Cuddle Privacy Policy

Effective Date: May 8, 2026

Last Updated: October 2, 2026

1. About This Privacy Policy

1.1 Purpose

This Privacy Policy explains how Third Hub US, Inc., doing business as Cuddle (“Cuddle,” “we,” “us,” or “our”), collects, uses, discloses, retains, protects, and deletes personal information in connection with Cuddle.

Cuddle is an online dating and social connection service for adults 18 or older, designed for married or partnered adults.

1.2 Scope

This Privacy Policy applies to personal information processed through Cuddle’s websites, registration, accounts, profiles, discovery, Likes, Matches, messaging, photo-sharing features, Free Access, Premium subscriptions, checkout, support, safety and moderation, cookies, security, fraud prevention, and limited account reviews.

Together, these features are the “Service.”

This Privacy Policy does not apply to third-party services that Cuddle does not own or control. Those services may have separate privacy practices.

1.3 Key Privacy Summary

Depending on how you use Cuddle, we may process account, profile, preference, activity, message, device, location, subscription, billing, support, safety, and review information.

We use personal information to provide and improve the Service, operate discovery and communications, administer Premium, process payments, protect members, prevent fraud and abuse, respond to requests, and comply with law.

We may disclose information to other members through Service features and to affiliates, service providers, payment participants, advisers, or lawful authorities as described here.

Cuddle does not sell personal information or share it for targeted advertising. In-Service messages are not end-to-end encrypted, and other members may copy or share information they receive.

1.4 Relationship to Other Policies

This Privacy Policy should be read with our Terms of Service, Cookie / Tracking Policy, Purchase, Billing, Cancellation & Refund Terms, Paid Features Terms, State-Specific Terms & Cancellation Notices, and notices.

If another policy conflicts with this Privacy Policy concerning personal-information processing, this Privacy Policy controls to the extent permitted by law. We will obtain consent where required.

2. Who We Are and Service Scope

2.1 Responsible Entity

Cuddle is operated by Third Hub US, Inc., a Delaware corporation doing business as Cuddle.

In this Privacy Policy, “Cuddle,” “we,” “us,” and “our” mean Third Hub US, Inc., unless the context states otherwise.

Third Hub US, Inc. is the entity responsible for personal information processed in connection with the Service, subject to applicable law and the roles of affiliates, service providers, payment participants, and other recipients described in this Privacy Policy.

2.2 Adults-Only U.S. Service

Cuddle is intended only for adults who are at least 18 years old.

The Service is currently offered to eligible adults who are physically located in the fifty (50) U.S. states or the District of Columbia while using Cuddle. It is not currently offered in U.S. territories or outside the United States unless we expressly state otherwise.

Section 13 explains how we handle information involving minors.

2.3 Role of Affiliates and Service Providers

Our affiliates and service providers may help host, develop, operate, secure, support, moderate, analyze, communicate about, and process payments for the Service.

They may process personal information for us under contracts, instructions, confidentiality obligations, security requirements, and applicable law. Some third parties may act independently for limited purposes under their own legal obligations, as explained in this Privacy Policy.

2.4 Responsibility for Processing

We determine the purposes and means of personal-information processing for Cuddle where applicable law treats us as a controller or business.

Using an affiliate or service provider does not transfer our responsibilities under this Privacy Policy. We remain responsible for our own obligations, while other entities remain responsible for processing they independently control.

Questions or privacy requests may be sent to privacy@cuddle-global.com.

3. Personal Information We Collect

What we collect depends on how you use Cuddle. Not every person provides or is associated with every category below.

3.1 Account, Contact, and Eligibility Information

We collect information you provide or generate when you request access, create or manage an account, register, confirm contact information, sign in, recover an account, or communicate with Cuddle.

This may include:

• your email address, phone number, and country calling code;
• account, user, profile, and support identifiers;
• password-related, authentication, login, session, account-recovery, and new-device-verification records;
• email-confirmation and SMS-verification records;
• date of birth, age, and records used to confirm that you are at least 18;
• state of residence, profile location, language, and supported-area information;
• account status, restrictions, settings, notification preferences, and privacy choices; and
• records of your acceptance, acknowledgment, consent, withdrawal, or opt-out relating to our Terms, Privacy Policy, subscription disclosures, and other notices or choices.

Confirming an email address or phone number shows control of that contact method. It does not, by itself, verify identity, background, or account ownership.

3.2 Profile, Preferences, Photos, and User Content

We collect information you choose to provide through your profile or other Service features.

This may include:

• display name, age as displayed, sex at birth, pronouns, profile text, prompts, interests, and lifestyle information;
• marital or relationship-status information you choose to provide;
• sexual orientation and the gender or genders you choose to meet, where you choose to provide them;
• discovery preferences, profile location, visibility settings, and photo-sharing choices;
• profile photos, gallery photos, and other images;
• messages, attachments, screenshots, evidence, reports, appeals, support communications, feedback, and other content you submit; and
• other information you make available through the Service.

Profile and relationship-status information is generally self-reported. Do not provide information or content that you do not have the right to use or share.

We may process approximate location inferred from an IP address and location information you provide. We do not collect precise geolocation unless a feature or review requires it and we provide any notice or choice required by law.

3.3 Likes, Matches, Messages, and Service Activity

We collect information about how you use profiles, discovery, Likes, Matches, messaging, blocking, reporting, and other features.

This may include:

• profiles presented, viewed, skipped, passed, or otherwise acted on;
• Incoming Likes, Likes Back, First Likes, and related account identifiers and timestamps;
• First-Like usage, remaining allowance, limit, reset, and paywall records;
• Match, unmatch, block, and conversation records;
• message content, attachments, sender and recipient identifiers, timestamps, delivery information, and related metadata;
• report, safety, moderation, anti-spam, and feature-restriction activity; and
• pages viewed, links selected, searches or filters used, settings changed, errors encountered, and other Service interactions.

In-Service messages are not end-to-end encrypted. We and authorized service providers may process messages where reasonably necessary to deliver, store, secure, moderate, investigate, support, and maintain the Service.

3.4 Subscription and Billing Information

We collect or receive information relating to Free Access, Premium subscriptions, checkout, payment authorization, billing, renewal, cancellation, refunds, and payment disputes.

This may include:

• Free Access, Premium, promotional, or complimentary-access status;
• subscription, customer, checkout, purchase, transaction, authorization, invoice, and receipt identifiers;
• subscription start date, 30-day billing interval, current billing period, renewal date, cancellation request date, cancellation effective date, and subscription status;
• Premium price, currency, taxes, discounts, and fees displayed or charged;
• automatic-renewal consent records and the versions of checkout disclosures and terms presented;
• payment-method type, limited payment-method details, billing information, and billing ZIP code made available by payment participants;
• payment, settlement, failure, retry, reversal, refund, statutory-cancellation, chargeback, and payment-dispute status;
• Premium activation, expiration, and First-Like allowance records;
• the billing descriptor associated with the transaction; and
• billing-support communications and records concerning unauthorized, duplicate, or incorrect charges.

Full payment card numbers and card security codes are intended to be submitted through processor-hosted or processor-approved fields and are not intended to be received or stored on Cuddle-controlled systems.

3.5 Support, Reports, Safety, and Legal Information

We collect information when you contact support, submit a report, request cancellation or a refund, exercise a privacy right, appeal an action, report a security issue, or send a legal or rights-related communication.

This may include contact information, account and request identifiers, the substance of communications, categories and descriptions, attachments, screenshots, evidence, transaction references, routing information, request status, response records, and timestamps.

For safety, moderation, fraud prevention, enforcement, and account integrity, we may also collect reporter and reported-account identifiers, relevant messages or content, device and session information, risk signals, internal review records, decisions, restrictions, appeals, and related evidence.

3.6 Device, Cookie, Security, and Risk Information

We may collect technical and usage information automatically or through cookies and similar technologies.

This may include:

• IP address and approximate location inferred from it;
• device type, operating system, browser type and version, language, and time zone;
• referring page, Service version, cookie identifiers, local-storage identifiers, and session identifiers;
• authentication events, login history, new-device records, network and request information, and security logs;
• pages and features used, errors, diagnostics, and performance information;
• bot-prevention responses, rate-limit information, suspicious-activity signals, and related-account or device signals; and
• fraud-prevention, payment-risk, sanctions, account-takeover, and circumvention indicators.

Our Cookie / Tracking Policy provides additional information about cookies and similar technologies.

3.7 Limited Account-Review Information

Cuddle does not routinely require a government ID, identity-document review, or photo or selfie review during ordinary registration.

In limited, risk-based circumstances, we may request additional information, identity-document images, government ID images or information, a current photo, or selfie review materials to address suspected impersonation, scams, fraud, prohibited commercial activity, account farming, payment risk, safety concerns, account recovery, account integrity, compliance, moderation, or enforcement.

Related records may include the review request, review type, associated account identifier, submission and completion dates, result or status, internal reason or reference code, and whether another review is required.

Review materials must be submitted only through the authenticated review flow made available through the Service. After a review is completed and related operational, safety, fraud-prevention, dispute, and legal needs are resolved, submitted review images are placed into our deletion process, subject to reasonable processing periods, backups, legal holds, and applicable law. We may retain a limited review-result record as described in Sections 8 and 12.

4. Sources of Personal Information

4.1 Information You Provide

We collect personal information directly from you when you request access, create or manage an account, complete a profile, select preferences, upload content, send Likes or messages, subscribe to Premium, contact support, submit a report or appeal, exercise a privacy right, or otherwise interact with Cuddle.

In limited, risk-based circumstances, we may also receive account-review materials you submit through the authenticated review flow available through the Service.

4.2 Information from Other Members

We may receive information about you from other members through Service interactions, reports, complaints, screenshots, attachments, and evidence.

Information provided by another member may be inaccurate, incomplete, outdated, or misleading and is not automatically verified.

4.3 Information Collected or Generated Through the Service

We collect information automatically when you access or use Cuddle, including device, browser, IP-address, approximate-location, cookie, session, authentication, usage, diagnostic, and security information.

We may generate account-status, feature-access, recommendation, subscription, safety, moderation, fraud-prevention, payment-risk, support-routing, and enforcement records from account, activity, device, transaction, report, and interaction data.

4.4 Affiliates, Service Providers, and Payment Participants

We may receive information from affiliates and providers that help host, operate, secure, support, analyze, communicate about, moderate, or process payments for the Service.

Payment processors, banks, card issuers, and payment networks may provide limited transaction, payment-method, billing, refund, dispute, and risk information. Full payment card details are not intended to be received or stored on Cuddle-controlled systems.

4.5 Public, Legal, and Authorized Sources

Where permitted by law, we may receive information from public records, courts, regulators, law-enforcement authorities, professional advisers, rights holders, complaint submitters, authorized representatives, persons you authorize, or other lawful sources.

We may combine information from these sources with other information described in this Privacy Policy for the purposes stated in Section 5.

5. How We Use Personal Information

We use personal information for the purposes described below. Not every purpose applies to every person, account, feature, subscription, report, review, or interaction.

5.1 Providing and Operating Cuddle

We use personal information to:

• receive and manage requests for access;
• create, authenticate, maintain, and recover accounts;
• confirm age and supported-area eligibility;
• operate profiles, settings, preferences, visibility controls, and photo-sharing features;
• provide Free Access and other available functionality;
• maintain sessions, deliver notices, troubleshoot errors, and support Service availability; and
• administer account restrictions, deletion requests, and other account actions.

We may use account, profile, preference, location, device, and activity information to provide the features you request and personalize your non-price Service experience.

5.2 Discovery and Recommendations

We use profile information, preferences, approximate location, Service activity, account status, and safety or moderation signals to select, organize, filter, and display profiles and other content.

These processes may affect which profiles you see and the order in which they appear. They do not guarantee visibility, compatibility, Likes, Matches, messages, or any other outcome.

We do not use limited account-review images to recommend or rank members.

5.3 Likes, Matches, and Messaging

We use personal information to operate Incoming Likes, Likes Back, First Likes, Matches, blocking, unmatching, and messaging.

This includes determining whether a Like is a Like Back or First Like, whether applicable access or limits permit the action, whether a Match exists, and whether a message may be delivered.

We do not use sex, gender identity, sexual orientation, or the gender or genders a member chooses to meet to determine whether Premium is required for a Like.

We may process message content and metadata to deliver, store, secure, filter, moderate, investigate, troubleshoot, and support messaging. In-Service messages are not end-to-end encrypted.

5.4 Premium and Billing

We use personal information to:

• display Premium offers and checkout disclosures;
• create and administer subscriptions;
• record automatic-renewal consent;
• activate Premium and apply First-Like allowances;
• process recurring charges, renewals, cancellations, receipts, taxes, discounts, and refunds;
• manage failed payments, payment retries, chargebacks, and billing disputes; and
• provide billing and subscription support.

We may use account, transaction, device, browser, IP-address, session, billing, and risk information to prevent unauthorized payment use and other payment abuse.

We do not use marital or relationship status, sexual orientation, private messages, safety reports, or limited account-review materials to personalize the price charged to an individual member.

5.5 Safety, Moderation, Fraud Prevention, and Enforcement

We use personal information to protect members and the Service; review reports; moderate content; investigate suspected violations; prevent scams, spam, bots, impersonation, account takeover, account farming, payment abuse, and circumvention; and enforce our Terms and policies.

Human, automated, and machine-assisted tools may analyze account, profile, content, message, report, device, session, transaction, and risk information for these purposes.

We may restrict features, preserve evidence, suspend or terminate accounts, respond to appeals, and share information where permitted or required by law. These tools may be incomplete or inaccurate and do not guarantee safety or truthfulness.

5.6 Support and Communications

We use personal information to operate the Help Center, route and respond to requests, troubleshoot issues, verify account ownership, and manage privacy, safety, security, billing, cancellation, legal, and rights-related communications.

We may send account, authentication, security, safety, subscription, renewal, cancellation, receipt, policy, support, and legal notices. We also use communication preferences and consent or opt-out records to manage optional communications.

5.7 Analytics and Service Improvement

We may use personal information and, where appropriate, aggregated or de-identified information to measure Service use, diagnose errors, evaluate features, conduct controlled product tests, improve performance, develop safety and fraud-prevention systems, and understand general trends.

Where implemented, cookies and analytics technologies are used as described in Section 11 and our Cookie / Tracking Policy.

We do not use the substance of private in-Service messages to train general-purpose artificial-intelligence models for unrelated third-party commercial use.

5.8 Legal Compliance and Business Operations

We use personal information to comply with law, court orders, lawful government requests, tax, accounting, audit, recordkeeping, and regulatory obligations.

We may also use information to establish, exercise, or defend legal claims; protect the rights and safety of members, Cuddle, our affiliates, service providers, payment participants, and the public; manage contracts and providers; support corporate governance and business continuity; and evaluate or complete a merger, financing, restructuring, asset transfer, or similar transaction.

We use personal information only for disclosed purposes, compatible purposes, or other purposes permitted by law. Where a materially different use requires notice or consent, we will provide it.

6. Profiles, Messages, Photos, and Visibility

6.1 Information Visible to Other Members

Information you add to your profile may be visible to other members through profiles, discovery, Incoming Likes, Likes, Matches, messaging, photo-sharing features, and related Service functionality.

Depending on what you provide and the features available, a profile may display your display name, age, pronouns, profile location, photos, prompts, interests, preferences, marital or relationship-status information, and other information you choose to make available.

Visibility may depend on your settings and actions, the other member’s settings and actions, account status, location, blocks, unmatches, safety controls, moderation, technical availability, and applicable law.

We may use profile, preference, approximate-location, activity, account-status, and safety information to select and organize profiles in discovery. We do not guarantee that every profile will be visible to every member or receive any particular number of views, Likes, Matches, or messages.

6.2 Messages and the Non-E2EE Notice

In-Service messages are not end-to-end encrypted.

Cuddle and authorized service providers may process message content, attachments, sender and recipient identifiers, timestamps, delivery information, and related metadata where reasonably necessary to deliver, store, route, secure, filter, moderate, investigate, support, and maintain the Service or comply with law.

Do not use messages to send passwords, authentication codes, full payment information, government identification, precise location, medical records, or other information that you do not want the intended recipient or authorized Cuddle personnel to receive.

We do not guarantee that a message will be delivered, seen, read, retained, or answered.

6.3 Photo and Gallery Controls

Photos you submit may be displayed through profiles, discovery, Likes, Matches, messaging, galleries, or other Service features according to your settings and actions.

Where Cuddle provides gallery or photo-sharing controls, those controls may limit which members can view particular content within the Service. They cannot prevent an authorized recipient from copying, saving, screenshotting, photographing, recording, forwarding, publishing, or otherwise disclosing that content.

A photo, gallery permission, account review, badge, or indicator does not guarantee identity, ownership, authenticity, intentions, or safety.

6.4 Copies, Screenshots, and Off-Service Disclosure

Other members may copy, save, screenshot, record, forward, publish, disclose, or misuse information or content they receive or view.

Our Terms and Community Guidelines may prohibit certain conduct, but Cuddle cannot control every recipient, device, external platform, or off-Service disclosure. We do not guarantee complete anonymity, confidentiality, or that information shared through the Service will remain within Cuddle.

Use care before sharing contact details, workplace information, travel plans, family information, location information, intimate content, financial information, or other sensitive information.

6.5 Blocking, Unmatching, and Deletion Limits

Blocking or unmatching may restrict future visibility or communication through Cuddle, but it may not remove information already received, copied, saved, screenshotted, recorded, or disclosed.

Removing content or deleting an account may remove or deactivate information from ordinary Service views. It may not immediately or completely remove messages, recipient copies, reports, safety or support records, subscription or payment records, fraud-prevention records, legal records, logs, backups, search indexes, or information in service-provider systems that we are permitted or required to retain.

We may preserve relevant information when reasonably necessary for safety, moderation, fraud prevention, dispute resolution, legal compliance, or enforcement. Section 12 provides additional information about retention and deletion.

7. Premium Subscription and Payment Information

7.1 Subscription Records

We process personal information to create, administer, and document Premium subscriptions.

This may include your customer and subscription identifiers, selected plan, subscription start date, 30-day billing interval, current billing period, renewal date, cancellation status, expiration date, Premium access status, First-Like allowance, price, currency, discounts, taxes, and applicable terms or offer versions.

We also retain records showing the subscription disclosures presented at checkout, your automatic-renewal authorization, purchase confirmation, invoices, receipts, and related account activity.

Premium payments are made to Third Hub US, Inc. for Cuddle-operated digital features and are not payments to or for another member.

7.2 Checkout and Payment Processors

We use authorized payment processors and other payment participants to support checkout, payment authentication, authorization, settlement, receipts, fraud prevention, and subscription administration.

We may send or receive account, customer, subscription, transaction, price, currency, tax, billing, device, browser, IP-address, session, and risk information as reasonably necessary for those purposes.

Payment participants may provide payment-method type, limited payment-method details, billing information, authorization status, transaction identifiers, and updated payment credentials or tokens where permitted.

7.3 Renewal and Cancellation Records

We process records of scheduled renewals, completed renewal charges, cancellation requests, cancellation methods, request dates, effective dates, confirmations, and the end of Premium access.

We use these records to stop future charges, maintain access through an applicable paid period, respond to questions, document consent and cancellation, and comply with automatic-renewal and recordkeeping requirements.

Deleting an account may also generate records showing that future Premium renewals were canceled.

7.4 Failed Payments, Refunds, Chargebacks, and Taxes

We may process payment failures, declines, retries, reversals, refunds, billing errors, unauthorized-charge claims, chargebacks, disputes, and related communications.

This may include transaction and receipt identifiers, amounts, dates, limited payment-method details, processor or issuer status information, account activity, Premium usage, device and session information, evidence, correspondence, and resolution records.

We may also process billing location, ZIP code, subscription amount, applicable tax rate, tax amount, and related records to calculate, collect, report, and remit taxes where required.

7.5 Full Payment-Card Information

Full payment card numbers and card security codes are intended to be entered directly into processor-hosted or processor-approved fields. They are not intended to be received or stored on Cuddle-controlled systems.

Do not send full card numbers, security codes, bank credentials, passwords, or authentication codes through profiles, messages, reports, support tickets, ordinary email, or mail.

8. Sensitive Information, Location, and Limited Account Review

8.1 Sensitive Information

Some information processed through Cuddle may be sensitive under applicable law. This may include age and date of birth, marital or relationship status, sexual orientation you choose to provide, private messages, profile photos, approximate location, payment activity, safety reports, and limited account-review information.

We process this information for purposes described in this Privacy Policy, including providing features, supporting discovery, administering subscriptions, protecting members, preventing fraud, reviewing reports, securing accounts, and complying with law.

We do not sell sensitive personal information or use it for targeted advertising or individual price personalization.

8.2 Relationship Status and Profile Attributes

Marital or relationship status, sexual orientation, pronouns, interests, lifestyle information, and similar profile attributes are generally information you choose to provide.

This information may be displayed to other members according to your settings and used to provide discovery preferences, organize profiles, operate features, and support safety and moderation.

Relationship-status information is self-reported. Cuddle does not independently verify or guarantee any member’s marital status, relationship status, living situation, intentions, or availability.

8.3 Location Information

We may process profile location, state of residence, billing location, and approximate location inferred from an IP address or similar permitted signals.

We use location information for eligibility, discovery, localization, security, fraud prevention, payment-risk management, tax calculation, state-specific notices, and legal compliance.

Cuddle does not collect precise geolocation unless a feature or review reasonably requires it and we provide any notice, choice, or consent required by law.

8.4 Limited Identity-Document or Photo Review

Cuddle does not routinely require an identity document, government ID, or current-photo review during ordinary registration.

In limited, risk-based circumstances, we may request these materials to address suspected impersonation, scams, fraud, prohibited commercial activity, account farming, payment risk, safety concerns, account recovery, account integrity, compliance, moderation, or enforcement.

Review materials must be authentic and submitted only through the authenticated review flow available through the Service. Do not submit them through profiles, messages, reports, ordinary email, support tickets, external forms, or mail.

A completed review does not guarantee identity, age, relationship status, background, intentions, truthfulness, compatibility, or safety.

8.5 No Facial Recognition, Biometric Templates, or Liveness Analysis

Cuddle does not use automated facial-recognition technology, create facial or other biometric identifiers or templates, or perform liveness analysis.

A current photo requested for a limited review is processed as an image for that review and related safety, fraud-prevention, account-integrity, compliance, moderation, enforcement, or dispute purposes. We do not use review images to recommend or rank members, personalize prices, advertise, or create public-facing profile content.

If these practices change, we will update this Privacy Policy and provide any notice or consent required before the new processing begins.

8.6 Review-Material Deletion and Limited Result Records

After a review is completed and related operational, safety, fraud-prevention, dispute, and legal needs are resolved, submitted review images are placed into our deletion process.

Deletion may be subject to reasonable processing periods, backup cycles, legal holds, security requirements, and applicable law.

We may retain a limited result record, such as the review type, result or status, completion date, internal reference or reason code, account identifier, and whether another review is required. We do not ordinarily retain an active copy of the submitted review image after deletion is completed.

8.7 Consumer Health Data Where Applicable

Cuddle does not ask for medical records, diagnoses, treatment information, or other consumer health data during ordinary registration.

A member may nevertheless disclose health-related information in profile content, messages, reports, support communications, or other materials. We process it only as reasonably necessary for the feature, request, safety matter, legal obligation, or other disclosed purpose.

Do not submit unnecessary medical or health information. If applicable law treats information we process as consumer health data, we will provide any separate notice, consent, deletion process, or other protection required by law.

9. Recommendations, Safety, Moderation, and Automated Tools

9.1 Profile Recommendations and Ordering

Cuddle may use profile information, preferences, approximate location, Service activity, account status, and safety or moderation signals to select, filter, organize, and display profiles and other content.

These processes may affect which profiles you see and the order in which they appear. They do not guarantee that a profile will be shown, viewed, Liked, matched, or messaged.

We do not use limited account-review images to recommend or rank members.

9.2 Spam, Fraud, and Safety Detection

We may use automated and machine-assisted tools to help detect or prevent spam, bots, scams, impersonation, account farming, harassment, minor-safety concerns, account takeover, unauthorized payment use, suspicious devices or networks, and attempts to evade account, payment, safety, or enforcement controls.

These tools may analyze account, profile, content, message, interaction, device, browser, IP-address, session, transaction, report, and risk information.

Where permitted by law, a detected signal may cause additional review, a warning, content filtering, a feature limit, a payment check, a temporary restriction, or another protective action.

9.3 Human and Machine-Assisted Review

Cuddle personnel and authorized service providers may review information when reasonably necessary for support, safety, moderation, fraud prevention, account recovery, payment risk, legal compliance, or enforcement.

Automated or machine-assisted tools may help identify, prioritize, classify, or route content, accounts, transactions, reports, and requests for review. A person may review relevant information before or after an action, depending on the issue, urgency, risk, and applicable law.

We may provide an appeal or review process where required by law or made available under our Terms and policies.

9.4 Price Personalization and Significant Decisions

Cuddle does not use marital or relationship status, sexual orientation, private messages, safety reports, or limited account-review materials to personalize the price charged to an individual member.

We do not currently use personal information to make automated decisions that produce legal or similarly significant effects concerning employment, housing, credit, insurance, lending, or access to essential services.

Premium eligibility and feature access may still depend on account status, subscription status, safety controls, technical availability, and compliance with our Terms.

9.5 Limits of Automated Tools

Automated, machine-assisted, and human review processes may be incomplete, delayed, inaccurate, unavailable, or circumvented. They cannot identify every false statement, harmful act, prohibited user, fraud attempt, or safety risk.

A recommendation, ranking, warning, review result, badge, account status, moderation decision, or safety feature is not an endorsement or guarantee of identity, truthfulness, compatibility, legality, or safety.

Section 14 explains applicable privacy rights, including rights relating to certain profiling or automated processing where required by law.

10. How We Disclose Personal Information

We disclose personal information as described in this Privacy Policy, at your direction, or as permitted or required by law. The categories disclosed depend on the feature, transaction, request, risk, and recipient’s role.

10.1 Other Members and Intended Recipients

We disclose profile information and User Content to other members through profiles, discovery, Incoming Likes, Likes, Matches, messaging, photo-sharing controls, and related features.

A Like is disclosed to its intended recipient. Match status is disclosed to both matched members. Messages, attachments, and sender information are disclosed to the intended recipient and may be processed as described in Section 6.

We do not ordinarily disclose a reporter’s identity solely because a report was submitted. We may disclose limited report-related information where required by law or reasonably necessary to investigate, review, explain, or enforce an action while limiting identifying information where practical.

10.2 Affiliates and Hosted Platform Providers

We may disclose personal information to affiliates and hosted platform providers that help develop, host, operate, secure, maintain, support, moderate, analyze, and improve Cuddle.

They may process account, profile, content, message, interaction, subscription, support, safety, security, fraud-prevention, and limited account-review information as reasonably necessary for their role.

They must process information under applicable contracts, instructions, confidentiality obligations, security requirements, and law. They are not authorized to use Cuddle personal information for unrelated advertising, user monetization, or purposes outside their role, subject to independent legal obligations.

10.3 Operational Service Providers

We may disclose personal information to providers supporting cloud hosting, storage, communications, email and SMS delivery, customer support, authentication, security, bot prevention, fraud prevention, moderation, analytics, consent management, account review, and other operations.

Providers used for these functions may include Amazon Web Services, Twilio, Intercom, Typeform, and Google reCAPTCHA.

Depending on the service, disclosed information may include account identifiers, contact information, content, support communications, device and browser information, IP address, session data, logs, delivery records, diagnostics, and risk signals.

Limited account-review images must be submitted only through the authenticated review flow available through the Service. They are not intended to be collected through ordinary support, email, Intercom, Typeform, or member messaging.

10.4 Payment Participants

We may disclose personal information to authorized payment processors, payment-method providers, banks, card issuers, card networks, tax providers, and fraud- or payment-risk providers.

This may include account, customer, subscription, transaction, invoice, receipt, price, currency, tax, billing, device, browser, IP-address, session, authorization, refund, cancellation, chargeback, dispute, and risk information.

These disclosures support checkout, renewals every 30 days, payment authentication, settlement, receipts, tax calculation, refunds, cancellations, failed-payment handling, disputes, fraud prevention, and payment-risk management.

Full payment card numbers and card security codes are intended to be entered through processor-hosted or processor-approved fields and are not intended to be received or stored on Cuddle-controlled systems.

10.5 Safety, Legal, and Regulatory Disclosures

We may disclose personal information to courts, regulators, law-enforcement authorities, emergency services, government agencies, rights holders, payment participants, or other lawful recipients where reasonably necessary to:

• comply with law, legal process, or regulatory requirements;
• address serious safety concerns or protect members, minors, Cuddle, or the public;
• investigate fraud, abuse, account takeover, prohibited conduct, or security incidents;
• preserve evidence or enforce our Terms and policies;
• respond to intellectual-property, privacy, or other rights-related claims; or
• establish, exercise, or defend legal claims.

Where appropriate and permitted by law, we may challenge, narrow, or limit a request.

10.6 Professional Advisers and Business Transfers

We may disclose personal information to lawyers, auditors, accountants, insurers, consultants, and other professional advisers where reasonably necessary for legal, tax, accounting, audit, risk-management, governance, or business purposes.

We may also disclose or transfer information in connection with a merger, acquisition, financing, restructuring, asset sale, affiliate transfer, change of control, bankruptcy, or similar transaction, subject to applicable law and appropriate safeguards.

10.7 At Your Direction or With Your Authorization

We may disclose information to a person, service, authorized agent, or recipient you direct or authorize.

Your actions through profiles, Likes, Matches, messages, photo-sharing controls, external links, support requests, and privacy requests may cause disclosure to recipients you select.

Third-party services you choose may process information under their own terms and privacy policies.

10.8 No Sale or Targeted-Advertising Sharing

Cuddle does not sell personal information or share personal information for cross-context behavioral advertising or targeted advertising.

We do not authorize service providers or affiliates acting for Cuddle to use personal information for unrelated advertising or user monetization, subject to independent legal obligations.

We will not use your profile photo, name, likeness, or private in-Service messages in public-facing advertising or marketing without your separate permission.

Section 14 explains applicable privacy rights and opt-out mechanisms.

11. Cookies, Analytics, and Communications

Cuddle may use cookies, pixels, tags, scripts, local or session storage, browser or device identifiers, consent tools, and similar technologies. Not every technology applies to every user, device, page, or feature. Our Cookie / Tracking Policy provides details.

11.1 Necessary and Session Technologies

We use technologies necessary to load pages, authenticate accounts, maintain sessions, remember settings, operate profiles and messaging, support account recovery, provide privacy choices, and maintain Service availability.

Blocking or deleting these technologies may prevent parts of Cuddle from working properly.

11.2 Security and Fraud-Prevention Technologies

We may use cookies and similar technologies to detect bots, suspicious activity, unusual login or device changes, account takeover, credential misuse, account farming, circumvention, card testing, unauthorized payment use, refund or chargeback abuse, and other security or payment risks.

These technologies may use device, browser, IP-address, session, interaction, transaction, and risk information. They reduce risk but cannot detect or prevent every harmful act.

11.3 Analytics and Performance

Where implemented, we may use analytics, diagnostics, and performance technologies to understand page views, navigation, feature use, errors, load times, subscription and checkout issues, support flows, and aggregated Service trends.

We use this information to maintain, troubleshoot, and improve Cuddle. We do not use private messages, sensitive personal information, payment information, or limited account-review materials for targeted advertising.

11.4 Support and Checkout Technologies

Cuddle and authorized providers may use technologies to operate the Help Center, route support requests, manage communications, process checkout, authenticate payments, administer subscriptions, provide receipts, handle renewals and cancellations, and prevent fraud.

Full payment-card information is intended to be entered through processor-hosted or processor-approved fields.

11.5 Cookie Choices and Universal Opt-Out Signals

Where required, we may provide a cookie banner, settings panel, consent tool, or other choice.

You may use browser or device controls to block or delete some technologies. Doing so may affect login, security, settings, support, checkout, or other functionality.

Where applicable law requires recognition of Global Privacy Control or another legally recognized universal opt-out signal, we will process it as required.

11.6 Communication Preferences

You may manage optional or marketing communications through available settings or unsubscribe methods.

We may still send necessary account, authentication, security, safety, subscription, renewal, cancellation, receipt, privacy, policy, support, and legal communications.

Changing a communication preference does not cancel Premium, stop a renewal, create a refund, or replace a required cancellation method.

12. Retention and Deletion

12.1 Retention Criteria

Cuddle retains personal information only for as long as reasonably necessary and proportionate for the purposes described in this Privacy Policy and as permitted or required by law.

Retention periods vary by category and context. We may consider:

• the nature and sensitivity of the information;
• whether your account, subscription, request, report, investigation, dispute, or legal matter remains active;
• the purposes for which the information was collected or used;
• safety, security, fraud-prevention, payment-risk, moderation, and account-integrity needs;
• tax, accounting, audit, recordkeeping, and contractual requirements; and
• reasonable technical and operational requirements.

Not every category is retained for the same period.

12.2 Active Accounts, Messages, and User Content

While your account is active, we may retain account, profile, preference, photo, Like, Match, message, block, unmatch, report, support, and other Service records needed to provide, secure, support, moderate, and administer Cuddle.

Deleting content, a conversation, or an account may remove or deactivate information from ordinary Service views, but it may not immediately or completely remove information already received, copied, saved, screenshotted, recorded, or disclosed by another member.

12.3 Subscription, Payment, Tax, and Accounting Records

We may retain records relating to Premium subscriptions, checkout disclosures, automatic-renewal authorization, invoices, receipts, renewals, cancellations, payment failures, refunds, chargebacks, billing disputes, taxes, accounting, and audits.

These records may be retained after Premium ends or an account is deleted where reasonably necessary for legal compliance, fraud prevention, dispute resolution, financial reporting, or enforcement.

Completing account deletion cancels future Premium renewals as described in our Terms, but it does not automatically reverse a completed charge, create a refund, or erase records that we are permitted or required to keep.

12.4 Safety, Fraud, Moderation, and Legal Records

We may retain reports, moderation decisions, appeals, restrictions, enforcement records, security logs, account-takeover records, fraud and payment-risk records, related account or device signals, and supporting evidence.

We may also preserve information subject to a legal hold, court order, subpoena, regulatory or law-enforcement request, safety matter, security incident, rights complaint, privacy request, payment dispute, audit, or legal claim.

We may retain limited records showing that a request or matter was received, reviewed, completed, denied, appealed, or resolved.

12.5 Account-Review Materials

When we request limited identity-document, government-ID, current-photo, or selfie review materials, those materials must be submitted through the authenticated review flow.

After the review and related operational, safety, fraud-prevention, dispute, and legal needs are resolved, submitted review images are placed into our deletion process, subject to reasonable processing periods, backups, legal holds, and applicable law.

We may retain a limited result record, including the review type, status or result, completion date, internal reference code, account identifier, and whether another review is required.

12.6 Backups and Service-Provider Systems

Personal information may remain temporarily in backups, logs, archives, recovery systems, search indexes, and systems operated by affiliates or service providers before deletion, isolation, de-indexing, or expiration is completed.

We may not be able to delete information controlled by another member, an independent third party, a court, regulator, law-enforcement authority, or payment participant.

12.7 Aggregated and De-Identified Information

We may retain aggregated or de-identified information for analytics, safety, fraud prevention, Service improvement, reporting, business planning, and legal compliance.

Where information is de-identified, we will maintain and use it in de-identified form and will not attempt to reidentify it except as permitted by law.

When personal information is no longer reasonably necessary, we may delete, de-identify, aggregate, isolate, or otherwise dispose of it, subject to applicable law.

13. Security and Minors

13.1 Administrative, Technical, and Organizational Safeguards

Cuddle uses administrative, technical, and organizational safeguards designed to protect personal information against unauthorized access, use, disclosure, alteration, loss, or destruction.

These safeguards may include authentication controls, session management, access restrictions, logging, monitoring, backups, recovery procedures, encryption where appropriate, and measures used by our cloud and service providers.

Safeguards vary based on the information involved, the Service feature, and applicable law. No security measure eliminates every risk, and we cannot guarantee that personal information or the Service will always remain secure.

13.2 Administrative Access

We limit administrative access to personal information based on job responsibilities and authorized business purposes.

Cuddle personnel and authorized affiliates or service providers may access information where reasonably necessary for support, safety, moderation, fraud prevention, payment-risk management, account review, security, or legal compliance.

We use authentication, role-based access controls, confidentiality obligations, and other restrictions designed to limit access to people and systems that need the information. Access may be removed when no longer appropriate.

13.3 Incident Response and Breach Notices

We may investigate suspected security incidents, preserve records, restrict access, reset credentials, suspend accounts, notify providers, and take reasonable steps to contain, assess, remediate, and document an incident.

Where law requires notice of a data breach or security incident, we will notify affected individuals, regulators, or other required recipients by a permitted method and within the required period.

13.4 Your Account-Security Responsibilities

You are responsible for protecting your password, email account, phone number, devices, authentication codes, and other access methods.

Do not share credentials or codes. Promptly contact security@cuddle-global.com if you suspect unauthorized access, phishing, credential theft, or account compromise.

Cuddle’s security channel is not an emergency service and may not be monitored in real time.

13.5 Adults Only and Information About Minors

Cuddle is only for adults 18 or older. Minors may not create accounts, use the Service, appear in member content, communicate with members, or purchase or use Premium.

If we learn that a minor used Cuddle or submitted personal information, we may restrict or terminate the account and delete the information. We may retain limited records where reasonably necessary and permitted by law for safety, investigation, legal compliance, or enforcement.

If you believe a minor is using Cuddle or is at risk, contact safety@cuddle-global.com. If there is immediate danger, contact local emergency services.

14. Privacy Rights and U.S. State Notices

14.1 Overview of Rights

Depending on your state and applicable law, you may have rights to confirm, access, delete, correct, or obtain a copy of personal information; withdraw consent; limit certain sensitive-data uses; opt out; appeal; use an authorized agent; and receive protection against unlawful discrimination.

Rights may vary by person, information, activity, and circumstance and may be subject to verification, exceptions, limitations, and legal response periods.

14.2 Access, Deletion, Correction, and Portability

Where applicable, you may request:

• confirmation of whether we process personal information about you;
• access to eligible personal information;
• information about categories collected, sources, purposes, retention criteria, and recipients where required;
• deletion of eligible personal information;
• correction of inaccurate personal information; and
• a portable copy in a reasonably usable format.

Deletion may remove or deactivate account and profile information from ordinary Service views, but may not remove information already received by another member or records retained under Section 12.

A privacy deletion request does not automatically create a refund or resolve a payment dispute. It cancels future Premium renewals only if completed account deletion results; use the subscription-management option to stop renewals promptly.

We may limit disclosure where permitted to protect another person, security, privileged material, trade secrets, fraud-prevention methods, or legal rights.

14.3 Consent Withdrawal and Sensitive-Data Rights

Where we rely on consent, you may withdraw it as permitted by law. Withdrawal applies prospectively and does not make prior lawful processing unlawful.

Depending on your state, you may have rights to consent to, withdraw consent from, limit, or delete certain sensitive personal information. Exercising a right may affect a feature or process that reasonably requires the information.

A request does not automatically remove information already received by another person or records we may retain. Additional rights may apply to consumer health data under Section 8.7 and any separate notice.

14.4 Sale, Sharing, Targeted Advertising, and Profiling

Cuddle does not sell personal information or share it for cross-context behavioral advertising or targeted advertising.

We do not currently use personal information for profiling that produces legal or similarly significant effects concerning employment, housing, credit, insurance, lending, or access to essential services.

Where law provides an opt-out right, we will process a valid request. Because we do not currently engage in these activities, it may have limited practical effect.

Where required, we will recognize Global Privacy Control or another legally recognized universal opt-out signal. Necessary processing for security, authentication, fraud prevention, payment risk, Service operation, and legal compliance may continue where permitted.

14.5 How to Submit a Request

Submit a privacy request through a method available in the Service or contact:

privacy@cuddle-global.com

Include enough information to identify the account or information, the requested right, your state where relevant, associated contact information, and your authority if acting for another person.

Requests are generally free. We may charge a reasonable fee, limit a request, or decline to act only where permitted by law, including for manifestly unfounded, excessive, repetitive, fraudulent, or abusive requests.

Do not send identity documents or review images through ordinary email. If reasonably necessary, use only the authenticated review flow we provide.

14.6 Verification and Authorized Agents

We may confirm that a request concerns the correct person or account and that the requester has authority.

Verification may use account email, phone number, login status, identifiers, recent activity, purchase details, signed declarations, or other proportionate information. We will not request more information than reasonably necessary.

For a higher-risk request, we may require an identity-document, government-ID, current-photo, or selfie review through the authenticated review flow.

Where permitted, an authorized agent may submit a request. We may require signed permission, proof of registration, power of attorney, or other evidence and may contact you directly.

If we cannot reasonably verify the request or authority, we may limit or deny it as permitted by law.

14.7 Appeals and Complaints

We will respond within the period required by law and may extend that period where permitted, with notice when required.

If applicable law provides an appeal right, appeal by contacting:

privacy@cuddle-global.com

Identify the original request, decision, state of residence where relevant, and reason for further review.

If an appeal is denied, we will provide any further complaint method required by law. You may also contact an applicable state privacy regulator or Attorney General.

14.8 Non-Discrimination

Cuddle will not unlawfully discriminate against you for exercising an applicable privacy right.

We will not deny the Service, charge a different price, or provide a different level or quality solely because you exercised a right, except where permitted by law.

A change resulting from deletion, consent withdrawal, inability to verify, account ineligibility, safety or payment risk, or information needed for a requested feature is not unlawful discrimination where permitted.

Cuddle does not currently offer a financial-incentive or loyalty program in exchange for the collection, sale, or sharing of personal information.

14.9 California Disclosures

For California privacy-law purposes, the categories we collect and may have collected during the preceding twelve months include:

• identifiers, such as contact, account, IP-address, and device identifiers;
• personal-record and profile information, including date of birth, billing information, profile details, and preferences;
• protected-classification information you provide, including age, sex or gender-related information, marital status, and sexual orientation;
• commercial information, including subscription, transaction, invoice, receipt, refund, and dispute records;
• internet or electronic-network activity, including usage, cookie, session, authentication, and diagnostic information;
• approximate geolocation and, only where disclosed and permitted, precise geolocation;
• audio, electronic, visual, or similar information, including photos, messages, attachments, and support communications;
• inferences used for recommendations, safety, fraud prevention, moderation, or Service operation; and
• sensitive personal information, including account-access credentials, private communications, sexual orientation if provided, and limited review information.

Sources are described in Section 4, purposes in Section 5, and recipients in Section 10.

During the preceding twelve months, we may have disclosed relevant categories for business purposes to other members, affiliates, hosted platform and operational providers, payment participants, advisers, authorities, or other recipients described in Section 10.

We do not sell or share personal information for cross-context behavioral advertising.

Where California law applies, you may have rights to know, access, delete, correct, opt out of sale or sharing, limit qualifying uses of sensitive personal information, and receive equal treatment.

We do not currently use or disclose sensitive personal information for purposes requiring a separate right-to-limit method. If that changes, we will provide the required notice and choice.

We do not currently offer a California financial incentive tied to personal information.

14.10 Other U.S. State Rights

Residents of other U.S. states may have similar or additional rights, including rights to:

• access, delete, or correct personal information;
• obtain a portable copy;
• withdraw consent for sensitive-data processing;
• opt out of sale, targeted advertising, or qualifying profiling;
• request information about recipients;
• use an authorized agent; and
• appeal a decision.

We will provide any state-specific notice, consent process, opt-out method, appeal process, or response required by applicable law.

Nothing in this Privacy Policy limits a privacy, data-security, breach-notification, consumer-health-data, court-access, or other right that cannot lawfully be waived.

15. Cross-Border Processing, Changes, and Contact

15.1 Locations of Processing

Personal information may be processed in the United States, Singapore, Japan, and other locations where our affiliates, platform providers, service providers, payment participants, advisers, or lawful recipients operate.

The laws of those locations may differ from the laws where you live. Where law requires notice, consent, contractual safeguards, or transfer mechanisms, we will apply them.

15.2 International Affiliates and Service Providers

Affiliates and platform providers may help develop, host, operate, secure, support, analyze, and improve Cuddle.

They may process personal information only as necessary for their role and subject to contracts, instructions, confidentiality obligations, security requirements, and law.

Third Hub US, Inc. remains responsible for its obligations under this Privacy Policy. Another recipient may be independently responsible for processing it controls under applicable law.

15.3 Third-Party Services

Cuddle may link to services that we do not own or control. Those services may have their own terms, privacy policies, security measures, payment rules, and support procedures.

Review applicable third-party information before providing personal information or using an external service. An external link, payment instruction, or review request provided by another member is not an authorized Cuddle purchase or review channel.

Except where law provides otherwise, Cuddle is not responsible for an independent third party’s privacy, security, availability, content, or data practices.

15.4 Changes and Effective Date

We may update this Privacy Policy as the Service, technology, providers, or law changes.

For a material update, we will revise the Effective Date or Last Updated date and provide any notice, consent request, opt-out opportunity, or other process required by law through the Service, email, an account notice, checkout, or another permitted method.

Updates apply prospectively unless law requires otherwise. Continued use does not replace separate consent where consent is required. We may retain prior versions and notice, consent, withdrawal, and opt-out records.

15.5 Contact, Requests, and Complaints

For privacy questions, requests, appeals, or complaints, contact:

privacy@cuddle-global.com

Cuddle is operated by:

Third Hub US, Inc., d/b/a Cuddle

6900 Dallas Pkwy

Plano, TX 75024

United States

Business mailing address:

Third Hub US, Inc., d/b/a Cuddle

1007 N Orange St, 4th Floor, Suite #5681

Wilmington, DE 19801

United States

Include enough information to identify your account or request. We may verify identity, residency, account ownership, or authority before responding.

Do not send passwords, authentication codes, full payment information, government identification, or review images through ordinary email or mail. Use only an authenticated review flow when we request review materials.

You may also contact a state privacy regulator or Attorney General. These channels are not emergency services. For immediate danger, contact local emergency services.