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., a Delaware corporation, d/b/a Cuddle (“Cuddle,” “we,” “us,” or “our”) collects, uses, discloses, retains, protects, deletes, and processes personal information in connection with Cuddle.

Cuddle is an 18+ online dating and social connection service for eligible adults in the United States. The Service includes accounts, profiles, discovery, Likes, Matches, messaging, safety tools, support, Free Access, and optional Premium.

By using the Service or otherwise interacting with Cuddle, you acknowledge the processing described here. This acknowledgment is not consent where law requires separate consent for a particular activity.

1.2 Scope of This Privacy Policy

This Privacy Policy applies to personal information processed through Cuddle’s websites, request-an-invite forms, registration, accounts, profiles, messaging, safety and moderation, limited risk-based account review, support, checkout, billing, cookies, security, fraud prevention, payment-risk management, and related functionality.

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 services may have separate privacy practices.

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 other locations are excluded unless Cuddle states otherwise.

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

If Cuddle learns that a minor created an account or submitted personal information, Cuddle may restrict or terminate the account and delete or retain limited records as permitted or required for safety, investigation, legal compliance, and prevention of re-registration.

1.4 Free Access, Premium, and Current Purchase Model

Free Access currently includes reviewing Incoming Likes, viewing the members who sent them, sending Likes Back, forming Matches, and messaging matched members without a plan-based message-count limit, subject to applicable restrictions.

Premium permits eligible members to send First Likes, subject to applicable limits. Purchased Premium is thirty-day, fixed-term, non-renewing access sold through Cuddle’s authorized direct checkout as a one-time purchase.

Cuddle does not currently offer subscriptions, recurring billing, automatic renewal, automatic repurchase, automatic trial-to-paid conversion, or external purchase channels.

Payments through Cuddle’s checkout are payments to Third Hub US, Inc., d/b/a Cuddle for Cuddle-operated digital functionality, not payments to or for another member. Full payment card details are intended to be submitted through processor-hosted or processor-approved fields and not stored on Cuddle-controlled systems.

1.5 Important Privacy and Safety Limits

Information you provide may be visible to other members based on Service functionality, your settings, and your actions. Other members may copy, save, screenshot, record, forward, disclose, misuse, or distribute it outside Cuddle.

In-Service messages are not end-to-end encrypted and should not be treated as a guaranteed secure channel for highly sensitive information.

Cuddle does not routinely require an identity-document review, government ID review, or photo or selfie review for every member or during ordinary registration. In limited, risk-based circumstances, Cuddle may request a review for suspected impersonation, scams, fraud, prohibited commercial activity, account farming, payment risk, safety concerns, account recovery, account integrity, compliance, moderation, or enforcement.

Where Cuddle requests review materials, use only the authenticated review flow made available through the Service. Section 8 explains these reviews.

Cuddle does not sell personal information or share it for targeted advertising.

1.6 Relationship to Other Terms

This Privacy Policy should be read with Cuddle’s Terms of Service and applicable Additional Terms, including the Purchase Terms, Paid Features Terms, Cookie / Tracking Policy, State-Specific Terms & Cancellation Notices, Contact / Legal Notices, and applicable law.

If there is a conflict regarding personal-information processing, this Privacy Policy controls to the extent permitted by law.

2. Who We Are, Addresses, and Contact Channels

2.1 Cuddle Operator and Responsible Entity

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 requires otherwise.

Cuddle is responsible for the personal information it processes in connection with the Service, subject to applicable law and the roles of service providers and payment participants.

Third Hub US, Inc., d/b/a Cuddle is also the contracting party for the Service and the contracting seller for direct purchases completed through Cuddle’s authorized checkout.

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.

The operating address is not a payment, emergency, ordinary-support, privacy-request, statutory-cancellation, review-submission, registered-agent, service-of-process, subpoena, law-enforcement, regulatory, or formal-legal-notice address.

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.

It is not necessarily Cuddle’s registered-agent, service-of-process, emergency, payment, refund, statutory-cancellation, privacy-request, support, or review-submission address. Mail sent to an incorrect address or channel may be delayed, misrouted, returned, or not treated as the intended request.

2.4 Privacy and Data-Rights Contact

For questions about this Privacy Policy or requests concerning access, deletion, correction, portability, consent withdrawal, opt-outs, authorized agents, or privacy appeals where available, contact:

privacy@cuddle-global.com

Include enough information to identify the account or request, your state of residence where relevant, and your authority to act. Cuddle may reasonably confirm identity, account ownership, residency, or authority before responding, as described in Section 13.

2.5 Other Official Contact Channels

Use the channel that best matches your request:

• General Support: support@cuddle-global.com
• Billing, Refunds, Duplicate or 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

The Contact / Legal Notices provide current routing instructions. Section 15 of the Terms controls Notices of Dispute and arbitration-related communications.

2.6 Routing, Emergency, Review-Submission, and Sensitive-Information Limits

A general support request is not automatically a privacy, billing, cancellation, safety, security, rights, legal, appeal, dispute, arbitration, or service-of-process communication. Using the wrong channel may delay review and may not satisfy a deadline unless law requires otherwise or Cuddle accepts the communication in writing.

Cuddle’s channels are not emergency-response channels and may not be monitored in real time. If there is immediate danger, contact local emergency services.

Where Cuddle requests review materials, Cuddle may send a notice to the email address associated with the account or through another available account communication channel. Review materials must be submitted only through the authenticated review flow made available through the Service.

Do not submit identity-document images, government identification, photo or selfie review materials, passwords, authentication codes, full payment card or bank information, private keys, wallet credentials, intimate content, information about minors, medical records, or other highly sensitive information through ordinary email, general support channels, in-Service messages, profile fields, reports, appeals, or mail.

3. Personal Information We Collect

3.1 Overview

Cuddle collects personal information to provide, operate, secure, support, improve, administer, and enforce the Service.

The information we collect depends on how you interact with Cuddle, the features you use, the information you provide, the settings you select, the purchases you make, the reports or requests you submit, any limited account 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. Describing a category does not mean that Cuddle collects every item in that category from every user.

3.2 Invite, Account, Registration, Eligibility, and Contact Information

We may collect information you provide or generate when you request an invitation, create or manage an account, complete registration, confirm contact information, access or recover an account, or communicate with Cuddle.

This may include:

• email address and phone number;
• request-an-invite form responses and submission metadata;
• account, user, profile, and support identifiers;
• password-related, authentication, login, session, account-recovery, and new-device-verification records;
• email-confirmation records;
• country calling code, phone-number-validation information, and SMS request, delivery, error, and verification records;
• date of birth, age, and eighteen-plus eligibility records;
• display name, sex at birth, pronouns, language, state of residence, and supported-area information;
• account status, restrictions, settings, notification preferences, communication preferences, and privacy choices; and
• records of acceptance, acknowledgment, consent, withdrawal, or opt-out relating to the Terms, this Privacy Policy, checkout disclosures, purchase terms, notices, and other applicable choices.

Email confirmation establishes control of the submitted email address. Phone-number verification by SMS establishes access to the submitted phone number.

Date-of-birth entry supports eighteen-plus eligibility confirmation but does not, by itself, confirm identity, account ownership, or background.

3.3 Profile, Preferences, Location, Photos, and User Content

We collect information you provide for your profile or through Service features.

This may include profile photos, gallery photos where supported, profile text, prompts, interests, lifestyle information, relationship or marital-status information you choose to provide, age as displayed, profile location, discovery preferences, sexual orientation if you choose to provide it, information reflecting the gender or genders you choose to meet, visibility settings, photo-sharing choices, and other profile or preference information.

We may collect content and materials that you upload, submit, display, send, link to, or otherwise make available, including photos, messages, attachments, screenshots, evidence, reports, appeals, support communications, privacy requests, security reports, legal notices, rights complaints, Feedback, and other materials you provide.

Cuddle may process location information that you provide, such as profile location or state of residence, and approximate location inferred from an IP address or similar permitted signals.

3.4 Likes, Matches, Messages, and Service Activity

We may 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 timestamps and account identifiers;
• daily First-Like usage, remaining allowance, limit and reset records, and paywall displays;
• Match, unmatch, block, and conversation records;
• message content, attachments, sender and recipient identifiers, timestamps, delivery information, and related metadata;
• reports, safety actions, anti-spam actions, external-contact-detail restrictions, and moderation-related feature activity; and
• pages viewed, links selected, settings changed, searches or filters used, errors encountered, and other Service interactions.

In-Service messages are not end-to-end encrypted. Additional information about message processing and visibility appears in Section 6.

3.5 Premium, Checkout, Billing, and Payment Information

We may collect or receive information relating to Free Access, Premium, direct checkout, payment authorization, activation, expiration, refunds, and payment disputes.

This may include:

• Free Access, Premium, promotional, or complimentary access status;
• the product, functionality, thirty-day access period, price, currency, and applicable taxes, if any, displayed at checkout or charged in connection with the purchase;
• checkout, purchase, transaction, authorization, receipt, and billing identifiers;
• payment-method type, limited payment-method details, billing information, and billing ZIP code made available by payment participants;
• payment, settlement, failure, reversal, refund, statutory-cancellation, access-adjustment, chargeback, and payment-dispute status;
• Premium activation and expiration information;
• the billing descriptor disclosed for the transaction;
• device, browser, IP-address, session, fraud-prevention, and payment-risk information connected to checkout or a transaction; and
• communications and records relating to billing support, unauthorized transactions, duplicate charges, refunds, statutory cancellations, chargebacks, and disputes.

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

3.6 Support, Reports, Appeals, Safety, and Legal Information

We may collect information when you use the Help Center, contact support, submit a report, request a refund or cancellation, 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 identifiers, ticket or request identifiers, the substance of communications, categories and descriptions, attachments, screenshots, evidence, transaction references, request status, routing information, response records, and related timestamps.

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

3.7 Device, Browser, Session, Cookie, Security, and Risk Information

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

This may include IP address, approximate location inferred from IP address, device type, operating system, browser type and version, language, time zone, referring page, Service or web version, cookie identifiers, local-storage identifiers, session identifiers, authentication events, login history, new-device records, pages and features used, network and request information, error and diagnostic information, and security logs.

We may also collect bot-prevention responses, rate-limit information, suspicious-activity signals, related-account or device signals, fraud-prevention information, payment-risk information, account-takeover indicators, and records used to protect the Service and enforce applicable terms.

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

3.8 Limited, Risk-Based Account Review Information

Cuddle does not routinely require an identity-document review, government ID review, or photo or selfie review for every user or as part of ordinary account registration.

In limited, risk-based circumstances, Cuddle may collect identity-document images, government ID images or information, photo or selfie review materials, and related submission information where reasonably necessary to investigate or address suspected impersonation, scams, fraud, prohibited commercial solicitation, account farming, coordinated or deceptive account activity, payment risk, safety concerns, account recovery, account integrity, legal or privacy 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.

Where Cuddle requests review materials, the materials must be submitted only through the authenticated review flow made available through the Service.

After the review is completed and related operational, safety, fraud-prevention, dispute, and legal needs are resolved, Cuddle places submitted review images into its operational deletion process. Deletion may be subject to reasonable processing periods, backup cycles, legal holds, applicable law, and limited technical or operational requirements.

Cuddle may retain a limited review-result record but does not ordinarily retain a continuing active copy of the submitted review image after the applicable deletion process is completed. Sections 8 and 11 provide additional information.

3.9 Information Not Routinely Collected During Ordinary Registration

Ordinary registration does not routinely require identity-document images, government ID images, or photo or selfie review materials. This does not apply to profile photos or other User Content submitted for display or use through the Service.

Do not submit passwords, authentication codes, full payment card information, full bank credentials, identity-document images, government identification, photo or selfie review materials, private keys, wallet credentials, medical records, information about minors, or other highly sensitive information through ordinary email, general support channels, in-Service messages, profile fields, reports, appeals, or mail.

Where Cuddle requests limited review materials, use only the authenticated review flow made available through the Service.

4. Sources of Personal Information

4.1 Information You Provide

We collect personal information directly from you when you request an invitation, create or manage an account, complete registration, provide profile information, upload photos or other User Content, select preferences, send Likes or messages, complete checkout, make a purchase, contact support, submit a report or appeal, exercise a privacy right, or otherwise interact with Cuddle.

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

4.2 Information from Other Users

We may receive personal information about you from other users through Incoming Likes, Likes Back, Matches, messages, blocks, unmatches, reports, complaints, screenshots, attachments, evidence, and safety- or rights-related communications.

Information supplied by another user may be inaccurate, incomplete, outdated, or misleading and is not automatically treated as verified.

4.3 Information Collected or Generated Through the Service

We collect information automatically when you access or use the Service. This may include IP address, approximate location inferred from IP address, device and browser information, operating system, language, time zone, session identifiers, authentication events, pages or features used, links selected, errors, diagnostics, cookie or local-storage identifiers, and related technical or usage information.

We may generate account-status, eligibility, security, fraud-prevention, payment-risk, moderation, support-routing, feature-access, and enforcement records from account, device, session, transaction, report, and Service activity.

4.4 Information from Operational Service Providers

We may receive information from providers that help operate, secure, and support Cuddle.

For example, Typeform may provide request-an-invite form responses and submission-related information. Twilio may provide phone-number validation and SMS-delivery information. Intercom may provide Help Center activity, support communications, ticket information, attachments, routing information, and request-status records. Google reCAPTCHA may provide bot-prevention and security signals.

AWS and other cloud, communications, security, and operational providers may generate logs, delivery records, diagnostic information, or service-status records on Cuddle’s behalf.

4.5 Information from Payment Participants

When you use Cuddle’s authorized checkout, we may receive limited information from payment processors, payment-method providers, banks, card issuers, or card networks.

This may include transaction and authorization status, payment-method type, limited payment-method details, billing information, transaction or receipt identifiers, refunds, reversals, chargebacks, disputes, and fraud-prevention or payment-risk information.

Full payment card details are not intended to be received or stored on Cuddle-controlled systems.

4.6 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 explained in Section 5.

5. How We Use Personal Information

5.1 Overview

Cuddle uses personal information to provide, operate, secure, support, administer, improve, and enforce the Service; manage invitation requests; process purchases and other requests; protect users and the Service; and comply with applicable law.

Not every purpose described in this Section applies to every person, account, device, purchase, report, request, review, or interaction. We use personal information for the purposes described in this Privacy Policy, applicable notices, the Terms, the Additional Terms, and applicable law.

5.2 Invitations, Registration, and Service Operation

We use personal information to receive and manage nationwide request-an-invite submissions; communicate about registration and account access; prevent abuse; honor applicable communication choices; and maintain related records.

We also use personal information to create and operate accounts; provide profiles, discovery, Likes, Matches, messaging, settings, notifications, visibility and photo-sharing controls, reporting, blocking, unmatching, support, and other Service functionality.

We may use profile information, preferences, Service activity, account status, and technical information to display content, apply settings, organize profiles, provide recommendations, personalize non-price Service experiences, and present relevant notices or controls.

5.3 Authentication, Eligibility, Recovery, and Account Security

We use personal information to authenticate accounts; confirm access to email addresses and phone numbers; support eighteen-plus and supported-area eligibility; manage login, password reset, new-device verification, account recovery, and session security; and maintain account status and permissions.

We may use account, device, browser, IP-address, approximate-location, phone-verification, support, security, fraud-prevention, and moderation information to prevent unauthorized access, account takeover, duplicate or abusive registrations, circumvention, and misuse.

5.4 Likes, Matches, and Messaging

We use personal information to operate profile discovery, Incoming Likes, Likes Back, First Likes, Matches, and Matched-Member Messaging.

This includes determining whether another member has already sent you an Incoming Like; whether your attempted Like is a Like Back or a First Like; whether Premium or another authorized form of First-Like access is required; applying First-Like limits; forming Matches; and routing, storing, delivering, filtering, restricting, and supporting messages.

Cuddle does 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.

5.5 Free Access, Premium, and Purchases

We use personal information to determine Free Access or Premium status; display paywalls and purchase disclosures; apply daily First-Like allowances; activate and expire Premium; maintain purchase and receipt records; and provide purchased, promotional, complimentary, or otherwise authorized access.

We also use personal information to process checkout, payment authorization, applicable taxes, refunds, statutory cancellations, access adjustments, billing questions, unauthorized-transaction concerns, chargebacks, and payment disputes.

Cuddle does not use safety, moderation, fraud-prevention, payment-risk, account-history, or review information to personalize the price charged to an individual user.

5.6 Safety, Moderation, Reporting, and Enforcement

We use personal information to review reports, protect users and minors, moderate content, investigate suspected violations, address safety concerns, enforce applicable terms, preserve relevant records, and respond to appeals.

This may include reviewing accounts, profiles, photos, messages, links, reports, attachments, screenshots, evidence, device or session information, account history, risk information, support communications, and moderation or enforcement records.

Human, automated, and machine-assisted tools may help detect spam, bots, scams, impersonation, harassment, account takeover, unauthorized payment use, minor-safety concerns, prohibited commercial activity, and other misuse.

5.7 Limited, Risk-Based Account Review

In limited, risk-based circumstances, we may use information submitted through the authenticated review flow for an identity-document review, government ID review, or photo or selfie review to investigate or address suspected impersonation, scams, fraud, prohibited commercial solicitation, account farming, coordinated or deceptive activity, payment risk, safety concerns, account recovery, account integrity, legal or privacy compliance, moderation, or enforcement.

Cuddle does not use submitted review images or limited review-result records to personalize prices, rank users, recommend or match users, advertise, create public-facing profile content, or provide financial products or services.

5.8 Fraud Prevention, Payment Risk, and Service Integrity

We use personal information to detect, prevent, investigate, document, and respond to fraud, scams, bots, account farming, suspicious registrations, account takeover, payment-method testing, unauthorized payment use, transaction laundering, refund or chargeback abuse, sanctions risk, payment disputes, and attempts to evade account, payment, safety, or enforcement controls.

We may combine account, device, browser, IP-address, session, transaction, billing, support, safety, moderation, and risk information for these purposes and to identify related activity where permitted by law.

5.9 Support, Communications, and Requests

We use personal information to operate the Help Center; route and respond to support requests; troubleshoot technical issues; send invitation, account, security, purchase, billing, policy, and Service communications; and respond to privacy, cancellation, safety, security, legal, rights-related, and accessibility requests.

We may use communication preferences and required consent, withdrawal, or opt-out records to manage Cuddle communications.

5.10 Legal Compliance and Protection of Rights

We use personal information to comply with applicable law, court orders, lawful government requests, regulatory requirements, tax and accounting obligations, recordkeeping duties, and valid legal process.

We may also use personal information to establish, exercise, or defend legal claims; protect users, Cuddle, service providers, payment participants, and the public; preserve evidence; and enforce agreements.

5.11 Testing, Analytics, and Improvement

We may use personal information and, where appropriate, aggregated or de-identified information to test, troubleshoot, measure, maintain, and improve the Service; diagnose errors; evaluate feature performance; conduct controlled product tests; improve safety and fraud-prevention systems; and understand Service usage.

Where implemented, analytics and performance tools may be used as described in Section 10 and the Cookie / Tracking Policy.

Cuddle will not use the substance of private in-Service direct messages to train general-purpose AI models for unrelated third-party commercial use.

5.12 Use Restrictions and No Prohibited Purpose

Cuddle does not use personal information to provide credit, lending, insurance, employment, housing, consumer-reporting, banking, brokerage, securities, money-transmission, payment-facilitation, marketplace, stored-value, wallet, 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, sexual services, escort services, compensated dating, sugar arrangements, abuse, exploitation, unsafe conduct, or unlawful activity.

6. Profiles, Likes, Matches, Messages, User Content, and Visibility Limits

6.1 Overview

Cuddle processes profile information, User Content, Likes, Matches, messages, and related activity to provide discovery, communication, safety, moderation, support, and account-management functionality.

Information you make available may be visible to other members, intended recipients, authorized Cuddle personnel, and service providers acting for Cuddle.

Visibility depends on Service functionality, account status, settings and actions, blocks, unmatches, safety controls, moderation, technical availability, and applicable law.

6.2 Profile Visibility and Discovery

A member profile may display a display name, age, pronouns, profile location, profile photos, prompts, interests, preferences, and other information provided for display.

Cuddle does not ordinarily display a member’s full date of birth. Information collected for eligibility, security, support, fraud prevention, payment risk, or limited account review is not automatically displayed on a member-facing profile.

Cuddle may use profile, preference, location, interaction, account-status, and safety information to determine which profiles appear in discovery and how they are organized.

Cuddle does not guarantee that every profile will be visible to every member or receive a particular number of views, Likes, Matches, or messages.

6.3 Incoming Likes and Likes You

An “Incoming Like” is a Like another member has already sent to you.

Eligible Free Access currently permits a member to review Incoming Likes and view the profiles of members who sent them, subject to account status and applicable restrictions.

Cuddle may process account identifiers, Like records, block status, moderation status, and technical records to determine whether an Incoming Like exists and remains available.

An Incoming Like may become unavailable if the sending account is deleted, restricted, blocked, unmatched, removed, or otherwise ineligible for display.

6.4 Likes Back, First Likes, and Matches

A “Like Back” is a Like sent to a member who has already sent you an Incoming Like. A “First Like” is a Like initiated toward a member who has not already sent you an Incoming Like.

Cuddle processes Like history and account records to determine whether an attempted Like is a Like Back or a First Like and whether Premium or another authorized form of First-Like access is required.

A “Match” is formed when two members mutually Like each other. Cuddle may display Match status and make Matched-Member Messaging available where supported.

A Like or Match does not require either member to reply, continue communicating, share information, move off the Service, or meet.

6.5 In-Service Messages and 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; respond to reports; prevent fraud or abuse; enforce applicable terms; comply with law; and protect users and the Service.

Do not use messages to send passwords, authentication codes, full payment card or bank information, identity-document images, government identification, photo or selfie review materials, private keys, wallet credentials, medical records, information about minors, or other highly sensitive information.

Where Cuddle requests review materials, use only the authenticated review flow made available through the Service.

Cuddle does not guarantee that a message will be delivered, seen, read, retained, or answered.

6.6 Profile Photos, Gallery Content, and Sharing Controls

Profile photos and other photos you submit are User Content. They may be displayed through profiles, discovery, Incoming Likes, Likes, Matches, messaging, or other Service functionality according to applicable settings and features.

Where Cuddle provides gallery or photo-sharing controls, those controls govern ordinary in-Service visibility but cannot prevent a recipient from copying, saving, photographing, screenshotting, recording, forwarding, publishing, or disclosing content outside Cuddle.

A profile photo, gallery permission, account indicator, review, or safety tool does not guarantee identity, ownership, authenticity, intentions, safety, or future conduct.

6.7 Copies, Screenshots, and Off-Service Disclosure

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

Cuddle may restrict such conduct under the Terms and Community Guidelines but cannot control every recipient, device, external platform, or off-Service disclosure.

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

6.8 Blocking, Unmatching, Removal, and Deletion Limits

Blocking or unmatching may restrict future in-Service visibility or communication but may not remove information already received, copied, saved, screenshotted, recorded, or disclosed.

Removing content or deleting an account may remove or deactivate information from active Service views. It may not immediately or completely remove messages, recipient copies, reports, safety or support records, purchase records, fraud-prevention or payment-risk records, legal records, logs, backups, or search indexes that Cuddle is permitted or required to retain.

Additional retention and deletion information appears in Section 11.

7. Premium, Direct Checkout, Billing, Refunds, and Payment Risk

7.1 Overview and Current Premium Model

Cuddle processes personal information to provide Free Access, optional Premium, direct checkout, billing support, refunds, statutory cancellations, chargebacks, and payment-risk controls.

Purchased Premium is thirty-day, fixed-term, non-renewing access to Cuddle-operated First-Like functionality. Each purchase is a separate one-time transaction. Cuddle does not currently offer subscriptions, recurring billing, automatic renewal, automatic repurchase, automatic trial-to-paid conversion, or external purchase channels.

Premium status does not control access to Incoming Likes, Likes Back, Matches, or Matched-Member Messaging, which remain part of eligible Free Access subject to applicable restrictions.

7.2 Direct Checkout and Contracting Seller

Third Hub US, Inc., d/b/a Cuddle is the contracting seller for direct purchases completed through Cuddle’s authorized checkout.

Before payment authorization, checkout may display the product, thirty-day access period, First-Like functionality, daily allowance, total price, currency, any applicable taxes, payment-method type, activation and expiration information, refund and statutory-cancellation information, intended billing descriptor, and other purchase-specific terms.

We process checkout and authorization records to document what was displayed, what you authorized, the applicable terms and policy versions, and the account receiving Premium.

7.3 Payment and Transaction Information

Cuddle may receive limited payment and transaction information from authorized payment processors, payment-method providers, banks, card issuers, and card networks.

Depending on the provider, payment method, and transaction, this may include:

• transaction, authorization, order, or receipt identifiers;
• payment-method type and limited payment-method details;
• billing name, address, or ZIP code;
• price, currency, and applicable taxes;
• charges imposed independently by a payment participant, where made available to Cuddle;
• authorization, settlement, failure, reversal, or refund status;
• billing-descriptor information;
• chargeback or payment-dispute information; and
• fraud-prevention and payment-risk information.

The exact information received depends on the provider, payment method, transaction, and applicable payment rules.

7.4 Full Payment Card Information

Full payment card details are intended to be submitted directly through processor-hosted or processor-approved payment fields or flows.

Full card numbers and card security codes are not intended to be received or stored on Cuddle-controlled systems.

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

7.5 Activation, Use, and Expiration Records

We process payment authorization, Premium activation, daily First-Like usage, remaining allowance, access restrictions, technical availability, and expiration records to provide and administer purchased access.

Premium generally begins when payment is authorized and access is activated for the eligible account. Activation may be delayed while a transaction, account, security, fraud, payment-risk, technical, legal-compliance, or account-review issue is evaluated.

Premium expires automatically at the date and time associated with the purchase record. Continued purchased access requires a new checkout and separate payment authorization.

7.6 Refunds, Statutory Cancellations, and Access Adjustments

We process account, purchase, activation, usage, support, technical, and payment information to evaluate refund requests, statutory-cancellation requests, duplicate-charge concerns, and access-adjustment requests.

If Premium is not activated or becomes materially unavailable because of a Cuddle-controlled technical error, we may process diagnostic, availability, support, refund, and adjustment records to restore access or provide an appropriate remedy under applicable terms and law.

Submitting a request does not guarantee a refund, adjustment, extension, or other result.

7.7 Unauthorized Transactions, Chargebacks, and Payment Disputes

We may use checkout, receipt, account, device, browser, IP-address, session, activation, usage, support, and transaction records to investigate and respond to an unauthorized-transaction claim, billing error, chargeback, or payment dispute.

We may disclose relevant information to payment participants, banks, card issuers, card networks, regulators, courts, or other lawful recipients where reasonably necessary and permitted or required by law.

Good-faith exercise of a non-waivable payment or consumer right is not prohibited.

7.8 Fraud Prevention and Payment Risk

We use personal information to detect, prevent, investigate, and respond to card testing, payment-method testing, unauthorized payment use, account takeover, transaction laundering, sanctions risk, refund or chargeback abuse, billing inconsistencies, suspicious device or network activity, and other material payment risk.

Cuddle and payment participants may authenticate, approve, decline, delay, review, restrict, reverse, or refund a transaction as permitted by applicable law and payment rules.

Cuddle may restrict checkout, block a payment method, delay activation, limit Premium, preserve records, or take account action where reasonably necessary to address fraud, safety, compliance, or payment risk.

Where a limited, risk-based account review is requested for a payment-risk matter, review materials must be submitted only through the authenticated review flow made available through the Service.

7.9 No User-to-User Payments and Relationship to Other Terms

A Cuddle purchase is payment to Third Hub US, Inc., d/b/a Cuddle for Cuddle-operated digital functionality. It is not payment to or for another member.

Cuddle does not provide user-to-user payments, tips, donations, payouts, stored value, wallets, virtual credits, gift cards, cryptocurrency transfers, money transmission, payment facilitation, marketplace payments, banking, lending, investment, brokerage, escrow, or other financial services.

The Terms of Service, Purchase Terms, Paid Features Terms, State-Specific Terms & Cancellation Notices, checkout disclosures, and applicable law provide additional information about purchases, refunds, cancellations, billing, and payment rights.

8. Sensitive Information, Age, Location, and Limited Account Review

8.1 Overview and Sensitive Information

Cuddle may process information that is sensitive because it relates to age, profile characteristics, relationship or marital status, sexual orientation you provide, private communications, location, payment activity, safety matters, or account review.

Cuddle uses and discloses sensitive personal information only as reasonably necessary and proportionate to provide requested functionality, protect users and the Service, prevent fraud or abuse, process authorized transactions, comply with law, and perform other disclosed purposes.

Cuddle does not use sensitive personal information for targeted advertising, unrelated profiling, unrelated commercial purposes, or price personalization. Cuddle does not sell personal information and does not share it for targeted advertising.

8.2 Date of Birth and 18+ Eligibility

Cuddle collects date of birth to determine eighteen-plus eligibility, calculate age, prevent minor access, and support legal and safety obligations.

Cuddle may display age but ordinarily does not display a full date of birth. Date-of-birth entry alone does not confirm identity, account ownership, background, or safety.

8.3 Location and Supported Area

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

We use this information for supported-area eligibility, discovery, localization, security, fraud prevention, payment-risk management, state-specific notices, and compliance.

Cuddle does not use precise geolocation unless a feature or review requires it and Cuddle provides any notice, choice, or consent required by law.

8.4 No Routine Review for Every User

Cuddle does not routinely require an identity-document review, government ID review, or photo or selfie review for every user or during ordinary registration.

Profile photos and other User Content submitted for display or use through the Service are separate from limited account-review materials.

8.5 Limited, Risk-Based Account Review

In limited, risk-based circumstances, Cuddle may request an identity-document review, government ID review, or photo or selfie review to address suspected impersonation, scams, fraud, prohibited commercial solicitation, account farming, deceptive activity, payment risk, safety concerns, account recovery, account integrity, legal or privacy compliance, moderation, or enforcement.

Not every user is subject to review. If Cuddle cannot resolve a material risk or reasonably confirm necessary information, Cuddle may restrict, delay, or decline access, functionality, checkout, or another request under the Terms.

8.6 Review Materials and Authenticated Review Flow

A requested review may involve identity-document images, government ID images or information, photo or selfie review materials, submission records, and account information.

Review materials must be submitted only through the authenticated review flow provided through the Service. Do not submit them through ordinary email, general support channels, in-Service messages, profile fields, reports, appeals, Typeform, or mail.

Cuddle uses review materials only for the applicable review and related safety, fraud-prevention, account-integrity, compliance, moderation, enforcement, or dispute purposes described at collection.

8.7 Deletion and Limited Review-Result Records

After the review is completed and related operational, safety, fraud-prevention, dispute, and legal needs are resolved, Cuddle places submitted review images into its operational deletion process.

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

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

8.8 Review Limits and Privacy Rights

Cuddle does not use review images or limited review-result records to personalize prices, rank users, recommend or match users, advertise, or create public-facing profile content.

A completed review is not a criminal background check, sex-offender-registry check, relationship-status check, intention check, or safety clearance. It does not guarantee identity, age, location, background, truthfulness, safety, compatibility, account ownership, or future conduct.

Section 11 explains retention and deletion criteria. Section 13 explains privacy rights and request procedures.

9. How We Disclose Personal Information and Use Service Providers

9.1 Overview

Cuddle discloses personal information as described in this Privacy Policy, at your direction, to provide and protect the Service, to service providers and payment participants, and where permitted or required by law.

Not every recipient receives every category. Disclosure depends on the feature, transaction, request, report, review, risk, legal requirement, and recipient’s role. A disclosure does not necessarily constitute a sale or targeted-advertising sharing.

9.2 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 functionality.

A Like is disclosed to its intended member. Match status is disclosed to both matched members. Messages, attachments, and sender information are disclosed to the intended recipient and processed under Section 6.

Information collected for security, payment risk, moderation, or limited account review is not automatically displayed to other members.

Cuddle does 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, enforce, explain, or review an action, while limiting identifying information where reasonably possible.

9.3 Amazon Web Services

Cuddle uses Amazon Web Services (“AWS”) as a cloud infrastructure provider to host and operate portions of the Service.

AWS may process personal information on Cuddle’s behalf where information is stored, transmitted, logged, backed up, secured, indexed, searched, or otherwise processed through AWS services configured by Cuddle.

This may include account, profile, User Content, message, interaction, support, safety, moderation, security, fraud-prevention, payment-risk, purchase, and limited account-review records.

9.4 Twilio

Cuddle uses Twilio to support phone-number validation and SMS verification-code delivery.

We may disclose a submitted phone number, country calling code, verification-request information, and related delivery, status, error, security, or abuse-prevention information to Twilio to provide, secure, monitor, and troubleshoot phone-number verification.

9.5 Intercom

Cuddle uses Intercom to provide the Help Center, manage customer-support communications, route requests, and maintain support and ticket records.

Depending on the features used, Intercom may process account identifiers, contact information, request or conversation content, attachments, device or browser information, routing information, request status, and timestamps on Cuddle’s behalf.

Do not submit account-review images or other highly sensitive information through ordinary Intercom or general-support communications.

9.6 Typeform

Cuddle uses Typeform to operate its request-an-invite form.

Depending on the form and settings, Typeform may process contact information, form responses, technical information, and submission metadata on Cuddle’s behalf and under its applicable terms and privacy practices.

Cuddle uses this information to receive and manage nationwide request-an-invite submissions, communicate about registration and account access, prevent abuse, honor applicable communication choices, and maintain related records.

Do not submit payment information, identity-document images, government identification, photo or selfie review materials, medical information, information about minors, or other highly sensitive information through that form.

9.7 Google reCAPTCHA

Cuddle uses Google reCAPTCHA for bot prevention and registration security.

Google may process IP address, device and browser information, interaction signals, and related security information under its applicable terms and privacy practices.

9.8 Payment Participants

Cuddle may disclose personal information to authorized payment processors, payment-method providers, banks, card issuers, card networks, fraud-prevention providers, and payment-risk providers for checkout, authorization, settlement, receipts, refunds, statutory cancellations, reversals, chargebacks, disputes, fraud prevention, and payment-risk management.

This may include account and transaction identifiers, purchase amount, currency, billing information, payment-method type, limited payment-method details, device, browser, IP-address, session, authorization, refund, dispute, and risk information.

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

9.9 Other Operational Service Providers

Cuddle may use providers supporting hosting, storage, communications, email delivery, security, fraud prevention, payment-risk management, moderation, analytics where implemented, consent management, legal compliance, and other operations.

These providers may process personal information on Cuddle’s behalf only as reasonably necessary for their function, subject to their roles, applicable agreements, Cuddle’s configurations, and law.

Typeform and Intercom are not used to collect the account-review images described in Section 8. Those materials must be submitted through the authenticated review flow made available through the Service.

Some third-party services may process information under their own terms and privacy policies where they act independently.

9.10 Safety, Legal, Regulatory, and Rights-Related Disclosures

We may disclose personal information to courts, regulators, law-enforcement authorities, emergency services, government agencies, payment participants, rights holders, or other lawful recipients where reasonably necessary to comply with law; address serious safety concerns; protect users, minors, Cuddle, or the public; investigate fraud, abuse, account takeover, prohibited conduct, or security incidents; preserve evidence; enforce terms; respond to rights-related claims; or establish, exercise, or defend legal claims.

Cuddle may challenge, narrow, or limit a request where appropriate and permitted by law.

9.11 Professional Advisers and Business Transfers

We may disclose personal information to lawyers, auditors, accountants, insurers, consultants, and other professional advisers where reasonably necessary.

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 law and appropriate safeguards.

9.12 At Your Direction or With Your Authorization

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

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

9.13 No Sale, No Targeted-Advertising Sharing, and Provider Limits

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

Cuddle does not authorize service providers acting for Cuddle to use personal information for unrelated advertising, user monetization, or purposes outside their role, subject to independent legal obligations.

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

Additional rights and opt-out information appear in Sections 10 and 13.

10. Cookies, Tracking, Analytics, Communications, and Preferences

10.1 Overview

Cuddle may use cookies, pixels, tags, scripts, local or session storage, browser or device identifiers, security tools, communications tools, consent tools, preference tools, and similar technologies in connection with the Service.

These technologies may be provided by Cuddle or service providers acting for Cuddle. Not every technology applies to every user, device, page, feature, invite form, support interaction, or checkout flow.

The Cookie / Tracking Policy provides additional information and controls cookie-specific subjects.

10.2 Strictly Necessary, Authentication, and Session Technologies

Cuddle may use technologies necessary to load pages, maintain availability, authenticate accounts, keep users signed in, manage sessions, remember settings, support account recovery, operate profiles and messaging, support authenticated account-review flows, deliver Legal pages, and maintain privacy choices.

Blocking or deleting these technologies may prevent parts of the Service from operating correctly.

10.3 Security, Fraud-Prevention, and Payment-Risk Technologies

Cuddle 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 risk.

Cuddle uses Google reCAPTCHA for bot prevention and registration security. Google may process technical and interaction information under its applicable terms and privacy practices.

These technologies reduce risk but do not guarantee detection or prevention of every harmful act.

10.4 Checkout and Purchase-Support Technologies

Cuddle and payment participants may use technologies to support direct checkout, payment authentication, transaction status, receipts, Premium activation and expiration, refunds, statutory cancellations, chargebacks, payment disputes, and fraud prevention.

These technologies do not create a subscription, recurring billing, automatic renewal, automatic repurchase, wallet, stored value, user-to-user payment, or external purchase channel.

Full payment card details are intended to be submitted through processor-hosted or processor-approved fields or flows.

10.5 Intercom and Support Technologies

Where Intercom functionality is used, Intercom may use cookies, local storage, session, browser, device, and related information to provide the Help Center, support communications, request routing, and ticket management.

The technologies used may depend on whether you are signed in and the functionality Cuddle makes available.

Do not submit account-review images or other highly sensitive information through ordinary Intercom or general-support communications.

10.6 Typeform and Request-an-Invite Forms

A request-an-invite link may direct you to a form hosted by Typeform.

Typeform may use cookies and similar technologies and process browser, device, interaction, and submission information under its applicable terms and privacy practices.

Do not submit payment information, identity-document images, government identification, photo or selfie review materials, medical information, information about minors, or other highly sensitive information through the invite form.

10.7 Analytics and Performance Where Implemented

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

Cuddle does not use private messages, sensitive personal information, payment-related information, or limited account-review materials for targeted advertising. Cuddle does not sell personal information or share it for targeted advertising.

10.8 Cookie, Browser, Device, and Privacy Choices

Cuddle may provide cookie banners, settings, consent tools, preference controls, or other choices where required.

You may use browser, device, or operating-system controls to block or delete some cookies or storage technologies. Doing so may affect login, settings, security protections, support tools, invite forms, checkout, or other functionality.

Where applicable law requires Cuddle to recognize Global Privacy Control or another legally recognized opt-out preference signal, Cuddle will process that signal as required by law.

Changing a choice generally applies prospectively and may not delete records already created or information retained under Section 11.

10.9 Communications Preferences and Relationship to Other Terms

You may have choices about optional or marketing communications where offered. Cuddle may still send Service-related communications, including invitation, account, security, safety, purchase, billing, refund, cancellation, privacy, policy, support, report, appeal, and legal notices where necessary or permitted.

Changing a communication preference does not cancel a purchase, create a refund, stop a legal deadline, or change a required notice method.

This Section is supplemented by the Cookie / Tracking Policy, Section 13, the Contact / Legal Notices, and applicable law. More specific cookie choices and non-waivable rights control.

11. Retention, Deletion, Backups, Search Indexes, and Legal Records

11.1 Overview and Retention Criteria

Cuddle retains personal information for as long as reasonably necessary and proportionate to the purposes described in this Privacy Policy and applicable law.

Retention varies by category and context. Cuddle may consider:

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

Cuddle does not retain every category for the same period.

11.2 Invite Requests, Active Accounts, Messages, and User Content

Cuddle may retain request-an-invite submissions while reasonably necessary to manage nationwide invitation requests, communicate about registration and account access, prevent abuse, honor applicable communication choices, and maintain related records.

While an account is active, Cuddle may retain account, profile, photo, preference, setting, Like, Match, message, User Content, block, unmatch, report, support, and related records to provide, secure, support, moderate, and administer the Service.

Removing content, blocking, unmatching, or deleting a conversation from a Service view may not result in complete deletion. Copies may remain with recipients, on their devices, in screenshots or recordings, or outside Cuddle’s control.

11.3 Account Deletion and Privacy Deletion Requests

You may request account deletion through methods Cuddle makes available and may submit a privacy-law deletion request under Section 13.

Account deletion may disable access and remove or deactivate profile information from ordinary Service views. It does not automatically delete every message, purchase, report, support, safety, security, invite, or other associated record.

Cuddle may retain limited information after deletion where permitted for safety, security, fraud prevention, payment risk, moderation, disputes, compliance, tax, accounting, audit, enforcement, records management, or protection of users and the Service.

Account deletion does not automatically reverse a purchase, create a refund, resolve a chargeback or payment dispute, or remove information another person already received.

Cuddle may limit or deny a deletion request only where permitted by law.

11.4 Purchase, Billing, Refund, and Payment Records

Cuddle may retain records relating to checkout, one-time purchases, payment authorization, receipts, Premium activation and expiration, billing descriptors, refunds, statutory cancellations, access adjustments, disputed charges, chargebacks, taxes, accounting, audits, fraud prevention, and payment risk.

Retention of these records does not create a subscription, recurring billing, automatic renewal, automatic repurchase, or future charge.

11.5 Safety, Security, Fraud, Enforcement, and Review Records

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

Where Cuddle conducts a limited, risk-based identity-document review, government ID review, or photo or selfie review, materials must be submitted through the authenticated review flow made available through the Service.

After the review is completed and related operational, safety, fraud-prevention, dispute, and legal needs are resolved, Cuddle places submitted review images into its operational deletion process. Deletion may be subject to reasonable processing periods, backup cycles, legal holds, applicable law, and operational requirements.

Cuddle may retain a limited review-result record, including the review type, result or status, completion date, internal reference or reason code, account identifier, and whether another review is required. Cuddle does not ordinarily retain a continuing active copy of the submitted image after the deletion process is completed.

11.6 Backups, Logs, Search Indexes, and Service-Provider Systems

Personal information may remain temporarily in backups, logs, archives, recovery or security systems, search indexes, and service-provider systems before deletion, isolation, de-indexing, or expiration.

Cuddle may index records to support discovery, account administration, invitation management, purchases, safety, moderation, fraud prevention, payment-risk management, and enforcement. Deletion from an active database may require corresponding removal from a search index and may not appear in every system immediately.

Service providers may retain information to provide services, follow lawful instructions, protect systems, maintain backup or audit records, prevent fraud, or meet legal obligations.

Cuddle may not be able to delete information controlled by another user, an external platform, a payment participant, a regulator, a court, law enforcement, or another independent third party.

11.7 Legal Holds, Open Matters, and Request Records

Cuddle may preserve information subject to a legal hold, subpoena, court order, regulatory or law-enforcement request, audit, tax or accounting obligation, chargeback, payment dispute, fraud investigation, safety matter, privacy request, security incident, rights complaint, appeal, or legal claim.

Cuddle may retain limited records showing that a request was received, confirmed, completed, limited, denied, appealed, or resolved, where permitted by law.

11.8 De-Identified or Aggregated Information

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

When information is no longer reasonably necessary, Cuddle may delete, de-identify, aggregate, isolate, or otherwise dispose of it, subject to applicable law and the limits described above.

12. Security, Safety Processing, Administrative Access, and Breach Notices

12.1 Overview

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

Safeguards vary based on the nature and sensitivity of the information, the Service component, the risks presented, technology, and law.

No safeguard eliminates every risk. This Section describes Cuddle’s general approach and does not guarantee that personal information, accounts, communications, systems, or Service functionality will always remain secure.

12.2 AWS and Cloud Infrastructure

Cuddle uses Amazon Web Services (“AWS”) to host and operate portions of the Service.

Cuddle may use AWS-based authentication, databases, computing, storage, logging, backup, recovery, and search or indexing functionality.

Security responsibilities are shared between AWS and Cuddle. Cuddle remains responsible for configuring and managing its AWS environment and protecting Cuddle-controlled accounts, applications, access methods, data, and workloads.

12.3 Authentication and Account Security

Cuddle uses account-authentication and security controls designed to protect accounts and Service access.

These controls may include email confirmation, password requirements, phone-number verification by SMS, new-device verification, session controls, account recovery, bot-prevention tools, rate limits, suspicious-activity review, and account restrictions.

Cuddle may use device, browser, IP-address, session, authentication, phone-verification, and risk information to detect or respond to account takeover, unauthorized access, abusive registrations, credential misuse, circumvention, and other security concerns.

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

12.4 Administrative Access Controls

Cuddle limits administrative access to personal information based on operational roles and authorized business purposes.

Cuddle uses authentication, role-based administrative access controls, and other restrictions designed to limit access to personnel and systems that need information for support, safety, moderation, fraud prevention, payment-risk management, security, or legal compliance.

Administrative permissions may vary by role. Cuddle may restrict or remove access when it is no longer appropriate.

12.5 Safety, Moderation, Fraud, and Review Processing

Cuddle may process account, profile, message, report, device, session, purchase, support, moderation, security, fraud-prevention, payment-risk, and enforcement information to investigate and address safety or integrity concerns.

This may include suspected scams, impersonation, prohibited commercial activity, account farming, harassment, minor-safety concerns, account takeover, payment abuse, circumvention, and violations of applicable terms.

Where Cuddle conducts a limited, risk-based account review, review materials must be submitted through the authenticated review flow made available through the Service and are handled as described in Sections 8 and 11.

Safety, security, moderation, fraud-prevention, payment-risk, and review tools may be incomplete, delayed, inaccurate, unavailable, or circumvented and do not guarantee that a user or activity is safe, truthful, lawful, or appropriate.

12.6 Incident Response and Breach Notices

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

Where law requires notification of a breach or security incident, Cuddle will notify affected persons, regulators, or other recipients by a permitted method within the required period.

A notice may describe the incident, information involved, steps taken, protective measures and contact information, as appropriate and permitted by law.

12.7 Security Reports

Report suspected account compromise, phishing, unauthorized access, vulnerability, or another concern to:

security@cuddle-global.com

Do not publicly disclose a security issue or access, copy, alter, retain, or expose personal information beyond what is reasonably necessary to report it.

Cuddle’s security channel is not an emergency-response channel. If there is immediate danger, contact local emergency services.

12.8 No Absolute Security Guarantee

Internet transmission, cloud infrastructure, storage, software, devices, accounts, authenticated review flows, and operations involve risk.

Cuddle cannot guarantee that unauthorized access, disclosure, loss, misuse, alteration, interruption, or another security incident will never occur.

Nothing in this Section limits any non-waivable data-security, breach-notification, privacy, consumer-protection, reporting, court-access, or other right under applicable law.

13. Privacy Rights and U.S. State Privacy Notices

13.1 Overview

Depending on where you reside and applicable law, you may have rights concerning personal information processed by Cuddle.

These rights may include confirmation, access, deletion, correction, portability, consent withdrawal, limits on certain uses of sensitive information, opt-outs, appeals, authorized-agent requests, and protection against unlawful discrimination.

Not every right applies to every person, request-an-invite submission, account, category of information, processing activity, or circumstance. Rights may be subject to verification, exceptions, limitations, and procedures under applicable law.

13.2 Right to Confirm and Access

Where applicable, you may request confirmation of whether Cuddle processes personal information about you and access to personal information associated with your request.

You may also be entitled to information about the categories of personal information collected, sources, purposes, categories or specific recipients where required, retention criteria, and other processing details required by law.

Cuddle may provide responsive information through an account interface, electronic file, written response, or another lawful method.

Access rights do not require Cuddle to disclose another person’s personal information, privileged information, confidential safety, security, fraud-prevention, payment-risk, or moderation information, trade secrets, proprietary systems, or information that law permits or requires Cuddle to withhold.

13.3 Right to Delete

Where applicable, you may request deletion of personal information that Cuddle collected from or about you, including information associated with an eligible request-an-invite submission or account.

Deletion may remove or deactivate account and profile information from active Service views, but it may not immediately or completely remove:

• messages or information already received, copied, saved, screenshotted, recorded, or disclosed by another person;
• purchase, receipt, refund, statutory-cancellation, chargeback, payment-dispute, tax, accounting, or audit records;
• safety, moderation, fraud-prevention, payment-risk, security, appeal, enforcement, or limited review-result records;
• information subject to a legal hold or reasonably necessary to establish, exercise, or defend legal claims;
• information in backups, logs, archives, recovery systems, search indexes, or service-provider systems pending ordinary deletion, isolation, de-indexing, or expiration processes; or
• information that Cuddle is permitted or required to retain.

Account deletion is not the same as a refund, statutory cancellation, chargeback, or payment dispute and does not automatically create or resolve one.

13.4 Right to Correct

Where applicable, you may request correction of inaccurate personal information, taking into account the nature of the information and the purposes for which it is processed.

Some profile or account fields may be directly editable. Other fields, including eligibility-related, security-related, purchase-related, or review-related information, may require support or privacy review.

Cuddle may request information reasonably necessary to evaluate a correction and may retain records of prior information and the correction where permitted for safety, fraud prevention, payment risk, account integrity, disputes, or legal compliance.

13.5 Right to Portability or a Copy

Where applicable, you may request a portable copy of personal information that you provided or that is otherwise covered by applicable law.

Cuddle may provide information in a reasonably usable electronic format where technically feasible and legally required.

Portability does not require Cuddle to provide internal risk scores, security logic, fraud-prevention or payment-risk methods, moderation logic, proprietary systems, another person’s information, or information outside the scope of applicable law.

13.6 Consent Withdrawal and Sensitive-Information Rights

Where Cuddle relies on consent for a processing activity, you may withdraw that consent as permitted by law. Withdrawal applies prospectively and does not make prior lawful processing unlawful.

Depending on your state and the processing involved, you may have rights concerning sensitive personal information, including rights to consent, withdraw consent, limit certain uses, request deletion, or receive specific notice.

A withdrawal or sensitive-information request may affect functionality or a process that reasonably requires the information. It does not automatically delete all records, cancel a purchase, create a refund, remove information already received by another person, or prevent retention permitted under Section 11.

13.7 Sale, Sharing, Targeted Advertising, Profiling, and Opt-Out Signals

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

Cuddle does not currently use personal information to make decisions producing legal or similarly significant effects concerning employment, housing, credit, insurance, lending, or access to essential services.

Where applicable law provides an opt-out right concerning sale, sharing, targeted advertising, or covered profiling, Cuddle will process a valid request as required by law. Because Cuddle does not currently engage in sale or targeted-advertising sharing, some opt-out requests or signals may have limited practical effect on current practices.

Where required by applicable law, Cuddle will recognize Global Privacy Control or another legally recognized universal opt-out mechanism in the manner required by law.

Security, authentication, fraud-prevention, payment-risk, account-integrity, Service-operation, and legal-compliance processing may continue where permitted.

13.8 How to Submit a Request

To submit a privacy request, consent-withdrawal request, opt-out request, sensitive-information request, privacy appeal, or authorized-agent request, use a privacy-request method made available through the Service or contact:

privacy@cuddle-global.com

Include enough information to identify:

• the request-an-invite submission, account, or personal information involved;
• the right or choice you want to exercise;
• your state of residence where relevant;
• the email address, phone number, account identifier, or purchase information associated with the request; and
• your authority to act if you submit the request for another person.

Using another channel may delay review and may not satisfy a legal deadline unless law requires otherwise or Cuddle accepts the communication in writing.

Requests are generally processed without charge. Cuddle may charge a reasonable fee, limit a request, or decline to act only where permitted by law, including for requests that are manifestly unfounded, excessive, repetitive, fraudulent, or abusive.

13.9 Request Confirmation and Verification

Cuddle may take reasonable steps to confirm that a request relates to the correct person, submission, or account and that the requester has authority to act.

Confirmation may use account email, phone number, login status, account identifiers, invite-form information, purchase details, recent Service activity, signed declarations, or other information reasonably appropriate to the request and risk involved.

Cuddle will not request more information than reasonably necessary. If Cuddle cannot reasonably confirm a request, it may request additional information, limit its response, or deny the request as permitted by law.

In limited circumstances, Cuddle may request an identity-document review, government ID review, or photo or selfie review where reasonably necessary to confirm a high-risk request, account ownership, authorized-agent authority, or prevent fraud.

Where Cuddle requests review materials, use only the authenticated review flow made available through the Service. Review materials and limited review-result records are handled under Sections 8 and 11.

13.10 Authorized Agents and Representatives

Where applicable law permits, you may authorize another person to submit a privacy request on your behalf.

Cuddle may require the agent to provide signed permission, proof of registration where applicable, power of attorney, or other reasonable evidence of authority.

Cuddle may also contact you directly to confirm the authorization or verify your identity, except where law provides otherwise.

An agent may not use the request process to obtain information beyond the authority granted, evade account restrictions, access another person’s account, obtain confidential safety or risk information, or continue prohibited conduct.

13.11 Timing, Appeals, and Complaints

Cuddle will confirm, respond to, and complete privacy requests within the periods required by applicable law.

Where permitted, Cuddle may extend the response period when reasonably necessary and will provide notice of the extension where required.

If Cuddle denies or limits a request and applicable law provides an appeal right, you may appeal by contacting:

privacy@cuddle-global.com

Identify the original request, the decision being appealed, your state of residence where relevant, and why you believe further review is warranted.

If an appeal is denied, Cuddle will provide information about any further complaint right or contact method where required by law.

You may also contact an applicable state privacy regulator or Attorney General.

13.12 Non-Discrimination, Limits, and Relationship to Other Terms

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

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

A change in functionality, account access, record retention, safety treatment, fraud-prevention treatment, payment-risk treatment, or review status that results from a valid request, deletion, opt-out, consent withdrawal, inability to verify, account ineligibility, safety concern, payment-risk concern, or legal requirement is not unlawful discrimination where permitted by law.

Cuddle may decline, limit, delay, or condition a request where permitted or required to protect another person’s rights, maintain security, prevent fraud, comply with law, preserve evidence, resolve disputes, provide requested functionality, or enforce applicable terms.

This Section is supplemented by the Cookie / Tracking Policy, State-Specific Terms & Cancellation Notices, Contact / Legal Notices, Terms of Service, and applicable law. More specific and non-waivable rights control.

Nothing in this Section limits any non-waivable privacy, data-security, breach-notification, access, deletion, correction, portability, consent, opt-out, appeal, authorized-agent, non-discrimination, consumer-protection, public-injunctive-relief, court-access, or other right under applicable law.

14. International Processing, Third-Party Services, Changes, and Non-Waivable Rights

14.1 United States Operation and Service Availability

Cuddle is operated by Third Hub US, Inc., a United States company, and 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 states otherwise. Limited support, privacy, billing, refund, statutory-cancellation, security, or legal communications concerning an existing account, invite request, or purchase may be processed when the requester is outside the supported area.

14.2 Locations of Processing

Personal information may be collected, stored, transmitted, accessed, disclosed, or otherwise processed in the United States and other locations where Cuddle’s authorized service providers, payment participants, professional advisers, or lawful recipients operate.

The laws of those locations may differ from the laws of your state or residence. Where law requires notice, consent, contractual safeguards, transfer mechanisms, or other protections, Cuddle will apply them as required.

Processing locations may vary by Service feature, provider, account activity, invite submission, support request, transaction, security need, technical configuration, and legal requirement.

14.3 AWS and Operational Providers

Cuddle uses Amazon Web Services (“AWS”) as a cloud infrastructure provider to host and operate portions of the Service.

Personal information may be processed through AWS services configured by Cuddle for authentication, application operation, databases, computing, storage, logging, backup, recovery, and search or indexing.

Cuddle also uses Twilio for phone-number validation and SMS verification-code delivery, Intercom for Help Center and customer-support functions, Typeform for request-an-invite forms, and Google reCAPTCHA for bot prevention and registration security.

Cuddle may use additional communications, email-delivery, security, fraud-prevention, payment-risk, moderation, analytics where implemented, consent-management, payment, professional, and operational providers.

14.4 Third-Party Services Cuddle Does Not Control

The Service may contain links to, rely on, or interoperate with services that Cuddle does not own or control.

Those services may have their own terms, privacy policies, cookie practices, security measures, payment rules, support procedures, and legal obligations. Review applicable third-party information before providing personal information or using an external service.

Except where law provides otherwise, Cuddle is not responsible for the privacy, security, availability, content, conduct, or data-handling practices of an independent third party.

A user-provided link, payment handle, QR code, wallet address, external page, or third-party instruction is not an authorized Cuddle purchase channel.

14.5 Service-Provider and Processing Changes

Cuddle may add, replace, remove, or change service providers, payment participants, infrastructure, integrations, processing locations, or technical configurations as the Service evolves.

Cuddle will evaluate material changes under applicable privacy, security, contractual, and legal requirements. Where a change requires notice, consent, an opt-out, or another process, Cuddle will provide it.

A provider acting for Cuddle is not authorized to use personal information for unrelated advertising, user monetization, or purposes outside its role, subject to independent legal obligations.

14.6 Changes to This Privacy Policy

Cuddle may update this Privacy Policy.

For a material change, Cuddle will update the Effective Date or Last Updated date and provide any notice required by law through the Service, a Legal page, email, an account notice, a privacy or cookie notice, checkout, the Contact / Legal Notices, or another permitted method.

Where law requires advance notice, consent, acknowledgment, an opt-out, or another process, Cuddle will follow that requirement.

Updated practices apply prospectively from the stated effective date unless law requires otherwise. Continued use after that date acknowledges the updated Privacy Policy where permitted, but does not replace separate consent where law requires consent for materially different processing.

14.7 Effective Date and Prior Versions

The Effective Date identifies when this Privacy Policy applies. A Last Updated date may identify a later revision.

Cuddle may retain prior versions and records of notices, acknowledgments, consents, withdrawals, opt-outs, and policy acceptance where reasonably necessary for compliance, dispute resolution, records management, and legal claims.

An update does not retroactively authorize materially different processing where law requires prior notice, consent, or another protection.

14.8 Non-Waivable Rights and No Prohibited Use

Nothing in this Privacy Policy limits a privacy, data-security, breach-notification, access, deletion, correction, portability, consent, opt-out, appeal, authorized-agent, non-discrimination, consumer-protection, public-injunctive-relief, court-access, or other right that cannot lawfully be waived or limited.

No processing practice, provider relationship, support process, privacy request, account review, disclosure, or policy update authorizes Prohibited Services, Prohibited Payments, user-to-user transfers of value, abuse, exploitation, unsafe conduct, or unlawful activity.

More specific notices and non-waivable law control the subjects they address.

14.9 Contact, Complaints, and Review Materials

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

privacy@cuddle-global.com

Use the routing information in the Contact / Legal Notices. You may also contact a state privacy regulator or Attorney General where permitted by law.

Do not send passwords, authentication codes, full payment card or bank information, identity-document images, government identification, photo or selfie review materials, private keys, medical records, information about minors, or other highly sensitive information through ordinary email, mail, Intercom, Typeform, general support channels, in-Service messages, profile fields, reports, or appeals.

Where Cuddle requests limited account-review materials, use only the authenticated review flow made available through the Service.