes, or enforcement.
We may also create records or inferences, such as account status, eligibility indicators, safety indicators, fraud-risk indicators, payment-risk indicators, moderation decisions, enforcement decisions, support classifications, access status, verification-review status where used, and privacy-request status.
Cuddle does not use these records to personalize prices or fees or to provide credit, insurance, housing, employment, lending, brokerage, securities, banking, or other financial products or services.
4. Sources of Personal Information
4.1 Overview
Cuddle may collect personal information from several sources, depending on how you use the Service, the features you access, the purchases or requests you make, the reviews or verification processes involved, and the information reasonably needed to operate, secure, support, protect, and enforce Cuddle.
Not every source applies to every user, account, purchase, report, request, device, session, review, or interaction.
Cuddle may collect information directly from you, automatically from your use of the Service, from other users, from service providers and operational vendors, from payment participants, from fraud-prevention and payment-risk sources, from safety and moderation sources, and from legal, public, or other lawful sources.
Cuddle does not currently use a third-party identity-verification vendor, government-ID verification vendor, biometric verification provider, liveness provider, facial-recognition provider, or face-matching provider as a source of identity verification information.
Cuddle may use internal, manual, non-liveness photo or selfie review and identity-document or government-ID review for limited verification, safety, fraud-prevention, payment-risk, account-integrity, legal, privacy, refund, statutory-cancellation, dispute, moderation, or enforcement purposes as described in this Privacy Policy.
4.2 Information From You
We collect personal information directly from you when you create or manage an account, build or update a profile, set preferences, send messages, submit content, use reporting or blocking tools, complete checkout, request billing support, request a refund, submit a statutory-cancellation request, contact support, submit a privacy request, appeal a decision, send a legal notice, respond to a review or verification request, or otherwise communicate with Cuddle.
You choose what to provide, but some information may be required to create an account, verify eligibility, provide a feature, process a purchase, respond to a request, investigate a report, protect account integrity, manage payment risk, enforce applicable terms, or comply with law.
Information you provide may include account information, contact information, profile information, preferences, messages, User Content, photos, videos where supported, reports, screenshots, evidence, support communications, billing communications, refund communications, statutory-cancellation communications, privacy-request communications, appeal materials, legal notices, and other information you submit.
Where reasonably necessary for a specific verification, safety, legal, privacy, refund, statutory-cancellation, account-recovery, dispute, Service-integrity, fraud-prevention, payment-risk, moderation, or enforcement process, Cuddle may request identity-document or government-ID information from you through a secure upload flow or specific instructions.
Cuddle does not ask users to send identity-document images, government identification documents, liveness data, face templates, faceprints, facial-geometry data, fingerprints, voiceprints, biometric identifiers, biometric templates, full payment card numbers, card security codes, passwords, authentication codes, full bank credentials, private keys, wallet credentials, intimate content, information about minors, medical records, or other highly sensitive information by ordinary email, ordinary messages, profile fields, reports, appeals, support channels, or mail.
4.3 Information From Your Use of the Service
We collect information automatically when you access or use Cuddle.
This may include device, browser, IP-address, approximate-location, session, cookie, log, feature-use, communication, checkout, security, fraud-prevention, payment-risk, diagnostic, and account-integrity information.
This information may be generated by your interactions with profiles, discovery, matching or connection features, messages, visibility settings, reports, blocking tools, safety tools, checkout, billing flows, refund flows, statutory-cancellation flows, payment-dispute processes, support channels, emails, notices, Legal pages, pricing pages, account settings, secure upload flows where used, or other Service functionality.
We may collect signals relating to login patterns, device and browser changes, linked-account indicators, velocity signals, suspicious activity indicators, card-testing or payment-abuse signals, bot or automation signals, account-takeover signals, duplicate-account signals, abuse reports, moderation signals, verification-review status where used, and enforcement history.
We may use information generated from your use of the Service to assess supported-area eligibility, account ownership, age or eligibility concerns, payment authority, account integrity, fraud risk, payment risk, safety risk, legal compliance, and Service integrity.
4.4 Information From Other Users
Other users may provide information about you when they interact with you, mention you, send messages, report content or conduct, block or unmatch you, submit evidence, appeal a decision, respond to a safety or moderation process, or contact Cuddle.
This may include messages, screenshots, profile references, account identifiers, links, external usernames, payment-request concerns, off-Service conduct reports, safety concerns, scam reports, impersonation reports, harassment reports, prohibited-service reports, prohibited-payment reports, unauthorized-payment concerns, and other information reasonably related to the report, request, or interaction.
Other users may also provide information that suggests fake accounts, impersonation, scams, bots, account farms, prohibited commercial activity, prohibited services, prohibited payments, unauthorized payment use, payment abuse, account takeover, age or location evasion, verification evasion, re-registration evasion, or other misuse.
Cuddle may review information from other users together with account, device, transaction, support, verification, moderation, fraud-prevention, payment-risk, and enforcement records where reasonably necessary and permitted by law.
Information from another user may be incomplete, inaccurate, misleading, altered, or submitted in bad faith. Cuddle does not treat a user report, screenshot, statement, profile reference, or other user-submitted material as automatically true.
4.5 Information From Service Providers, Operational Vendors, and Payment Participants
We may receive information from service providers and operational vendors that help us operate, host, secure, analyze, support, moderate, communicate, process privacy requests, prevent fraud, manage payment risk, provide operational tools, or provide the Service.
These sources may include hosting providers, cloud providers, storage providers, security vendors, communications providers, email providers, customer-support tools, analytics providers, performance and debugging tools, fraud-prevention vendors, payment-risk vendors, safety vendors, moderation vendors, consent-management tools, privacy-request tools, legal-process tools, tax and accounting providers, and other operational providers.
For direct checkout purchases, we may receive limited information from authorized payment processors, payment-method providers, banks, card networks, fraud-prevention vendors, payment-risk vendors, tax providers, accounting providers, support providers, and dispute participants.
This may include transaction status, payment-method type, limited payment details, billing information, billing ZIP code, receipt identifiers, billing descriptor, authorization status, refund information, statutory-cancellation information, chargeback information, payment-dispute information, device information, IP address, risk signals, and related support communications.
Full payment card details are submitted directly through processor-hosted or processor-approved payment fields or flows and are not intended to be received or stored on Cuddle-controlled systems.
Cuddle does not currently use a third-party identity-verification vendor, government-ID verification vendor, biometric verification provider, liveness provider, facial-recognition provider, or face-matching provider.
Cuddle may use operational service providers to host, secure, store, route, log, or support Cuddle-managed review systems. Infrastructure, storage, security, support, moderation, communications, fraud-prevention, payment-risk, privacy-request, or operational vendors are not treated as third-party identity-verification vendors merely because they help Cuddle operate systems used in connection with review, support, moderation, fraud prevention, payment-risk management, or enforcement.
Cuddle does not receive liveness data, face templates, faceprints, facial-geometry data, fingerprints, voiceprints, biometric identifiers, biometric templates, or biometric verification materials from biometric verification, liveness, facial-recognition, face-matching, fingerprint-verification, or voiceprint-verification providers because Cuddle does not use those verification methods.
4.6 Information From Legal, Public, and Other Lawful Sources
We may collect information from legal, public, and other lawful sources where reasonably necessary for safety, security, fraud prevention, payment-risk management, legal compliance, dispute resolution, rights protection, account integrity, Service integrity, or enforcement.
These sources may include public records, legal processes, regulators, law-enforcement authorities, courts, government authorities, professional advisers, security researchers, rights holders, authorized representatives, payment-dispute participants, business-transfer parties, sanctions or restricted-party sources where lawful, and other sources permitted by law.
We may receive or collect information relating to subpoenas, court orders, legal notices, preservation requests, rights complaints, copyright or IP complaints, regulatory inquiries, law-enforcement requests, safety matters, fraud matters, payment disputes, chargebacks, unauthorized-transaction claims, billing-error claims, tax or accounting matters, audits, or legal claims.
We may also receive information from authorized agents, representatives, estate representatives, guardians where lawful, attorneys, or other persons acting with authority or apparent authority in connection with privacy requests, statutory-cancellation requests, refund requests, account-recovery requests, legal notices, disputes, or other processes.
Cuddle may use legal, public, and other lawful sources to help protect users, minors, Cuddle, payment participants, service providers, rights holders, and the Service.
We do not use these sources to provide credit, lending, insurance, employment, housing, brokerage, securities, banking, or other financial products or services.
4.7 Generated Records, Combined Information, and Limits
We may create records or inferences from information we collect, such as account status, eligibility indicators, supported-area indicators, safety indicators, fraud-risk indicators, payment-risk indicators, moderation decisions, enforcement decisions, support classifications, access activation or expiration status, verification-review status where used, privacy-request status, refund-request status, statutory-cancellation status, chargeback status, and payment-dispute status.
When permitted by law, we may combine information from different sources to understand account status, provide functionality, protect users, prevent fraud, manage payment risk, moderate content, respond to requests, document purchases, enforce applicable terms, comply with law, and protect Service integrity.
Cuddle may combine information from you, your use of the Service, other users, service providers, operational vendors, payment participants, fraud-prevention vendors, payment-risk vendors, safety vendors, moderation sources, legal sources, public sources, and other lawful sources for the purposes described in this Privacy Policy.
We do not rely on those signals to personalize individual prices or fees.
Cuddle does not use these records or sources to provide credit, lending, insurance, employment, housing, brokerage, securities, banking, payment facilitation, marketplace activity, money transmission, stored value, wallets, virtual credits, cryptocurrency, or other financial products or services.
Nothing in this Section authorizes prohibited services, prohibited payments, user-to-user transfers of value, adult content monetization, adult live-chat, pornography sales, sexual services, escort services, compensated dating, sugar arrangements, paid companionship, abuse, exploitation, unsafe conduct, or unlawful activity.
5. How We Use Personal Information
5.1 Overview
Cuddle uses personal information to provide, operate, secure, support, improve, personalize non-price Service experiences, protect, and enforce the Service.
We use personal information only for purposes described in this Privacy Policy, the Terms, Purchase, Billing, Cancellation & Refund Terms, Paid Features Terms, Prohibited Services, Payments & Commerce Policy, Community Guidelines, Safety Tips / Dating Safety Notice, State-Specific Terms & Cancellation Notices, Contact / Legal Notices, checkout disclosures, purchase-specific terms, product disclosures, and applicable law.
Not every purpose applies to every user, account, purchase, report, request, device, session, verification review, or interaction.
5.2 Account, Eligibility, Access, and Service Operation
We use personal information to create, authenticate, operate, recover, manage, update, and secure accounts.
This includes confirming account ownership, age eligibility, United States supported-area eligibility, state of residence where relevant, account status, access permissions, settings, notifications, language choices, visibility choices, and Service availability.
We may use account, device, browser, IP-address, approximate-location, billing, payment, support, verification, fraud-prevention, payment-risk, moderation, and enforcement information to assess eligibility, prevent unauthorized access, protect account integrity, maintain Service functionality, and enforce location, age, safety, payment, and account rules.
5.3 Profiles, Discovery, Matching, Messaging, and User-Directed Features
We use personal information to provide profile, discovery, matching or connection, messaging, visibility, preference, filtering, notification, and communication features.
This may include displaying profile information you choose to provide, showing photos or other User Content, applying your preferences and settings, supporting likes, matches or connections, routing messages, providing read receipt visibility where supported, supporting limited message deletion where available, and operating blocking, muting, unmatching, and reporting tools.
We may use information to personalize non-price Service experiences, such as discovery, recommendations, visibility, ranking, filters, prompts, settings, and feature availability. Cuddle does not use fraud-prevention, payment-risk, safety, moderation, verification, account-history, or similar risk signals to personalize the price charged to an individual user.
5.4 Safety, Moderation, Reports, and Enforcement
We use personal information to promote safety, moderate content, review reports, investigate suspected violations, prevent abuse, protect minors, respond to safety concerns, and enforce applicable terms.
This may include reviewing reports, appeals, messages, User Content, screenshots, evidence, account information, device signals, IP-address information, payment-risk signals, fraud-prevention signals, moderation records, and enforcement records.
Cuddle may use internal, manual, non-liveness photo or selfie review and identity-document or government-ID review to detect, prevent, investigate, and enforce against fake accounts, impersonation, scams, bots, account farms, prohibited commercial activity, prohibited services, prohibited payments, unauthorized payment use, payment abuse, account takeover, age or location evasion, verification evasion, re-registration evasion, and other misuse.
Cuddle does not use liveness checks, facial-feature analysis, facial recognition, facial-geometry analysis, face templates, faceprints, fingerprints, voiceprints, biometric identifiers, biometric templates, or biometric verification for the Service.
5.5 Payments, Direct Checkout, Refunds, and Payment Risk
We use personal information to support direct checkout, process one-time purchases, confirm payment authorization, provide receipts, activate and expire one-month or three-month Paid Feature access, calculate taxes where applicable, maintain accounting records, respond to billing questions, review refund requests, process statutory-cancellation requests, manage chargebacks, and handle payment disputes.
We use limited payment, transaction, device, browser, IP-address, billing, receipt, activation, expiration, refund, statutory-cancellation, chargeback, dispute, fraud-prevention, and payment-risk information to detect unauthorized payment use, card testing, payment-method testing, account takeover, refund abuse, chargeback abuse, promotional abuse, transaction laundering, prohibited payments, and related misuse.
Cuddle does not currently offer subscriptions, recurring billing, automatic renewal, automatic trial-to-paid conversion, automatic repurchase, external purchase channels, or twelve-month Paid Feature access.
Payments through Cuddle’s checkout are payments to Cuddle only for Cuddle-operated digital Service functionality. Cuddle does not use personal information to provide user-to-user payments, tips, donations, payouts, stored value, wallets, virtual credits, gift cards, cryptocurrency, money transmission, payment facilitation, marketplace activity, banking, lending, investment, brokerage, securities, insurance, credit, or other financial products or services.
5.6 Support, Communications, Notices, and Requests
We use personal information to communicate with you about the Service, your account, safety, security, purchases, receipts, access activation, access expiration, billing, refunds, statutory cancellations, payment disputes, privacy requests, reports, appeals, legal notices, policy updates, and support matters.
We may use contact information, account information, support records, request details, communication contents, attachments, routing tags, timestamps, and related records to review, route, verify, respond to, document, and resolve requests.
We may send service-related emails, in-Service notices, account notices, legal notices, purchase confirmations, receipts, billing notices, safety notices, security notices, privacy notices, and policy-update notices.
5.7 Legal Compliance, Rights Protection, and Records
We use personal information to comply with law, respond to lawful requests, preserve records, support audits, maintain tax and accounting records, enforce terms, resolve disputes, protect rights, prevent fraud, manage payment risk, protect users, protect minors, protect payment participants, protect service providers, and protect Cuddle and the Service.
We may use personal information to respond to subpoenas, court orders, regulatory requests, law-enforcement requests, emergency requests, preservation requests, intellectual-property complaints, privacy requests, chargebacks, billing-error claims, unauthorized-transaction claims, and legal claims.
We may retain records where reasonably necessary for legal compliance, tax, accounting, audit, safety, fraud prevention, payment-risk management, privacy compliance, dispute resolution, enforcement, or rights protection, as described in Section 11.
5.8 Purposes Cuddle Does Not Use Personal Information For
Cuddle does not sell personal information, private messages, sensitive personal information, or payment-related personal information.
Cuddle does not share personal information for targeted advertising, cross-context behavioral advertising, or similar advertising purposes.
Cuddle does not use personal information to provide adult content monetization, adult live-chat, pornography sales, paid sexual messaging, sexual services, escort services, compensated dating, sugar arrangements, paid companionship, paid meetings, creator monetization, user payouts, marketplace activity, payment facilitation, stored value, wallets, virtual credits, cryptocurrency, money transmission, banking, lending, investment, brokerage, securities, insurance, credit, employment, housing, or other financial products or services.
Cuddle does not use profile photos, selfie materials, identity-document images, or government-ID materials to create biometric templates, perform facial recognition, conduct liveness checks, personalize prices, rank users, match users, advertise, sell or share personal information, or provide financial products or services.
6. Profiles, Messages, User Content, and Visibility Limits
6.1 Overview
Cuddle is a social connection service. Some personal information is intended to be shown, sent, or made available to other users through profiles, discovery, matching, messaging, reports, or other Service features.
This Section explains how profile information, messages, User Content, visibility controls, recipient behavior, and safety review may affect what others can see or keep.
6.2 Profiles and User-Visible Information
Information you place in a profile may be visible to other users, depending on your settings, access level, account status, and feature availability.
Profile information may include display name, profile identifier, photos, videos where supported, prompts, bios, preferences, approximate location or distance information, interests, account indicators, verification indicators where used, and other information you choose to provide.
You should not include information in a profile that you do not want other users to see, copy, save, screenshot, record, discuss, or share outside Cuddle.
Cuddle may limit, hide, remove, reorder, label, or refuse to display profile information where necessary for safety, privacy, moderation, fraud prevention, payment-risk management, legal compliance, user protection, or Service integrity.
6.3 Messages and Communications
Messages, reactions, likes, matches, reports, blocks, read receipts where supported, limited message-deletion activity where supported, and other interactions may generate personal information.
Messages you send are visible to intended recipients and may be processed by Cuddle to deliver, store, route, secure, moderate, review, investigate, support, enforce, and maintain the Service.
Unless Cuddle expressly states otherwise for a specific feature, in-Service messaging is not end-to-end encrypted and should not be treated as a guaranteed secure channel for highly sensitive information.
Do not send full payment card numbers, passwords, authentication codes, government identification documents, intimate content, information about minors, medical information, private keys, wallet credentials, or other highly sensitive information through messages.
6.4 User Content and Prohibited Content
“User Content” includes content, information, materials, and communications you create, submit, upload, display, send, link to, or otherwise make available through Cuddle.
User Content may include profile information, photos, videos where supported, prompts, bios, messages, reactions, links, reports, appeals, support communications, rights complaints, screenshots, evidence, and other materials you provide.
You are responsible for User Content you provide. Do not upload, send, request, exchange, display, distribute, or otherwise make available pornographic or sexually explicit images or videos through the Service, whether paid or unpaid, public or private.
Cuddle may remove, restrict, preserve, review, or disclose User Content as described in this Privacy Policy, the Terms, the Community Guidelines, and applicable law.
6.5 Visibility Controls and Feature Limits
Cuddle may provide settings or Paid Features that affect discovery, visibility, filtering, read receipts, limited message deletion, incognito browsing, profile display, or other privacy-related experiences.
These tools are limited. They do not guarantee anonymity, confidentiality, invisibility, secrecy, non-discoverability, or protection from copying, screenshots, recordings, forwarding, disclosure, monitoring, or misuse.
Limited message deletion, where supported, may remove or hide eligible messages from certain Cuddle views, but it does not guarantee deletion from recipient devices, screenshots, recordings, notifications, backups, logs, safety records, legal records, or places outside Cuddle’s control.
Incognito browsing, where supported, may limit profile visibility in certain contexts but does not guarantee that you cannot be discovered, identified, inferred, or recognized.
6.6 Recipient Behavior and Off-Service Sharing
Other users may copy, save, screenshot, photograph, record, forward, publish, describe, disclose, or misuse information or communications they receive, even if doing so violates Cuddle rules or law.
Cuddle cannot control what recipients, external platforms, devices, search engines, social media services, messaging applications, payment applications, employers, family members, or other third parties do with information once it leaves the Service.
Be careful before sharing contact details, location, workplace information, travel plans, identity information, financial information, private content, or other sensitive information.
6.7 Safety, Moderation, Reports, and Records
Cuddle may process profiles, messages, User Content, metadata, reports, support communications, device signals, payment-risk signals, fraud-prevention signals, and related records for safety, moderation, fraud prevention, account security, payment-risk management, support, legal compliance, and enforcement.
If content or conduct is reported, Cuddle may review relevant information, preserve records, restrict accounts, remove content, respond to users, cooperate with service providers or authorities, or take other action permitted by law.
Cuddle does not guarantee that it will review every message, detect every violation, preserve every record, or take a particular action.
6.8 Relationship to Rights and Other Terms
Your privacy choices, visibility settings, message controls, deletion requests, account deletion requests, and statutory rights are subject to this Privacy Policy, the Terms, the Community Guidelines, the Safety Tips / Dating Safety Notice, the Purchase Terms, the Paid Features Terms, the State-Specific Terms, and applicable law.
Nothing in this Section limits any non-waivable privacy, deletion, correction, access, portability, opt-out, appeal, safety, reporting, payment, refund, statutory-cancellation, consumer-protection, court-access, or other right under applicable law.
7. Payments, Direct Checkout, Billing, Refunds, and Payment Risk
7.1 Overview
This Section explains how Cuddle processes personal information relating to direct checkout, one-time purchases, billing, receipts, refunds, statutory cancellations, chargebacks, payment disputes, fraud prevention, and payment-risk management.
Cuddle currently offers Premium and Signature only as one-month or three-month fixed-term, non-renewing purchases through Cuddle’s authorized direct checkout flow. Cuddle does not currently offer subscriptions, recurring billing, automatic renewal, automatic trial-to-paid conversion, automatic repurchase, external purchase channels, or twelve-month Paid Feature access.
Payments through Cuddle’s checkout are payments to Cuddle only for Cuddle-operated digital Service functionality. They are not payments to or for another user.
7.2 Purchase and Billing Information
If you use checkout, purchase or use Paid Features, request billing support, request a refund, submit a statutory-cancellation request, dispute a charge, or participate in a chargeback or payment-dispute process, Cuddle may process purchase-related and billing-related personal information.
This may include access level, one-month or three-month access period, price, currency, applicable taxes or fees, purchase date, authorization status, activation date, expiration date and time, receipt information, billing descriptor, payment method type, limited payment method details where available, billing ZIP code, transaction identifiers, refund records, statutory-cancellation records, chargeback records, payment-dispute records, device information, browser information, IP-address information, fraud-prevention signals, payment-risk signals, and related support communications.
Full payment card details are submitted directly through processor-hosted or processor-approved payment fields or flows and are not intended to be received or stored on Cuddle-controlled systems.
7.3 Payment Participants and Processing
Cuddle may use authorized payment processors, payment-method providers, banks, card networks, fraud-prevention vendors, payment-risk vendors, tax providers, accounting providers, support providers, professional advisers, and dispute participants to support direct checkout and related billing, refund, statutory-cancellation, chargeback, and payment-dispute processes.
Payment participants may process information under their own terms, privacy policies, security practices, network rules, bank requirements, dispute procedures, and legal obligations. They may approve, decline, delay, authenticate, refund, reverse, restrict, or require additional information for a transaction.
7.4 How We Use Payment-Related Information
Cuddle uses payment-related personal information to process one-time purchases, confirm payment authorization, provide receipts, activate and expire Paid Feature access, calculate taxes where applicable, maintain tax and accounting records, respond to billing questions, review refund requests, process statutory-cancellation requests, respond to chargebacks, handle payment disputes, prevent fraud, manage payment risk, comply with law, and enforce applicable terms.
Cuddle may use payment, transaction, device, browser, IP-address, billing, receipt, activation, expiration, refund, statutory-cancellation, chargeback, dispute, fraud-prevention, payment-risk, account, support, moderation, verification-review, and enforcement records to detect, prevent, investigate, and respond to unauthorized payment use, card testing, payment-method testing, account takeover, refund abuse, chargeback abuse, promotional abuse, prohibited payments, transaction laundering, sanctions risk, and related misuse.
7.5 Payment Risk and Transaction Controls
Cuddle may decline, delay, cancel, reverse, refund, restrict, review, or condition a transaction; block or restrict a payment method; require additional verification; preserve records; or restrict Paid Features where reasonably necessary for fraud prevention, payment-risk management, legal compliance, safety, account integrity, Service integrity, or enforcement.
These controls may apply before, during, or after checkout and may involve information from Cuddle, payment participants, fraud-prevention vendors, payment-risk vendors, service providers, lawful authorities, or other lawful sources.
7.6 Refunds, Statutory Cancellations, and Disputes
Purchase, refund, statutory-cancellation, chargeback, billing-error, unauthorized-transaction, and payment-dispute rights and procedures are described in the Purchase, Billing, Cancellation & Refund Terms, State-Specific Terms & Cancellation Notices, checkout disclosures, purchase-specific terms, payment-participant rules, and applicable law.
For billing questions, refund requests, duplicate-charge concerns, unauthorized-charge concerns, chargebacks, or payment disputes, contact billing@cuddle-global.com. For statutory cancellation requests or another cancellation right provided by law, contact cancellations@cuddle-global.com.
7.7 Sensitive Information and Secure Upload Limits
Do not send full payment card numbers, card security codes, passwords, authentication codes, full bank credentials, identity-document images, government identification documents, liveness data, face templates, faceprints, facial-geometry data, fingerprints, voiceprints, biometric identifiers, biometric templates, private keys, wallet credentials, intimate content, information about minors, medical records, or other highly sensitive information by ordinary email, ordinary messages, profile fields, reports, appeals, support channels, or mail.
When Cuddle needs identity-document or government-ID information for a specific billing, refund, statutory-cancellation, chargeback, payment-dispute, fraud-prevention, payment-risk, safety, legal, privacy, moderation, or enforcement process, Cuddle will provide a secure upload flow or specific instructions for that process.
Cuddle does not request liveness data, face templates, faceprints, facial-geometry data, fingerprints, voiceprints, biometric identifiers, biometric templates, or biometric verification materials for ordinary billing, refund, statutory-cancellation, chargeback, payment-dispute, or payment-risk review.
7.8 Limits on Payment-Related Uses
Cuddle does not use payment-related personal information to provide user-to-user payments, tips, donations, payouts, stored value, wallets, virtual credits, gift cards, cryptocurrency, money transmission, payment facilitation, marketplace activity, banking, lending, investment, brokerage, securities, insurance, credit, or other financial products or services.
Cuddle does not use payment-related personal information to enable adult content monetization, adult live-chat, pornography sales, paid sexual messaging, sexual services, escort services, compensated dating, sugar arrangements, paid companionship, paid meetings, creator monetization, or prohibited payments.
Cuddle does not use fraud-prevention, payment-risk, safety, moderation, verification, account-history, or similar risk signals to personalize the price charged to an individual user.
8. Sensitive Information, Verification, Location, and Identity-Document Review
8.1 Overview
Cuddle may process sensitive information only where reasonably necessary for the Service, your request, safety, security, fraud prevention, payment-risk management, internal verification, legal compliance, Service integrity, moderation, enforcement, or another purpose described in this Privacy Policy.
Not every user is asked to provide sensitive information. Not every review involves photo or selfie materials, identity-document information, government identification information, precise geolocation, or another protected category.
Where law requires notice, consent, withdrawal, limitation, deletion, appeal, retention information, or another protection for sensitive information, Cuddle will provide it to the extent required.
Cuddle may use internal, manual, non-liveness photo or selfie review and identity-document or government-ID review to help prevent fake accounts, impersonation, scams, bots, account farms, prohibited commercial activity, prohibited services, prohibited payments, unauthorized payment use, payment abuse, account takeover, age or location evasion, verification evasion, re-registration evasion, and other misuse.
Cuddle does not currently use a third-party identity-verification vendor, government-ID verification vendor, biometric verification provider, liveness provider, facial-recognition provider, or face-matching provider.
Cuddle does not use liveness checks, facial-feature analysis, facial recognition, facial-geometry analysis, face templates, faceprints, fingerprints, voiceprints, biometric identifiers, biometric templates, or biometric verification for the Service.
8.2 Sensitive Information We May Process
Sensitive information may include sensitive personal information, sensitive data, precise geolocation where used, photo or selfie materials where used for internal manual review, identity-document information where used, identity-document images where used, government identification information where used, government identification documents where used, account credentials, payment-related information, communication contents, information about sex life or sexual orientation if voluntarily provided, health-related information provided in support or safety contexts, information about minors submitted in safety or legal contexts, and other protected categories under applicable law.
Cuddle does not require information about sex life or sexual orientation to purchase Paid Features. If voluntarily provided, that information is processed only for user-directed profile, preference, safety, support, legal-rights, or similar functionality and does not authorize adult content, sexual services, prohibited payments, or prohibited activity.
Cuddle does not ask users to send identity-document images, government identification documents, photo or selfie materials for review, precise geolocation, or other highly sensitive information through ordinary email, ordinary messages, profile fields, reports, appeals, support channels, or mail.
When Cuddle needs identity-document or government-ID information for a specific verification, safety, legal, privacy, refund, statutory-cancellation, account-recovery, dispute, Service-integrity, fraud-prevention, payment-risk, moderation, or enforcement process, Cuddle will provide a secure upload flow or specific instructions for that process.
If a user sends highly sensitive information without being asked, Cuddle may process it only as reasonably necessary to route, secure, restrict, delete, respond to, preserve, investigate, enforce, or comply with law in connection with the relevant request, report, dispute, safety matter, or legal obligation.
8.3 Verification and Identity-Related Processing
Cuddle may request or process information to help confirm age, identity-document review, account ownership, United States supported-area location, state of residence, payment authority, billing details, eligibility, safety, fraud risk, payment risk, account integrity, Service integrity, legal compliance, or request validity.
Verification may include email or phone verification, age confirmation, internal manual non-liveness photo or selfie review, identity-document review, government-ID review, billing verification, payment-method verification, device checks, IP-address review, approximate-location review, state or residency confirmation, account-history review, transaction review, risk-signal review, support-based account-ownership review, or other non-biometric verification information.
Cuddle may use internal, manual, non-liveness photo or selfie review and identity-document or government-ID review to detect, prevent, investigate, and enforce against fake accounts, impersonation, scams, bots, account farms, prohibited commercial activity, prohibited services, prohibited payments, unauthorized payment use, payment abuse, account takeover, age or location evasion, verification evasion, re-registration evasion, and other misuse.
Cuddle does not currently use a third-party identity-verification vendor, government-ID verification vendor, biometric verification provider, liveness provider, facial-recognition provider, or face-matching provider for this review.
Cuddle does not use liveness checks, facial-feature analysis, facial recognition, facial-geometry analysis, face templates, faceprints, fingerprints, voiceprints, biometric identifiers, biometric templates, or biometric verification for the Service.
Cuddle does not use photo, selfie, identity-document, or government-ID materials to create biometric templates, perform facial recognition, conduct liveness checks, personalize prices, rank users, match users, advertise, sell or share personal information, or provide credit, lending, banking, insurance, securities, brokerage, payment facilitation, marketplace activity, or other financial products or services.
Where verification involves photo or selfie materials, identity-document images, government identification information, precise geolocation, sensitive personal information, sensitive data, or other protected information, Cuddle processes that information as described in this Privacy Policy, applicable notices, consent requirements where required, retention rules, deletion rights, and applicable law.
Unless Cuddle expressly states otherwise for a specific feature, program, state, or user category, Cuddle does not verify every user and does not conduct comprehensive identity verification, criminal background checks, sex-offender registry checks, relationship-status checks, marital-status checks, intention checks, employment checks, financial checks, health checks, immigration checks, social-media checks, or safety clearances on every user.
Verification does not guarantee that a user is safe, truthful, eligible, available, compatible, verified, trustworthy, or appropriate to interact with.
8.4 Location, Residency, and Supported Area
Cuddle offers and markets the Service only to eligible adults located in the fifty states and the District of Columbia.
Cuddle may process IP address, approximate location, billing ZIP code, state of residence, account information, device signals, payment information, support information, verification information where used, and related risk signals to assess supported-area eligibility, state-specific notices, privacy rights, statutory-cancellation rights, tax treatment, fraud prevention, sanctions compliance, payment-risk management, account integrity, and Service integrity.
Cuddle does not use precise geolocation unless a feature or process requires it and required notice or consent is provided.
If location information suggests use outside the supported area, Cuddle may restrict access, decline checkout, request verification, limit features, preserve records, block payment methods, suspend or terminate an account, or take other action permitted by applicable terms and law.
A supported-area check, residency check, billing ZIP code review, IP-address review, device-signal review, or location-related review does not guarantee that a user is physically located where they claim to be, remains in a supported area, or is safe or appropriate to interact with.
8.5 No Liveness, Facial-Recognition, or Biometric Verification
Cuddle may use internal, manual, non-liveness photo or selfie review and identity-document or government-ID review for age confirmation, account ownership, supported-area eligibility, safety, fraud prevention, payment-risk management, account recovery, privacy-request verification, refund or statutory-cancellation review, dispute review, legal compliance, Service integrity, moderation, and enforcement against fake accounts, impersonation, scams, bots, account farms, prohibited commercial activity, prohibited services, prohibited payments, and other misuse.
Cuddle does not currently use a third-party identity-verification vendor, government-ID verification vendor, biometric verification provider, liveness provider, facial-recognition provider, or face-matching provider for this review.
Cuddle does not use liveness checks, facial-feature analysis, facial recognition, facial-geometry analysis, face templates, faceprints, fingerprints, voiceprints, biometric identifiers, biometric templates, or biometric verification for the Service.
Cuddle does not use photo, selfie, identity-document, or government-ID materials to create biometric templates, perform facial recognition, conduct liveness checks, personalize prices, rank users, match users, advertise, sell or share personal information, or provide credit, lending, banking, insurance, securities, brokerage, payment facilitation, marketplace activity, or other financial products or services.
Cuddle does not request liveness data, face templates, faceprints, facial-geometry data, fingerprints, voiceprints, biometric identifiers, biometric templates, or biometric verification materials for ordinary account verification.
If Cuddle later introduces liveness checks, facial recognition, facial-feature analysis, facial-geometry analysis, biometric identifiers, biometric templates, biometric verification, fingerprint verification, voiceprint verification, face matching, or a provider that performs those functions for Cuddle, Cuddle will update this Privacy Policy and applicable notices before use and will provide any notice, consent, retention, deletion, opt-out, appeal, or other rights required by law.
8.6 Consent, Refusal, and Withdrawal
Where consent is required for sensitive information, identity-document information, government identification information, precise geolocation, or another protected category that Cuddle processes, Cuddle will request consent before the relevant processing.
You may decline to provide requested sensitive information, but Cuddle may be unable to create or recover an account, complete verification, process a privacy request, review a refund or statutory-cancellation request, complete checkout, provide a feature, investigate a report, resolve a dispute, maintain access, or complete another process where the information is reasonably necessary and law permits that result.
Where law permits withdrawal of consent, you may withdraw consent using the method provided. Withdrawal may not affect earlier processing, processing required by law, or processing reasonably necessary for legal claims, safety, fraud prevention, payment-risk management, security, accounting, audit, dispute resolution, tax, legal compliance, or enforcement.
A refusal or withdrawal does not authorize use of the Service by an ineligible person, use from an unsupported location, use of an unauthorized payment method, evasion of safety or fraud controls, prohibited services, prohibited payments, or another violation of applicable terms or law.
8.7 Disclosure, Retention, and Protection
Cuddle may disclose sensitive information to service providers, payment participants, fraud-prevention vendors, payment-risk vendors, safety vendors, moderation vendors, security vendors, support providers, professional advisers, regulators, courts, law enforcement, emergency services, or other lawful recipients where reasonably necessary and permitted by law.
Cuddle may use operational service providers to host, secure, store, route, log, or support Cuddle-managed review systems. Infrastructure, storage, security, support, moderation, communications, fraud-prevention, payment-risk, privacy-request, or operational vendors are not treated as third-party identity-verification vendors merely because they help Cuddle operate systems used in connection with review, support, moderation, or enforcement.
Cuddle does not currently disclose identity-document images or government identification documents to a third-party identity-verification vendor or government-ID verification vendor because Cuddle does not currently use one.
Cuddle does not disclose liveness data, face templates, faceprints, facial-geometry data, fingerprints, voiceprints, biometric identifiers, biometric templates, or biometric verification materials to biometric verification, liveness, facial-recognition, face-matching, fingerprint-verification, or voiceprint-verification providers because Cuddle does not use those verification methods.
Cuddle retains sensitive information only as reasonably necessary for account integrity, internal verification, safety, fraud prevention, payment-risk management, legal compliance, tax, accounting, audit, dispute resolution, privacy-request processing, refund or statutory-cancellation review, moderation, enforcement, or another lawful purpose described in this Privacy Policy, unless a shorter or longer period is required by law.
Cuddle may retain records showing that a verification, review, request, consent, withdrawal, deletion, limitation, appeal, dispute, refund, statutory-cancellation request, safety review, fraud review, or enforcement action occurred, where reasonably necessary to document compliance, prevent fraud, manage payment risk, protect users, resolve disputes, or comply with law.
Cuddle uses reasonable administrative, technical, and organizational safeguards designed to protect sensitive information. No website, application, network, database, transmission, device, browser, email account, payment method, upload flow, review tool, or storage system is perfectly secure.
8.8 Relationship to Other Rights and Terms
Sensitive information rights may vary by state. Section 13 explains privacy requests, appeals, opt-outs, authorized-agent requests, sensitive-information choices, deletion requests, correction requests, access requests, and other privacy rights.
This Section is supplemented by the Terms, Criminal Background Screening Disclosure, Safety Tips / Dating Safety Notice, Purchase Terms, Paid Features Terms, State-Specific Terms, Cookie / Tracking Policy, Contact / Legal Notices, checkout disclosures, purchase-specific terms, product disclosures, and applicable law.
If another Cuddle term, state-specific notice, privacy-rights notice, checkout disclosure, purchase-specific term, court rule, or applicable law provides a more specific or greater non-waivable right, that term, notice, disclosure, rule, or law controls to the extent required.
Nothing in this Section limits any non-waivable privacy, consent, deletion, correction, access, portability, opt-out, appeal, payment, refund, statutory-cancellation, safety, reporting, consumer-protection, accessibility, anti-discrimination, data-security, breach-notification, court-access, public-injunctive-relief, or other right under applicable law.
No verification process, sensitive-information process, privacy response, support response, refund response, statutory-cancellation response, safety review, moderation review, service-provider relationship, or third-party process authorizes prohibited services, prohibited payments, user-to-user transfers of value, adult content monetization, adult live-chat, pornography sales, sexual services, escort services, compensated dating, sugar arrangements, paid companionship, payment facilitation, marketplace activity, financial services, abuse, exploitation, unsafe conduct, or unlawful activity.
9. How We Disclose Personal Information
9.1 Overview
Cuddle may disclose personal information where reasonably necessary to provide, operate, secure, support, improve, protect, or enforce the Service; process requests; complete direct checkout purchases; comply with law; resolve disputes; prevent fraud; manage payment risk; moderate content; protect users; protect minors; protect Cuddle; support service providers; support payment participants; or protect others.
Not every disclosure applies to every user, account, purchase, report, request, device, session, review, or interaction.
We disclose only the information reasonably relevant to the purpose and subject to applicable law, contractual safeguards, privacy choices, sensitive-information limits, and non-waivable rights.
Cuddle may use internal, manual, non-liveness photo or selfie review and identity-document or government-ID review for limited verification, safety, fraud-prevention, payment-risk, account-integrity, legal, privacy, refund, statutory-cancellation, dispute, moderation, or enforcement purposes, as described in this Privacy Policy.
Cuddle does not currently use or disclose personal information to a third-party identity-verification vendor, government-ID verification vendor, biometric verification provider, liveness provider, facial-recognition provider, or face-matching provider.
Cuddle does not disclose personal information to enable liveness checks, facial-feature analysis, facial recognition, facial-geometry analysis, face-template creation, faceprint creation, fingerprint verification, voiceprint verification, biometric-identifier processing, biometric-template processing, or biometric verification for the Service.
9.2 Other Users and User-Directed Disclosures
Cuddle discloses information to other users when you choose to make information visible or send information through the Service.
This may include profile information, photos, videos where supported, prompts, display names, preferences, approximate location or distance information where supported, likes, matches or connections, messages, reactions, read receipt information where supported, reports or blocking effects where visible, account indicators where supported, verification indicators where used, and other information you direct Cuddle to show or send.
Other users are not Cuddle service providers. They may copy, save, screenshot, photograph, record, forward, disclose, publish, describe, or misuse information they receive, even if doing so violates Cuddle rules or law.
Cuddle cannot control recipient behavior outside the Service.
You should not treat in-Service messages, profile fields, reports, appeals, ordinary support channels, or communications with other users as secure channels for full payment card numbers, card security codes, passwords, authentication codes, full bank credentials, private keys, wallet credentials, identity-document images, government identification documents, liveness data, face templates, faceprints, facial-geometry data, fingerprints, voiceprints, biometric identifiers, biometric templates, medical records, information about minors, intimate content, or other highly sensitive information.
9.3 Service Providers and Operational Vendors
We disclose personal information to service providers and operational vendors that help Cuddle operate, host, secure, analyze, support, moderate, communicate, process privacy requests, prevent fraud, manage payment risk, provide operational tools, provide the Service, or perform other lawful business functions for Cuddle.
These may include hosting and cloud providers, storage providers, security vendors, communications providers, email providers, customer-support tools, analytics providers, performance and debugging tools, fraud-prevention vendors, payment-risk vendors, moderation vendors, safety vendors, privacy-request tools, consent-management tools, legal-process vendors, tax and accounting providers, infrastructure providers, logging tools, backup and disaster-recovery providers, and other operational providers.
Cuddle may use operational service providers to host, secure, store, route, log, or support Cuddle-managed review systems. Infrastructure, storage, security, support, moderation, communications, fraud-prevention, payment-risk, privacy-request, legal-process, tax, accounting, or other operational vendors are not treated as third-party identity-verification vendors merely because they help Cuddle operate systems used in connection with internal manual review, support, moderation, fraud prevention, payment-risk management, privacy-request processing, dispute processing, or enforcement.
Cuddle does not currently use a third-party identity-verification vendor, government-ID verification vendor, biometric verification provider, liveness provider, facial-recognition provider, or face-matching provider.
Cuddle does not disclose identity-document images or government identification documents to a third-party identity-verification vendor or government-ID verification vendor because Cuddle does not currently use one.
Cuddle does not disclose liveness data, face templates, faceprints, facial-geometry data, fingerprints, voiceprints, biometric identifiers, biometric templates, or biometric verification materials to biometric verification, liveness, facial-recognition, face-matching, fingerprint-verification, or voiceprint-verification providers because Cuddle does not use those verification methods.
Service providers and operational vendors may process information to perform services for Cuddle, comply with their legal obligations, protect their systems, prevent fraud, maintain records, support Cuddle’s lawful instructions, and perform functions permitted by their agreements with Cuddle and applicable law.
We require appropriate contractual, technical, and organizational safeguards where required by law.
We do not authorize service providers or operational vendors to use personal information for their own independent marketing, targeted advertising, user monetization, adult content monetization, prohibited payment activity, payment facilitation, marketplace activity, or prohibited services.
A provider may use information for its own security, fraud prevention, legal compliance, audit, billing, service-maintenance, and service-improvement purposes only where permitted by its agreement with Cuddle and applicable law.
9.4 Payment Participants, Billing, Refunds, and Chargebacks
For direct checkout purchases, Cuddle may disclose personal information to authorized payment processors, payment-method providers, banks, card networks, fraud-prevention vendors, payment-risk vendors, tax providers, accounting providers, support providers, professional advisers, regulators, courts, law enforcement, and dispute participants.
Disclosed information may include account identifiers, billing information, payment method type, limited payment details, transaction amount, currency, taxes or fees, purchase date, access level, one-month or three-month access period, activation and expiration information, receipt identifiers, billing descriptor, refund information, statutory-cancellation information, chargeback information, payment-dispute information, device information, browser information, IP address, session information, risk signals, support communications, and related records.
Full payment card details are submitted directly through processor-hosted or processor-approved payment fields or flows and are not intended to be received or stored on Cuddle-controlled systems.
Payment processors, payment-method providers, banks, card networks, and related participants may process information under their own terms, privacy policies, security practices, network rules, bank requirements, dispute procedures, and legal obligations.
Cuddle discloses payment-related personal information only as reasonably necessary for direct checkout, payment authorization, receipts, Paid Feature activation and expiration, billing support, refunds, statutory cancellations, chargebacks, payment disputes, fraud prevention, payment-risk management, tax, accounting, audit, legal compliance, dispute resolution, and rights protection.
Cuddle does not disclose payment information to provide user-to-user payments, tips, donations, payouts, stored value, wallets, virtual credits, gift cards, cryptocurrency, money transmission, payment facilitation, marketplace activity, banking, lending, investment, brokerage, securities, insurance, credit, employment, housing, or other financial products or services.
Cuddle does not disclose payment information to process payments for adult content monetization, adult live-chat, pornography sales, paid sexual messaging, sexual services, escort services, compensated dating, sugar arrangements, paid companionship, paid meetings, creator monetization, or other prohibited services.
9.5 Safety, Moderation, Reports, and User Protection
We may disclose personal information to review reports, respond to safety issues, moderate content, enforce terms, prevent scams, investigate abuse, protect minors, address non-consensual content, respond to account takeover, prevent fraud, manage payment risk, protect users, protect Cuddle, protect payment participants, protect service providers, or protect the Service.
Recipients may include safety vendors, moderation vendors, security providers, fraud-prevention vendors, payment-risk vendors, support providers, affected users where appropriate, payment participants, professional advisers, regulators, law enforcement, emergency services, courts, or other lawful recipients.
Information disclosed for these purposes may include account identifiers, profile information, messages, User Content, reports, screenshots, evidence, support communications, device information, IP-address information, approximate-location information, payment-risk signals, fraud-prevention signals, moderation records, enforcement records, transaction information, and other information reasonably relevant to the report, risk, request, or legal obligation.
We may disclose limited information to a reported or reporting user when necessary to explain an action, provide a notice, request information, support an appeal, protect users, prevent abuse, or comply with law.
We do not guarantee disclosure of outcomes, evidence, enforcement logic, safety logic, fraud-prevention logic, payment-risk logic, moderation logic, or internal records.
Cuddle may withhold information where disclosure could compromise safety, privacy, security, investigations, fraud prevention, payment-risk management, legal compliance, confidential information, trade secrets, or Service integrity.
No safety, moderation, reporting, enforcement, or user-protection disclosure authorizes prohibited services, prohibited payments, user-to-user transfers of value, adult content monetization, adult live-chat, pornography sales, sexual services, escort services, compensated dating, sugar arrangements, paid companionship, payment facilitation, marketplace activity, financial services, abuse, exploitation, unsafe conduct, or unlawful activity.
9.6 Legal, Regulatory, Compliance, and Rights Protection
Cuddle may disclose personal information where reasonably necessary to comply with laws, regulations, subpoenas, court orders, legal process, regulatory requests, law-enforcement requests, tax obligations, accounting obligations, audit requirements, sanctions obligations, reporting obligations, preservation duties, emergency requests, or other lawful requirements.
We may also disclose information to establish, exercise, or defend legal rights; enforce terms; respond to disputes, chargebacks, privacy appeals, rights complaints, intellectual-property complaints, arbitration notices, Notices of Dispute, regulatory inquiries, law-enforcement requests, safety matters, fraud matters, payment disputes, unauthorized-transaction claims, billing-error claims, or legal claims; protect personal information; prevent fraud; manage payment risk; protect users; protect minors; protect Cuddle; protect payment participants; protect service providers; and protect the Service.
Recipients may include courts, regulators, law enforcement, government authorities, payment participants, professional advisers, insurers, auditors, authorized representatives, rights holders, security researchers, emergency services, or other lawful recipients.
Cuddle may disclose information where Cuddle reasonably believes disclosure is necessary to prevent or address imminent harm, protect a person from physical danger, respond to suspected child exploitation or minor-safety risks, prevent fraud, prevent payment abuse, preserve evidence, or comply with applicable law.
Cuddle may challenge, narrow, delay, or decline a request where permitted by law and where Cuddle reasonably determines that doing so is appropriate.
Nothing in this Section limits any non-waivable privacy, safety, reporting, consumer-protection, payment, refund, statutory-cancellation, billing-error, unauthorized-transaction, chargeback, data-security, breach-notification, court-access, public-injunctive-relief, appeal, intellectual-property, accessibility, anti-discrimination, or other right under applicable law.
9.7 Business Transfers and Corporate Transactions
Cuddle may disclose or transfer personal information in connection with a financing, investment, merger, acquisition, reorganization, sale of assets, bankruptcy, due diligence review, change of control, affiliate transfer, provider transition, restructuring, or similar lawful transaction.
Recipients may include potential or actual buyers, investors, lenders, acquirers, affiliates, successors, professional advisers, auditors, insurers, financing sources, service providers, operational vendors, and other participants involved in the transaction.
The information disclosed or transferred may include account information, profile information, purchase records, support records, technical records, fraud-prevention records, payment-risk records, moderation records, legal records, and other information reasonably relevant to the transaction.
Any transfer remains subject to this Privacy Policy, applicable notices, contractual safeguards, and applicable law.
If a different privacy practice will apply after a transaction, Cuddle will provide notice and choices where required by law.
No business transfer authorizes prohibited services, prohibited payments, user-to-user transfers of value, adult content monetization, adult live-chat, pornography sales, sexual services, escort services, compensated dating, sugar arrangements, paid companionship, payment facilitation, marketplace activity, stored value, wallets, virtual credits, cryptocurrency, money transmission, financial services, abuse, exploitation, unsafe conduct, or unlawful activity.
9.8 No Sale, No Targeted Advertising Sharing, and No Prohibited Use
Cuddle does not sell personal information, private messages, sensitive personal information, or payment-related personal information.
Cuddle does not share personal information for targeted advertising, cross-context behavioral advertising, or similar advertising purposes.
Cuddle does not disclose personal information to enable adult content monetization, adult live-chat, pornography sales, paid sexual messaging, sexual services, escort services, compensated dating, sugar arrangements, paid companionship, paid meetings, creator monetization, user-to-user transfers of value, tips, donations, payouts, stored value, wallet balances, virtual credits, gift cards, payment facilitation, marketplace activity, money transmission, cryptocurrency services, banking, lending, investment, brokerage, securities, insurance, employment, housing, credit, or other financial products or services.
Cuddle does not disclose personal information to enable liveness checks, facial recognition, face matching, biometric identifiers, biometric templates, or biometric verification for the Service.
If Cuddle changes these practices in a way that requires notice, consent, or opt-out rights, Cuddle will provide them as required by law.
We may disclose aggregated or de-identified information that does not identify you, where permitted by law.
We maintain and use aggregated or de-identified information for analytics, safety research, fraud prevention, payment-risk analysis, Service improvement, business planning, reporting, legal compliance, and similar lawful purposes.
Where information is de-identified, Cuddle will maintain and use it in de-identified form and will not attempt to reidentify it except as permitted by law.
9.9 Relationship to Rights and Other Terms
Your privacy rights, choices, opt-outs, deletion requests, correction requests, access requests, portability requests, appeals, sensitive-information choices, consent choices, and authorized-agent requests are described in Section 13.
This Section is supplemented by the Terms, Purchase Terms, Paid Features Terms, Prohibited Services, Payments & Commerce Policy, Community Guidelines, Safety Tips / Dating Safety Notice, Criminal Background Screening Disclosure, State-Specific Terms, Cookie / Tracking Policy, Copyright / IP Complaints Policy, Contact / Legal Notices, checkout disclosures, purchase-specific terms, product disclosures, and applicable law.
The Privacy Policy controls personal-information processing. The Purchase Terms control purchases, billing, refunds, statutory cancellations, chargebacks, and payment disputes. The Prohibited Services, Payments & Commerce Policy controls prohibited services, prohibited payments, commerce, monetization, payment facilitation, marketplace activity, financial services, and user-to-user transfers of value. The State-Specific Terms and applicable law control non-waivable state-specific rights.
If another Cuddle term, state-specific notice, privacy-rights notice, checkout disclosure, purchase-specific term, court rule, or applicable law provides a more specific or greater non-waivable right, that term, notice, disclosure, rule, or law controls to the extent required.
Nothing in this Section limits any non-waivable privacy, payment, refund, statutory-cancellation, safety, reporting, consumer-protection, accessibility, anti-discrimination, data-security, breach-notification, court-access, public-injunctive-relief, consent, opt-out, appeal, authorized-agent, intellectual-property, or other right under applicable law.
No disclosure, service-provider relationship, operational-vendor relationship, payment-participant relationship, safety review, moderation review, fraud-prevention process, payment-risk process, legal process, business transfer, privacy response, support response, refund response, statutory-cancellation response, or third-party process authorizes prohibited services, prohibited payments, user-to-user transfers of value, adult content monetization, adult live-chat, pornography sales, sexual services, escort services, compensated dating, sugar arrangements, paid companionship, payment facilitation, marketplace activity, financial services, abuse, exploitation, unsafe conduct, or unlawful activity.
10. Cookies, Tracking, Analytics, Communications, and Preferences
10.1 Overview
Cuddle may use cookies, pixels, tags, scripts, SDKs, local storage, session storage, device identifiers, browser identifiers, analytics tools, security tools, fraud-prevention tools, payment-risk tools, checkout tools, communications tools, consent-management tools, preference-management tools, and similar technologies in connection with the Service.
This Section summarizes those technologies. The Cookie / Tracking Policy provides more specific information and controls cookie-specific subjects to the extent it applies.
10.2 Why We Use These Technologies
We use cookies and similar technologies to operate the Service, maintain sessions, authenticate users, remember settings, support account security, route requests, support privacy and cookie choices, provide notices, support checkout, deliver one-time purchase records, activate and expire Paid Features, measure performance, debug errors, prevent abuse, detect fraud, manage payment risk, comply with law, and maintain Service integrity.
We may also use these technologies to understand how users interact with profiles, discovery, messaging, reports, support tools, Legal pages, pricing pages, checkout flows, emails, notices, and account settings.
10.3 Categories of Technologies
Strictly necessary technologies help the Service function. They may support login, authentication, session management, security, fraud prevention, checkout security, privacy choices, account settings, support, and legal notices.
Analytics and performance technologies help us understand Service use, diagnose errors, measure reliability, improve usability, test lawful product experiences, and maintain operational records.
Communications technologies may help deliver, secure, measure, route, or document account, safety, security, privacy, billing, refund, statutory-cancellation, payment-dispute, access-expiration, enforcement, appeal, legal, and policy communications.
Consent and preference technologies help remember cookie choices, privacy choices, communication preferences, opt-outs, and state-specific choices where required.
10.4 Third-Party Providers
Some technologies are provided by Cuddle. Others may be provided by service providers, such as hosting, analytics, security, fraud-prevention, payment-risk, checkout, communications, support, consent-management, privacy-request, or similar providers.
These providers may process information under their own privacy policies, security practices, legal obligations, or agreements with Cuddle.
Cuddle does not authorize providers to use personal information for their own targeted advertising, user monetization, adult content monetization, payment facilitation, marketplace activity, or prohibited services.
10.5 Choices and Controls
Depending on your state, device, browser, and the technologies used, you may have choices through cookie banners, preference tools, account settings, browser settings, device settings, email settings, or privacy-request methods.
Blocking or deleting some technologies may affect login, account security, fraud prevention, payment-risk review, checkout, privacy choices, support, notifications, or other Service functionality.
Where required by law, Cuddle will honor applicable opt-out, consent, withdrawal, browser, device, and universal opt-out signal choices, including Global Privacy Control where required and technically feasible, and valid applicable user instructions.
10.6 Communications Preferences
Cuddle may send service-related communications that are necessary or appropriate for your account, security, safety, privacy, billing, purchase, refund, statutory-cancellation, access-expiration, payment-dispute, enforcement, appeal, legal, or policy matters.
Marketing communications, if any, may be subject to opt-out choices required by law. Opting out of marketing does not prevent service-related, transactional, security, safety, legal, privacy, billing, purchase, dispute, enforcement, or policy communications.
10.7 No Sale, No Targeted Advertising, and Other Limits
Cuddle does not sell personal information, private messages, sensitive personal information, or payment-related personal information.
Cuddle does not share personal information for targeted advertising or cross-context behavioral advertising.
Cuddle does not use cookies, tracking technologies, analytics technologies, communications technologies, security technologies, fraud-prevention technologies, payment-risk technologies, checkout technologies, consent-management technologies, or related records to provide user-to-user payments, stored value, wallets, virtual credits, cryptocurrency, payment facilitation, marketplace activity, financial services, adult content monetization, adult live-chat, pornography sales, sexual services, escort services, compensated dating, sugar arrangements, paid companionship, or other prohibited services.
Nothing in this Section limits any non-waivable privacy, cookie, consent, opt-out, access, deletion, correction, portability, appeal, payment, refund, statutory-cancellation, safety, consumer-protection, accessibility, anti-discrimination, data-security, breach-notification, court-access, or other right under applicable law.
10.8 Relationship to Other Terms
This Section is supplemented by the Cookie / Tracking Policy, Terms, Purchase Terms, Paid Features Terms, Contact / Legal Notices, State-Specific Terms, checkout disclosures, product disclosures, and applicable law.
The Cookie / Tracking Policy controls cookie-specific categories, choices, retention, provider roles, and universal opt-out signal procedures. This Privacy Policy controls personal-information processing generally. More specific notices and applicable law control the matters they address, including state-specific notices, legally required choices, and rights.
11. Retention, Deletion, Backups, and Legal Records
11.1 Overview
Cuddle retains personal information for as long as reasonably necessary to provide, operate, secure, support, improve, and enforce the Service; process requests; document purchases; comply with law; resolve disputes; prevent fraud; manage payment risk; protect users; and maintain business, tax, accounting, audit, safety, security, and legal records.
Retention periods vary depending on the type of information, purpose of collection, account status, purchase history, reports, disputes, legal obligations, user requests, operational needs, and applicable law.
11.2 Account, Profile, Message, and User Content Retention
We may retain account information, profile information, preferences, settings, messages, User Content, reports, blocks, moderation records, support communications, and related metadata while your account is active or as otherwise needed for the purposes described in this Privacy Policy.
If you delete content or use a limited message-deletion feature, Cuddle may remove or hide the content from certain Service views, but deletion may not be immediate, complete, or universal. Copies may remain in recipient accounts, recipient devices, screenshots, recordings, notifications, backups, logs, safety records, legal records, or locations outside Cuddle’s control.
11.3 Account Deletion and Privacy Deletion Requests
You may request account deletion through methods Cuddle makes available. You may also submit privacy-law deletion requests as described in Section 13.
Account deletion may disable access and remove certain profile information from active display. It does not automatically delete every record associated with your account, messages, purchases, reports, support matters, or legal obligations.
Cuddle may retain information after account deletion where reasonably necessary or permitted for security, fraud prevention, payment-risk management, safety, moderation, dispute resolution, legal compliance, tax, accounting, audit, records management, enforcement, business operations, or protection of users and the Service.
A deletion request may not affect information already disclosed to another user, information copied outside the Service, information Cuddle must keep to complete an open request, or information needed to comply with legal, accounting, payment, safety, security, or dispute obligations. If we deny or limit a deletion request, we will do so only where permitted by applicable law.
11.4 Purchase, Billing, Refund, and Payment-Dispute Records
Cuddle may retain records relating to direct checkout, one-time purchases, payment authorization, receipts, access activation, expiration date and time, billing descriptor, refunds, statutory cancellations, billing questions, duplicate charges, unauthorized-charge concerns, chargebacks, payment disputes, taxes, accounting, audits, fraud prevention, and payment-risk management.
Premium and Signature are fixed-term, non-renewing purchases. Retention of purchase records does not mean Cuddle offers subscriptions, recurring billing, automatic renewal, automatic trial-to-paid conversion, automatic repurchase, external purchase channels, or twelve-month Paid Feature access.
11.5 Safety, Security, Fraud, Payment-Risk, and Enforcement Records
Cuddle may retain safety reports, moderation decisions, enforcement records, appeals, account-restriction records, verification records where used, device and session signals, fraud-prevention records, payment-risk records, security logs, account-takeover records, abuse reports, and related evidence.
These records may be retained where reasonably necessary to protect users, minors, Cuddle, payment participants, service providers, and the Service; prevent fraud; manage payment risk; investigate reports; enforce terms; preserve evidence; respond to disputes; and comply with law.
11.6 Backups, Logs, Legal Holds, and Service Providers
Information may remain for a limited time in backups, logs, archives, disaster-recovery systems, security systems, service-provider systems, payment-participant systems, or other operational records.
Cuddle may preserve information subject to legal holds, regulatory requirements, subpoenas, court orders, law-enforcement requests, tax or accounting obligations, audits, chargebacks, payment disputes, fraud investigations, safety matters, privacy requests, or legal claims.
Service providers and operational vendors may retain information as needed to provide services to Cuddle, comply with their obligations, protect systems, prevent fraud, maintain records, or follow Cuddle’s lawful instructions and applicable law.
11.7 De-Identified or Aggregated Information
Cuddle may retain aggregated or de-identified information where permitted by law.
Where information is de-identified, Cuddle will maintain and use it in de-identified form and will not attempt to reidentify it except as permitted by law.
11.8 Relationship to Rights and Other Terms
This Section is supplemented by the Terms, Purchase, Billing, Cancellation & Refund Terms, Paid Features Terms, State-Specific Terms & Cancellation Notices, Cookie / Tracking Policy, Contact / Legal Notices, checkout disclosures, purchase-specific terms, product disclosures, and applicable law.
Nothing in this Section limits any non-waivable access, deletion, correction, portability, opt-out, consent, appeal, payment, refund, statutory-cancellation, billing-error, unauthorized-transaction, chargeback, safety, consumer-protection, data-security, breach-notification, court-access, public-injunctive-relief, or other right under applicable law.
No retention, deletion, backup, legal hold, service-provider process, payment-participant process, privacy response, support response, refund response, statutory-cancellation response, chargeback process, or payment-dispute process authorizes prohibited services, prohibited payments, user-to-user transfers of value, adult content monetization, payment facilitation, marketplace activity, stored value, wallets, virtual credits, cryptocurrency, money transmission, financial services, abuse, exploitation, unsafe conduct, or unlawful activity.
12. Security, Safety Processing, and Breach Notices
12.1 Overview
Cuddle uses personal information to help protect accounts, users, minors, Cuddle, service providers, payment participants, and the Service.
This Section explains how Cuddle processes information for security, safety, abuse prevention, fraud prevention, payment-risk management, incident response, and legally required notices.
12.2 Security Measures and Limits
Cuddle uses reasonable administrative, technical, and organizational safeguards designed to protect personal information against unauthorized access, disclosure, alteration, loss, misuse, and destruction.
These safeguards may include access controls, authentication tools, logging, monitoring, encryption where appropriate, secure development practices, vendor review, incident-response procedures, data minimization, retention controls, employee training, and contractual safeguards for service providers.
No website, application, network, database, transmission, device, browser, email account, payment method, or storage system is perfectly secure. Cuddle cannot guarantee that personal information will never be accessed, disclosed, altered, lost, misused, or destroyed.
12.3 Account Security and Misuse
Cuddle may process account, device, browser, IP-address, session, login, verification, checkout, billing, support, fraud-prevention, payment-risk, and communication information to detect, prevent, investigate, and respond to account takeover, unauthorized access, credential misuse, bot activity, scraping, spam, harassment, scams, payment abuse, card testing, chargeback abuse, prohibited services, prohibited payments, and other misuse.
If Cuddle detects or reasonably suspects a security or account-integrity issue, Cuddle may require verification, revoke sessions, reset credentials, restrict access, block payment methods, delay or decline checkout, restrict Paid Features, preserve records, notify affected users where appropriate, or take other action permitted by law and applicable terms.
12.4 Safety Reports, Moderation, and Evidence
Cuddle may process profiles, messages, User Content, metadata, reports, blocks, support communications, screenshots, evidence, device signals, payment-risk signals, fraud-prevention signals, and related records to review safety reports, moderate content, enforce terms, protect users, respond to disputes, and comply with law.
Cuddle may preserve information relating to suspected harassment, threats, extortion, sextortion, doxxing, impersonation, minor-safety concerns, non-consensual content, scams, payment requests, prohibited services, prohibited payments, adult content monetization, adult live-chat, pornography, sexual services, escort services, compensated dating, sugar arrangements, paid companionship, or other unsafe or unlawful conduct.
Submitting a report does not guarantee a particular review, preservation decision, account action, disclosure, response time, refund, statutory cancellation, or outcome.
12.5 Minor Safety and Serious Harm
Cuddle is for adults only. Cuddle may process and preserve information, restrict accounts, remove content, block access, and report matters where required or appropriate if Cuddle reasonably believes that minors, exploitation, trafficking, grooming, abuse, self-harm risk, imminent danger, violence, threats, or other serious harm may be involved.
Cuddle may disclose relevant information to service providers, emergency services, law enforcement, regulators, courts, or lawful recipients where permitted or required by law.
Cuddle channels are not emergency-response channels. If there is immediate danger, contact local emergency services.
12.6 Security Reports
If you believe you found a security vulnerability, account compromise, unauthorized access, or other security issue involving Cuddle, contact:
security@cuddle-global.com
Do not exploit, test beyond authorization, access another person’s account or data, disrupt the Service, exfiltrate information, or publicly disclose a vulnerability before Cuddle has had a reasonable opportunity to review it.
12.7 Breach and Incident Notices
If Cuddle determines that a security incident or data breach requires notice under applicable law, Cuddle will provide notice to affected persons, regulators, payment participants, or other required recipients using methods and timing required or permitted by law.
Not every security event, suspicious activity, report, vulnerability, unauthorized attempt, or service-provider issue is a notifiable breach.
12.8 Relationship to Rights and Other Terms
This Section is supplemented by the Terms, Community Guidelines, Prohibited Services, Payments & Commerce Policy, Safety Tips / Dating Safety Notice, Criminal Background Screening Disclosure, Purchase Terms, Paid Features Terms, State-Specific Terms, Cookie / Tracking Policy, Contact / Legal Notices, and applicable law.
Nothing in this Section limits any non-waivable privacy, security, breach-notification, access, deletion, correction, portability, opt-out, appeal, payment, refund, statutory-cancellation, chargeback, safety, reporting, consumer-protection, court-access, or other right under applicable law.
13. Privacy Rights and U.S. State Privacy Notices
13.1 Overview
Depending on your state of residence and applicable law, you may have rights concerning personal information that Cuddle processes.
These rights may include the right to know, access, confirm processing, receive a copy, correct, delete, opt out, limit certain processing, withdraw consent, appeal, use an authorized agent, and be free from unlawful discrimination for exercising privacy rights.
Not every right applies to every user, account, request, category of information, purpose, or circumstance. Some laws apply only if particular legal thresholds are met or if a specific type of information or processing is involved.
Cuddle will honor applicable non-waivable privacy rights to the extent required by law.
Cuddle currently offers and markets the Service only to eligible adults located in the fifty states and the District of Columbia. Privacy rights, appeal rights, sensitive-information choices, authorized-agent procedures, and response methods may vary by state.
Cuddle may need to verify your identity, account ownership, residency, purchase details, or authority to act before fulfilling a privacy request.
Cuddle may use internal, manual, non-liveness photo or selfie review and identity-document or government-ID review for limited privacy-request verification, safety, fraud-prevention, payment-risk, account-integrity, legal, refund, statutory-cancellation, dispute, moderation, or enforcement purposes, as described in this Privacy Policy.
Cuddle does not currently use a third-party identity-verification vendor, government-ID verification vendor, biometric verification provider, liveness provider, facial-recognition provider, or face-matching provider to verify privacy requests.
Cuddle does not use liveness checks, facial-feature analysis, facial recognition, facial-geometry analysis, face templates, faceprints, fingerprints, voiceprints, biometric identifiers, biometric templates, or biometric verification for the Service or for privacy-request verification.
13.2 Rights That May Be Available
Depending on applicable law, you may request that Cuddle:
- confirm whether we process your personal information;
- provide access to personal information associated with you;
- provide a portable copy of certain personal information;
- correct inaccurate personal information;
- delete personal information, subject to exceptions;
- explain categories of personal information collected, sources, purposes, and recipients;
- disclose categories of personal information sold or shared, if any;
- opt you out of sale, sharing, targeted advertising, or certain profiling where applicable;
- limit certain uses or disclosures of sensitive personal information where applicable;
- withdraw consent where processing is based on consent and withdrawal is permitted;
- appeal a privacy-request decision where applicable;
- use an authorized agent where permitted by law; and
- exercise another privacy right provided by applicable law.
Cuddle does not sell personal information, private messages, sensitive personal information, or payment-related personal information.
Cuddle does not share personal information for targeted advertising, cross-context behavioral advertising, or similar advertising purposes.
Cuddle does not use personal information to provide user-to-user payments, tips, donations, payouts, stored value, wallets, virtual credits, gift cards, cryptocurrency, money transmission, payment facilitation, marketplace activity, banking, lending, investment, brokerage, securities, insurance, credit, employment, housing, or other financial products or services.
Cuddle does not use personal information to enable adult content monetization, adult live-chat, pornography sales, paid sexual messaging, sexual services, escort services, compensated dating, sugar arrangements, paid companionship, paid meetings, creator monetization, or other prohibited services.
If Cuddle changes a practice in a way that requires notice, consent, opt-out, or another privacy right, Cuddle will provide the required notice, choice, or process.
13.3 How to Submit a Privacy Request
Submit privacy questions, data-rights requests, consent-withdrawal requests, opt-out requests, privacy appeals where available, or authorized-agent requests to:
privacy@cuddle-global.com
Your request should include enough information for Cuddle to identify the account, the request, the state of residence where relevant, and the person making the request.
Cuddle may provide web forms, account settings, in-Service request tools, secure upload flows, or other methods for particular rights. If a more specific method is required by law or by a Cuddle notice, use that method.
Do not send passwords, authentication codes, full payment card numbers, card security codes, full bank credentials, identity-document images, government identification documents, liveness data, face templates, faceprints, facial-geometry data, fingerprints, voiceprints, biometric identifiers, biometric templates, private keys, wallet credentials, intimate content, medical records, information about minors, or other highly sensitive information by ordinary email.
When Cuddle needs identity-document or government-ID information for a specific privacy, data-rights, authorized-agent, appeal, account-recovery, safety, legal, refund, statutory-cancellation, dispute, Service-integrity, fraud-prevention, payment-risk, moderation, or enforcement process, Cuddle will provide a secure upload flow or specific instructions for that process.
Cuddle does not request liveness data, face templates, faceprints, facial-geometry data, fingerprints, voiceprints, biometric identifiers, biometric templates, or biometric verification materials for ordinary account verification or privacy-request verification.
A general support request is not automatically a privacy request, data-rights request, opt-out request, consent-withdrawal request, authorized-agent request, or privacy appeal. Use the privacy contact or the specific method Cuddle provides for the relevant right.
For billing questions, refund requests, duplicate charges, unauthorized-charge concerns, chargebacks, or payment disputes, use billing@cuddle-global.com.
For statutory cancellation requests or another cancellation right provided by law, use cancellations@cuddle-global.com.
For safety reports, use in-Service reporting tools where available or safety@cuddle-global.com.
Submitting a privacy request does not automatically cancel a purchase, create a refund, reverse a charge, resolve a chargeback, end a payment dispute, remove information from another user’s device, or delete records that Cuddle is permitted or required to retain.
13.4 Verification of Requests
Before fulfilling a request, Cuddle may verify your identity, account ownership, residency, purchase details, and authority to act.
Verification may use account email, phone number, login status, account identifiers, purchase details, recent activity, signed declarations, authorized-agent documentation, identity-document or government-ID review where reasonably necessary, or other reasonable information.
Cuddle will request only information reasonably necessary to verify the request, protect privacy, prevent fraud, manage payment risk, protect users, protect Cuddle, protect the Service, and comply with law.
Cuddle may use internal, manual, non-liveness photo or selfie review and identity-document or government-ID review where reasonably necessary to verify a privacy request, authorized-agent request, account-recovery request, legal request, refund request, statutory-cancellation request, dispute, safety matter, fraud-prevention matter, payment-risk matter, moderation matter, or enforcement matter.
Cuddle does not currently use a third-party identity-verification vendor, government-ID verification vendor, biometric verification provider, liveness provider, facial-recognition provider, or face-matching provider to verify privacy requests.
Cuddle does not use liveness checks, facial-feature analysis, facial recognition, facial-geometry analysis, face templates, faceprints, fingerprints, voiceprints, biometric identifiers, biometric templates, or biometric verification to verify privacy requests.
Cuddle does not use photo, selfie, identity-document, or government-ID materials to create biometric templates, perform facial recognition, conduct liveness checks, personalize prices, rank users, match users, advertise, sell or share personal information, or provide credit, lending, banking, insurance, securities, brokerage, payment facilitation, marketplace activity, or other financial products or services.
If Cuddle cannot reasonably verify a request, Cuddle may deny, limit, or ask for additional information where permitted by law.
Verification information may be retained as needed to document the request, prevent fraud, manage payment risk, comply with law, resolve disputes, protect privacy, protect users, and enforce privacy rights, subject to applicable retention limits.
Cuddle may refuse to disclose information where disclosure would create a security risk, reveal another person’s information, reveal confidential business information, compromise safety, compromise fraud-prevention or payment-risk controls, violate law, interfere with a legal obligation, or fall within another permitted exception.
13.5 Authorized Agents and Representatives
Where applicable law permits, you may authorize another person to submit a privacy request for you.
Cuddle may require proof that the agent is authorized to act, proof of your identity, proof of the agent’s identity, a signed permission, a power of attorney, estate documentation, guardianship documentation where lawful, or direct confirmation from you.
Cuddle may deny, limit, or delay an authorized-agent request if authority cannot be reasonably verified, if the request appears fraudulent or unsafe, if the request could compromise privacy or security, or if law permits denial.
An authorized agent may not use a privacy request to obtain passwords, authentication codes, payment credentials, full payment card numbers, card security codes, full bank credentials, private keys, wallet credentials, intimate content, information about another user, confidential safety records, security logic, fraud-prevention logic, payment-risk logic, moderation logic, trade secrets, or information that law does not require Cuddle to disclose.
If an authorized-agent request involves identity-document or government-ID information, Cuddle will provide a secure upload flow or specific instructions where reasonably necessary.
Cuddle does not request liveness data, face templates, faceprints, facial-geometry data, fingerprints, voiceprints, biometric identifiers, biometric templates, or biometric verification materials from an authorized agent for ordinary privacy-request verification.
13.6 Opt-Out Signals and Preference Tools
Where required by applicable law, Cuddle will honor valid opt-out preference signals, including Global Privacy Control, when Cuddle can reasonably recognize the signal and associate it with the relevant browser, device, account, or consumer.
Because Cuddle does not sell personal information or share personal information for targeted advertising, an opt-out signal may not change those practices unless Cuddle later engages in a covered practice.
Browser, device, and cookie choices may be limited to a specific browser, device, or session. Account-level choices may require you to log in or provide enough information to connect the choice to your account.
Cuddle may provide cookie banners, preference tools, account settings, email settings, privacy-request methods, or other controls where required or appropriate.
Blocking or deleting cookies or similar technologies may affect login, account security, fraud prevention, payment-risk review, checkout, privacy choices, support, notifications, or other Service functionality.
More information may appear in the Cookie / Tracking Policy.
13.7 Sensitive Information Choices
Depending on applicable law, you may have rights concerning sensitive personal information or sensitive data, including rights to consent, withdraw consent, limit use, request deletion, request access, request correction, appeal, or receive specific notice.
Sensitive information may include precise geolocation where used, government identification information where used for identity-document or government-ID review, identity-document images where used, photo or selfie materials where used for internal manual review, certain verification data, account credentials, payment-related information, communication contents, information about sex life or sexual orientation if voluntarily provided, health-related information provided in support or safety contexts, information about minors submitted in safety or legal contexts, and other protected information.
Cuddle may process sensitive information only where reasonably necessary for the Service, your request, safety, security, fraud prevention, payment-risk management, internal verification, legal compliance, Service integrity, moderation, enforcement, or another purpose described in this Privacy Policy.
Cuddle does not require information about sex life or sexual orientation to purchase Paid Features. If voluntarily provided, that information is processed only for user-directed profile, preference, safety, support, legal-rights, or similar functionality and does not authorize adult content, sexual services, prohibited payments, or prohibited activity.
Cuddle may use internal, manual, non-liveness photo or selfie review and identity-document or government-ID review to help prevent fake accounts, impersonation, scams, bots, account farms, prohibited commercial activity, prohibited services, prohibited payments, unauthorized payment use, payment abuse, account takeover, age or location evasion, verification evasion, re-registration evasion, and other misuse.
Cuddle does not currently use a third-party identity-verification vendor, government-ID verification vendor, biometric verification provider, liveness provider, facial-recognition provider, or face-matching provider.
Cuddle does not use liveness checks, facial-feature analysis, facial recognition, facial-geometry analysis, face templates, faceprints, fingerprints, voiceprints, biometric identifiers, biometric templates, or biometric verification for the Service.
Cuddle does not use photo, selfie, identity-document, or government-ID materials to create biometric templates, perform facial recognition, conduct liveness checks, personalize prices, rank users, match users, advertise, sell or share personal information, or provide credit, lending, banking, insurance, securities, brokerage, payment facilitation, marketplace activity, or other financial products or services.
Cuddle does not ask users to send identity-document images, government identification documents, photo or selfie materials for review, precise geolocation, or other highly sensitive information through ordinary email, ordinary messages, profile fields, reports, appeals, support channels, or mail.
When Cuddle needs identity-document or government-ID information for a specific verification, safety, legal, privacy, refund, statutory-cancellation, account-recovery, dispute, Service-integrity, fraud-prevention, payment-risk, moderation, or enforcement process, Cuddle will provide a secure upload flow or specific instructions for that process.
A sensitive-information choice, limitation, deletion, or consent withdrawal may not affect processing required or permitted for safety, fraud prevention, payment-risk management, security, tax, accounting, audit, legal compliance, dispute resolution, statutory cancellation, refund review, chargebacks, enforcement, or legal claims.
13.8 Access, Deletion, Correction, and Portability Limits
Privacy rights are subject to applicable exceptions and limitations.
A deletion request may not require Cuddle to delete information that Cuddle is permitted or required to retain for security, fraud prevention, payment-risk management, safety, moderation, dispute resolution, chargebacks, payment disputes, refunds, statutory cancellations, legal compliance, tax, accounting, audit, records management, enforcement, business operations, or protection of users and the Service.
A deletion request may not affect information already disclosed to another user, information copied outside the Service, information preserved in screenshots or recordings, information in another user’s account or device, information held by payment processors, banks, card networks, regulators, courts, law-enforcement authorities, or information controlled by another third party.
A deletion request does not automatically cancel a purchase, create a refund, reverse a charge, end an access period, resolve a chargeback, resolve a payment dispute, delete information another user received, or remove information from locations outside Cuddle’s control.
Premium and Signature are fixed-term, non-renewing purchases. Account deletion is not required to prevent a future renewal charge because Cuddle does not offer subscriptions, recurring billing, automatic renewal, automatic trial-to-paid conversion, or automatic repurchase.
A correction request may be denied, limited, or not applied where Cuddle cannot reasonably verify the requested correction, where the request concerns an opinion or internal assessment, where the information is maintained for fraud-prevention or payment-risk reasons, where law permits denial, or where correction would compromise safety, security, legal compliance, dispute resolution, or Service integrity.
An access or portability request may not require Cuddle to disclose another person’s information, internal security information, confidential business information, fraud-prevention logic, payment-risk logic, moderation logic, trade secrets, legal-privilege materials, information that would compromise safety or security, or information that law does not require Cuddle to disclose.
Cuddle may provide information in a reasonably usable format where required by law and technically feasible.
13.9 State Privacy Notice Categories
For purposes of U.S. state privacy laws, Cuddle may process categories of personal information described in this Privacy Policy, including:
- identifiers and contact information;
- account, eligibility, and authentication information;
- profile information, preferences, and User Content;
- messages, interactions, reports, appeals, and support records;
- purchase, checkout, billing, refund, statutory-cancellation, chargeback, and payment-dispute information;
- device, browser, IP-address, approximate-location, cookie, usage, security, fraud-prevention, and payment-risk information;
- photo or selfie materials where used for internal manual review;
- identity-document information, identity-document images, government identification information, and government identification documents where used;
- sensitive personal information or sensitive data where applicable;
- commercial information relating to Cuddle purchases;
- internet, electronic network, and Service activity information;
- geolocation information, including approximate location and precise geolocation where used;
- audio, electronic, visual, or similar information where you provide photos, videos where supported, support communications, or similar materials;
- inferences or generated records, such as eligibility indicators, safety indicators, fraud-risk indicators, payment-risk indicators, moderation decisions, enforcement decisions, support classifications, access activation or expiration status, verification-review status where used, and privacy-request status; and
- legal, compliance, tax, accounting, audit, and dispute records.
Sources of personal information may include you, your use of the Service, other users, service providers, operational vendors, payment participants, fraud-prevention vendors, payment-risk vendors, safety vendors, moderation sources, legal sources, public sources, and other lawful sources, as described in Section 4.
Purposes for processing may include providing, operating, securing, supporting, improving, protecting, and enforcing the Service; processing requests; completing direct checkout purchases; activating and expiring fixed-term Paid Features; preventing fraud; managing payment risk; moderating content; protecting users; complying with law; resolving disputes; and the other purposes described in Section 5.
Recipients may include other users where you direct disclosure, service providers, operational vendors, payment participants, fraud-prevention vendors, payment-risk vendors, safety vendors, moderation vendors, security vendors, support providers, professional advisers, regulators, courts, law enforcement, emergency services, business-transfer participants, and other lawful recipients, as described in Section 9.
Retention periods are described in Section 11 and depend on the type of information, purpose, account status, purchase history, reports, disputes, legal obligations, operational needs, and applicable law.
Cuddle does not sell personal information, private messages, sensitive personal information, or payment-related personal information.
Cuddle does not share personal information for targeted advertising, cross-context behavioral advertising, or similar advertising purposes.
13.10 Appeals, Timing, and Non-Discrimination
Cuddle will respond to privacy requests within the time required by applicable law.
Where permitted by law, Cuddle may extend the response period if reasonably necessary and will provide notice of the extension where required.
If Cuddle denies or limits a privacy request and applicable law provides an appeal right, you may appeal using the method Cuddle provides or by contacting:
privacy@cuddle-global.com
Your appeal should identify the original request, the decision being appealed, the state of residence where relevant, and the reason you believe further review is warranted.
Cuddle will review privacy appeals as required by applicable law. If an appeal is denied, Cuddle will provide information about any further rights or complaint method where required by law.
Cuddle will not unlawfully discriminate against you for exercising privacy rights.
A difference in Service functionality, account access, fraud-prevention treatment, payment-risk treatment, safety treatment, legal compliance, or record retention that results from a valid request, deletion, opt-out, consent withdrawal, inability to verify, account ineligibility, location restriction, payment-risk concern, safety concern, or legal requirement is not unlawful discrimination where permitted by law.
Cuddle may decline, delay, restrict, or condition access where personal information is reasonably necessary to provide the Service, complete checkout, verify eligibility, protect users, prevent fraud, manage payment risk, comply with law, resolve disputes, or enforce applicable terms.
13.11 Relationship to Other Rights and Terms
This Section is supplemented by the Terms, Purchase Terms, Paid Features Terms, Prohibited Services, Payments & Commerce Policy, Community Guidelines, Safety Tips / Dating Safety Notice, Criminal Background Screening Disclosure, State-Specific Terms, Cookie / Tracking Policy, Copyright / IP Complaints Policy, Contact / Legal Notices, checkout disclosures, purchase-specific terms, product disclosures, and applicable law.
The Privacy Policy controls personal-information processing.
The Purchase Terms control purchases, billing, refunds, statutory cancellations, chargebacks, and payment disputes.
The Prohibited Services, Payments & Commerce Policy controls prohibited services, prohibited payments, commerce, monetization, payment facilitation, marketplace activity, financial services, and user-to-user transfers of value.
The State-Specific Terms and applicable law control non-waivable state-specific rights.
If another Cuddle term, state-specific notice, privacy-rights notice, checkout disclosure, purchase-specific term, court rule, or applicable law provides a more specific or greater non-waivable right, that term, notice, disclosure, rule, or law controls to the extent required.
Nothing in this Section limits any non-waivable privacy, payment, refund, statutory-cancellation, safety, reporting, consumer-protection, accessibility, anti-discrimination, data-security, breach-notification, court-access, public-injunctive-relief, consent, opt-out, appeal, authorized-agent, intellectual-property, or other right under applicable law.
No privacy request, privacy response, appeal, opt-out, deletion request, correction request, access request, portability request, sensitive-information choice, consent withdrawal, authorized-agent request, service-provider relationship, operational-vendor relationship, payment-participant relationship, safety review, moderation review, fraud-prevention process, payment-risk process, legal process, support response, refund response, statutory-cancellation response, or third-party process authorizes prohibited services, prohibited payments, user-to-user transfers of value, adult content monetization, adult live-chat, pornography sales, sexual services, escort services, compensated dating, sugar arrangements, paid companionship, payment facilitation, marketplace activity, financial services, abuse, exploitation, unsafe conduct, or unlawful activity.
14. International Processing, Third-Party Services, Changes, and Non-Waivable Rights
14.1 United States Service and Processing Locations
Cuddle currently offers and markets the Service only to eligible adults located in the fifty states and the District of Columbia. U.S. territories and locations outside the United States are excluded unless Cuddle expressly states otherwise.
Access to or use of the Service from outside the supported area is not authorized, except for lawful support, privacy, billing, refund, statutory-cancellation, security, or legal communications concerning an existing account or purchase.
Cuddle is operated from the United States. Personal information may be collected, processed, stored, disclosed, and transferred in the United States and in other locations where Cuddle, its service providers, operational vendors, payment processors, payment-method providers, banks, card networks, fraud-prevention vendors, payment-risk vendors, hosting providers, cloud providers, storage providers, security vendors, communications providers, email providers, support providers, moderation vendors, safety vendors, analytics providers, consent-management tools, privacy-request tools, legal-process tools, tax and accounting providers, professional advisers, regulators, courts, law enforcement, emergency services, business-transfer participants, or other lawful recipients operate.
Cuddle does not currently use a third-party identity-verification vendor, government-ID verification vendor, biometric verification provider, liveness provider, facial-recognition provider, or face-matching provider.
Cuddle may use operational service providers to host, secure, store, route, log, or support Cuddle-managed review systems. Infrastructure, storage, security, support, moderation, communications, fraud-prevention, payment-risk, privacy-request, legal-process, tax, accounting, or other operational vendors are not treated as third-party identity-verification vendors merely because they help Cuddle operate systems used in connection with internal manual review, support, moderation, fraud prevention, payment-risk management, privacy-request processing, dispute processing, or enforcement.
Cuddle does not transfer personal information to third-party identity-verification vendors, government-ID verification vendors, biometric verification providers, liveness providers, facial-recognition providers, face-matching providers, fingerprint-verification providers, or voiceprint-verification providers because Cuddle does not currently use those verification methods.
Privacy and data-protection laws in the places where information is processed may differ from the laws of your state or country. Where applicable law requires safeguards, notices, consent, contractual terms, data-transfer terms, or other protections for processing or transfers, Cuddle will apply them to the extent required.
Processing information in another location does not mean that Cuddle offers, markets, or authorizes the Service outside the supported United States area.
No international processing, service-provider relationship, payment-participant relationship, operational-vendor relationship, legal process, or transfer of information authorizes prohibited services, prohibited payments, user-to-user transfers of value, adult content monetization, adult live-chat, pornography sales, sexual services, escort services, compensated dating, sugar arrangements, paid companionship, payment facilitation, marketplace activity, financial services, abuse, exploitation, unsafe conduct, or unlawful activity.
14.2 Third-Party Services, Links, and Operational Providers
The Service may link to, rely on, or interoperate with third-party services that Cuddle does not own or control.
These may include hosting providers, cloud providers, storage providers, security vendors, analytics providers, communications providers, email providers, customer-support tools, fraud-prevention vendors, payment-risk vendors, payment processors, payment-method providers, banks, card networks, moderation vendors, safety vendors, consent-management tools, privacy-request tools, legal-process tools, tax and accounting providers, browser providers, device providers, operating-system providers, professional advisers, business-transfer participants, and similar operational or lawful recipients.
Cuddle does not currently use a third-party identity-verification vendor, government-ID verification vendor, biometric verification provider, liveness provider, facial-recognition provider, or face-matching provider.
Operational providers are not treated as third-party identity-verification vendors merely because they host, secure, store, route, log, transmit, support, or provide tools for Cuddle-managed systems used in connection with internal manual review, support, moderation, fraud prevention, payment-risk management, privacy-request processing, dispute processing, or enforcement.
Third-party services may have their own terms, privacy policies, cookie policies, security practices, payment rules, refund procedures, dispute processes, data-transfer terms, support processes, and legal obligations.
Cuddle is not responsible for privacy, security, data handling, content, conduct, availability, payment decisions, authentication decisions, refund decisions, dispute decisions, or support practices of third parties that Cuddle does not own or control, except where applicable law provides otherwise.
Payment processors, payment-method providers, banks, card networks, fraud-prevention vendors, and payment-risk vendors may process information under their own terms, privacy policies, security practices, network rules, bank requirements, dispute procedures, and legal obligations. They may approve, decline, delay, authenticate, refund, reverse, restrict, or require additional information for a transaction.
Cuddle currently offers Paid Features only through Cuddle’s authorized direct checkout flow. Cuddle does not currently offer Paid Features through an app store, browser platform, device platform, third-party marketplace, user-supplied payment link, QR code, payment handle, wallet address, external checkout page, or other external purchase channel.
Do not treat a user-provided payment link, payment handle, wallet address, QR code, external page, social-media profile, messaging-app instruction, or third-party listing as an authorized Cuddle purchase channel.
If a third-party service, user, website, app, message, QR code, payment handle, wallet address, or external page claims to sell, renew, extend, upgrade, transfer, restore, or provide Cuddle access outside Cuddle’s authorized direct checkout flow, do not complete the transaction. Contact billing@cuddle-global.com.
If you leave Cuddle, follow a link, use an external messaging service, use an external payment application, provide information to another platform, communicate outside the Service, or send money or value outside Cuddle’s authorized direct checkout flow, you do so at your own risk. Cuddle may have limited or no ability to prevent fraud, preserve evidence, recover funds, reverse transfers, remove external content, enforce its terms outside the Service, or provide support for activity outside Cuddle.
Do not send full payment card numbers, card security codes, passwords, authentication codes, full bank credentials, private keys, wallet credentials, identity-document images, government identification documents, liveness data, face templates, faceprints, facial-geometry data, fingerprints, voiceprints, biometric identifiers, biometric templates, intimate content, information about minors, medical records, or other highly sensitive information through external services, ordinary email, ordinary messages, profile fields, reports, appeals, support channels, or mail.
When Cuddle needs identity-document or government-ID information for a specific verification, safety, legal, privacy, refund, statutory-cancellation, account-recovery, dispute, Service-integrity, fraud-prevention, payment-risk, moderation, or enforcement process, Cuddle will provide a secure upload flow or specific instructions for that process.
No third-party service, external link, user-provided payment instruction, operational provider, payment participant, or off-Service communication authorizes prohibited services, prohibited payments, user-to-user transfers of value, adult content monetization, adult live-chat, pornography sales, sexual services, escort services, compensated dating, sugar arrangements, paid companionship, payment facilitation, marketplace activity, financial services, abuse, exploitation, unsafe conduct, or unlawful activity.
14.3 Changes to This Privacy Policy
Cuddle may update this Privacy Policy from time to time.
If Cuddle makes a material change, Cuddle will update the Effective Date or Last Updated date and provide notice where required by law. Notice may be provided through the Service, Legal pages, email, account notices, in-Service notices, privacy notices, cookie notices, checkout notices, the Contact / Legal Notices, or another method permitted by law.
Where law requires advance notice, consent, acknowledgment, opt-out, withdrawal opportunity, retention notice, deletion notice, or another process before a change applies, Cuddle will follow that requirement.
Continued access to or use of the Service after an updated Privacy Policy becomes effective means that you acknowledge the updated Privacy Policy, except where law requires a different process.
If you do not agree with an updated Privacy Policy, you must stop using the Service, except for lawful support, privacy, billing, refund, statutory-cancellation, security, or legal communications concerning an existing account or purchase.
A change to this Privacy Policy does not automatically cancel a purchase, create a refund, reverse a charge, resolve a chargeback, delete an account, delete information another user received, or end an access period unless applicable law, checkout disclosures, Purchase Terms, State-Specific Terms, or purchase-specific terms require that result.
If Cuddle later introduces a third-party identity-verification vendor, government-ID verification vendor, biometric verification provider, liveness provider, facial-recognition provider, face-matching provider, fingerprint-verification provider, voiceprint-verification provider, liveness checks, facial-feature analysis, facial recognition, facial-geometry analysis, face templates, faceprints, fingerprints, voiceprints, biometric identifiers, biometric templates, or biometric verification, Cuddle will update this Privacy Policy and applicable notices before use and will provide any notice, consent, retention, deletion, opt-out, appeal, or other rights required by law.
If Cuddle later offers Paid Features through an app store, browser platform, device platform, third-party marketplace, or another external purchase channel, Cuddle will update the applicable public pricing disclosures, Purchase Terms, Paid Features Terms, State-Specific Terms, checkout disclosures, product disclosures, and Legal notices before making that channel available.
No update to this Privacy Policy, Legal page, contact channel, service-provider relationship, operational-vendor relationship, payment-provider relationship, checkout disclosure, product disclosure, support process, privacy-request process, verification procedure, or secure-upload instruction authorizes prohibited services, prohibited payments, user-to-user transfers of value, adult content monetization, adult live-chat, pornography sales, sexual services, escort services, compensated dating, sugar arrangements, paid companionship, payment facilitation, marketplace activity, financial services, abuse, exploitation, unsafe conduct, or unlawful activity.
14.4 Contact, Requests, and Sensitive Information
For privacy questions, privacy requests, data-rights requests, consent-withdrawal requests, opt-out requests, sensitive-data questions, privacy appeals where available, authorized-agent requests, or questions about this Privacy Policy, contact:
privacy@cuddle-global.com
Use the most current official channel listed in this Privacy Policy or the Contact / Legal Notices. Keep records showing when, where, and how you sent any time-sensitive request, and include enough information for Cuddle to identify the account, request, state of residence where relevant, and authority to act.
For billing questions, refund requests, duplicate charges, unauthorized-charge concerns, chargebacks, or payment disputes, contact:
billing@cuddle-global.com
For statutory cancellation requests or another cancellation right provided by law, contact:
cancellations@cuddle-global.com
For safety reports, use in-Service reporting tools where available or contact:
safety@cuddle-global.com
For security reports, contact:
security@cuddle-global.com
For formal legal notices, contact:
legal@cuddle-global.com
A general support request is not automatically a privacy request, data-rights request, opt-out request, consent-withdrawal request, authorized-agent request, privacy appeal, refund request, statutory-cancellation request, safety report, security report, legal notice, copyright complaint, appeal, Notice of Dispute, arbitration opt-out notice, material-change rejection, subpoena response, law-enforcement request, regulatory request, or service-of-process communication.
Do not send passwords, authentication codes, full payment card numbers, card security codes, full bank credentials, identity-document images, government identification documents, liveness data, face templates, faceprints, facial-geometry data, fingerprints, voiceprints, biometric identifiers, biometric templates, private keys, wallet credentials, intimate content, medical records, information about minors, or other highly sensitive information by ordinary email, ordinary messages, profile fields, reports, appeals, support channels, or mail.
When Cuddle needs identity-document or government-ID information for a specific privacy, data-rights, authorized-agent, appeal, account-recovery, safety, legal, refund, statutory-cancellation, dispute, Service-integrity, fraud-prevention, payment-risk, moderation, or enforcement process, Cuddle will provide a secure upload flow or specific instructions for that process.
Cuddle does not request liveness data, face templates, faceprints, facial-geometry data, fingerprints, voiceprints, biometric identifiers, biometric templates, or biometric verification materials for ordinary account verification or privacy-request verification.
Cuddle contact channels are not emergency-response channels and may not be monitored in real time. If you are in immediate danger, believe another person is in immediate danger, or need emergency assistance, contact local emergency services immediately.
Sending a request to the wrong channel may delay review and may not satisfy a legal deadline unless applicable law requires otherwise or Cuddle accepts the communication in writing.
14.5 Non-Waivable Rights and Relationship to Other Terms
This Privacy Policy is supplemented by the Terms, Purchase Terms, Paid Features Terms, Prohibited Services, Payments & Commerce Policy, Community Guidelines, Safety Tips / Dating Safety Notice, Criminal Background Screening Disclosure, State-Specific Terms, Cookie / Tracking Policy, Copyright / IP Complaints Policy, Contact / Legal Notices, checkout disclosures, purchase-specific terms, product disclosures, and applicable law.
The Privacy Policy controls personal-information processing.
The Purchase Terms control purchases, billing, refunds, statutory cancellations, chargebacks, and payment disputes.
The Paid Features Terms control Paid Feature functionality, access, limits, expiration, availability, promotional or complimentary access, no cash value, non-transferability, and feature-specific restrictions.
The Prohibited Services, Payments & Commerce Policy controls prohibited services, prohibited payments, commerce, monetization, payment facilitation, marketplace activity, financial services, and user-to-user transfers of value.
The State-Specific Terms and applicable law control non-waivable state-specific rights.
The Cookie / Tracking Policy controls cookie-specific categories, choices, retention, provider roles, and universal opt-out signal procedures to the extent it applies.
The Contact / Legal Notices control official channels, routing instructions, formal legal notice procedures, and request-specific notice methods to the extent applicable.
If another Cuddle term, state-specific notice, privacy-rights notice, checkout disclosure, purchase-specific term, court rule, or applicable law provides a more specific or greater non-waivable right, that term, notice, disclosure, rule, or law controls to the extent required.
Nothing in this Privacy Policy limits any non-waivable privacy, payment, refund, statutory-cancellation, billing-error, unauthorized-transaction, chargeback, safety, reporting, consumer-protection, accessibility, anti-discrimination, data-security, breach-notification, court-access, public-injunctive-relief, consent, opt-out, appeal, authorized-agent, intellectual-property, cancellation, deletion, correction, access, portability, sensitive-information, or other right under applicable law.
No international processing, third-party service, operational vendor, service-provider relationship, payment-participant relationship, privacy response, support response, refund response, statutory-cancellation response, safety review, moderation review, fraud-prevention process, payment-risk process, legal process, business transfer, policy update, contact-channel update, secure-upload process, or third-party process authorizes prohibited services, prohibited payments, user-to-user transfers of value, adult content monetization, adult live-chat, pornography sales, sexual services, escort services, compensated dating, sugar arrangements, paid companionship, payment facilitation, marketplace activity, stored value, wallets, virtual credits, cryptocurrency, money transmission, financial services, abuse, exploitation, unsafe conduct, or unlawful activity.
