Cuddle Privacy Policy

Effective Date: May 8, 2026

1. Introduction, Scope, and Service Summary

1.1 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, shares, stores, protects, deletes, and otherwise processes personal information when you access or use Cuddle.

Cuddle is an 18+ online dating and social connection service. We help eligible adults create profiles, discover other users, communicate, manage account and privacy settings, use safety and reporting tools, contact support, and access optional paid digital features made available by Cuddle.

By using Cuddle, you acknowledge that we process personal information as described in this Privacy Policy.

1.2 Who We Are

Cuddle is operated by Third Hub US, Inc., a Delaware corporation, d/b/a Cuddle, 1007 N Orange St, 4th Floor, Suite #5681, Wilmington, DE 19801, United States.

For privacy questions or requests, contact privacy@cuddle-global.com. For general support, contact support@cuddle-global.com or use the support channels listed in our Contact / Legal Notices.

Please do not send highly sensitive information by ordinary email unless we specifically request it through an appropriate method. Cuddle support channels are not emergency-response channels. If you are in immediate danger or need emergency assistance, contact local emergency services immediately.

1.3 Where This Policy Applies

This Privacy Policy applies to personal information processed in connection with Cuddle, including accounts, profiles, discovery and matching features, messaging, safety and reporting tools, moderation, support, optional paid features, checkout, billing, cancellations, refunds, chargebacks, cookies, analytics, fraud prevention, payment-risk tools, and related services.

In this Privacy Policy, the “Service” means Cuddle’s 18+ online dating and social connection service and related features provided by or on behalf of Cuddle.

This Privacy Policy does not apply to third-party services that Cuddle does not own or control.

1.4 Adults Only

Cuddle is intended only for users who are at least eighteen (18) years old. Minors may not create accounts, access the Service, use the Service, purchase paid features, appear in content, communicate with users, submit content, submit reports, or otherwise interact with Cuddle.

By using Cuddle, you represent that you are at least eighteen (18) years old and have the legal capacity to use the Service.

We may process age, eligibility, verification, safety, fraud-prevention, payment-risk, and account-integrity information to enforce our 18+ requirement, protect users, comply with law, manage payment risk, prevent fraud, support safety, and enforce our Terms.

1.5 Service, Payments, and Prohibited Uses

Cuddle supports dating, conversations, introductions, social connection, and related personal interactions between eligible adults. Cuddle does not guarantee matches, responses, meetings, dates, relationships, compatibility, user truthfulness, user identity, user intentions, user safety, or any particular outcome.

Cuddle may offer optional paid digital features. Paid features are sold only for access to Cuddle-operated Service functionality. Payments are made only to Cuddle and are not payments to or for another user. Cuddle does not collect or store full payment card numbers, card security codes, or full bank account credentials on Cuddle-controlled systems.

Cuddle is not an adult content platform, pornography service, escort service, prostitution service, compensated dating service, sugar dating service, creator monetization platform, tipping platform, peer-to-peer payment service, money transmitter, stored-value provider, wallet provider, gift card issuer, cryptocurrency service, digital asset service, bank, lender, investment platform, brokerage service, securities service, financial advisor, financial institution, or marketplace for sexual content, sexual services, monetized user content, or transfers of value between users.

Users may not use Cuddle to solicit, arrange, promote, sell, purchase, monetize, process, or exchange adult content, sexual services, escort services, compensated dating, sugar arrangements, paid companionship, user-to-user payments, tips, donations, payouts, stored value, gift cards, cryptocurrency, digital assets, money transmission, financial services, or anything else of value between users.

1.6 Profiles, Messages, and Privacy Limits

Some information you provide may be visible to other users depending on your settings, actions, and features used. This may include profile information, photos, preferences, badges or account indicators if provided, messages and content you send, and other information you choose to make available.

Unless we expressly state otherwise, in-Service messaging is not end-to-end encrypted and should not be treated as a guaranteed secure channel for highly sensitive information. Other users may copy, save, screenshot, record, forward, disclose, misuse, or distribute content or communications outside the Service.

As of the Effective Date, Cuddle does not sell personal information, private messages, sensitive personal information, or payment-related personal information, and does not use private messages, payment-related personal information, or sensitive personal information for targeted advertising.

This Privacy Policy should be read together with our Terms of Service and other applicable policies. If there is a conflict regarding the handling of personal information, this Privacy Policy controls for that subject matter.

2. Personal Information We Collect

2.1 Overview

We collect personal information to provide, operate, secure, support, improve, and enforce Cuddle. The information we collect depends on how you use the Service, the features you use, the information you choose to provide, the purchases you make, the reports you submit, and the devices, browsers, and payment methods you use.

We may collect information directly from you, automatically when you use the Service, from other users, from payment processors and service providers, from safety, fraud-prevention, payment-risk, moderation, and verification vendors where used, and from other lawful sources. Not every user provides or generates every category described below.

2.2 Information You Provide and Content You Share

We collect information you provide when you create an account, create or edit a profile, upload photos or videos if supported, complete prompts, set preferences, send messages, submit reports, contact support, make purchases, request refunds or cancellations, submit privacy requests, appeal decisions, send legal notices, or otherwise interact with Cuddle.

This may include your name, display name, username or profile identifier, email address, phone number, date of birth or age confirmation, account credentials, profile text, profile media if supported, prompts, preferences, approximate location or location preferences, dating preferences, visibility settings, support communications, safety reports, billing communications, refund or cancellation requests, privacy requests, appeals, legal notices, and other information you choose to provide.

Because Cuddle is an online dating and social connection service, we also process profile information, messages, reactions, likes, matches or similar interactions if supported, reports, and other content or communications you submit through the Service. Unless we expressly state otherwise, in-Service messaging is not end-to-end encrypted and should not be treated as a guaranteed secure channel for highly sensitive information.

2.3 Payment, Device, Usage, and Technical Information

If you purchase a paid feature or interact with checkout, billing, cancellation, refund, chargeback, or payment-dispute processes, we may collect limited payment-related and billing-related information, such as billing information, payment method type, limited payment method details where available, transaction amount, currency, purchase date, paid feature purchased, payment status, receipt information, refund records, cancellation records, chargeback records, payment processor transaction identifiers, fraud-prevention signals, and payment-risk signals.

Cuddle does not collect, store, or process full payment card numbers, card security codes, or full bank account credentials on Cuddle-controlled systems. Payment card data is submitted directly to a third-party payment processor through processor-hosted, processor-controlled, or processor-approved payment fields or payment flows. Payments on Cuddle are solely for access to Cuddle-operated Service functionality and are not payments to or for another user.

When you access or use the Service, we may automatically collect technical information, such as IP address, browser type, device type, operating system, identifiers, log data, pages viewed, links clicked, features used, account activity, messaging activity, paid feature usage, checkout activity, approximate location inferred from IP address, billing location, and related security, fraud-prevention, and payment-risk signals.

We may use cookies and similar technologies to operate the Service, maintain sessions, remember preferences, protect accounts, prevent fraud, support checkout security, manage payment risk, analyze usage, debug errors, improve performance, support privacy choices, and comply with legal and operational requirements.

2.4 Safety, Moderation, Fraud Prevention, Payment Risk, and Verification Information

We may collect, generate, receive, and process information for safety, moderation, fraud prevention, payment-risk management, account security, age eligibility, account integrity, verification, legal compliance, privacy compliance, and enforcement.

This may include user reports, reported content or messages, screenshots or evidence, account identifiers, moderation decisions, enforcement records, appeal records, device information, IP address information, linked-account signals, transaction-risk signals, chargeback or refund history, account-takeover indicators, bot or spam indicators, prohibited-services indicators, prohibited-payments indicators, scam indicators, and related support or safety communications.

Where verification is used, we may process email verification, phone verification, age verification, identity verification, government identification information if used, selfie or photo verification if used, liveness checks if used, biometric-related information if used and treated as biometric information under applicable law, payment-method verification, billing verification, account ownership verification, verification results, and related vendor records. No verification, badge, screening result, account indicator, safety feature, fraud-prevention tool, payment-risk tool, or third-party review guarantees that a user is safe, truthful, eligible, available, compatible, trustworthy, verified, or appropriate to interact with.

2.5 Information From Others and Sensitive Information

We may receive information about you from other users, service providers, payment processors, fraud-prevention vendors, payment-risk vendors, verification vendors where used, professional advisors, legal authorities, and other lawful sources.

Some information we process may be considered sensitive personal information or sensitive data under certain laws. This may include precise geolocation if enabled, government identification information if used for verification, selfie or photo verification information if used, liveness or biometric-related information if used, account login credentials, payment-related information where treated as sensitive, contents of communications, dating preferences, information about sex life or sexual orientation, safety reports, fraud reports, harassment reports, payment-abuse reports, prohibited-services reports, or other sensitive incidents.

Where applicable law requires notice, consent, retention limits, deletion rules, opt-out rights, limitation rights, or other protections for sensitive information, we will provide the required notice, obtain the required consent, and apply the required protections to the extent required by law.

You should not send highly sensitive information through ordinary email, ordinary profile fields, ordinary messages, reports, appeals, or support channels unless Cuddle specifically requests it through an appropriate method. You should not send money, gift cards, cryptocurrency, payment-app transfers, bank transfers, wire transfers, loans, investments, payment credentials, account credentials, authentication codes, verification codes, private keys, wallet credentials, or anything else of value to another user. If another user asks you to do so, do not proceed and report the user through the Service or contact safety@cuddle-global.com

3. How We Use Personal Information

3.1 Overview

We use personal information to provide, operate, secure, support, improve, and enforce Cuddle.

How we use information depends on how you use the Service, the features you use, the information you choose to provide, the purchases you make, the reports or requests you submit, and the devices, browsers, and payment methods you use.

We do not use personal information to provide user-to-user payments, tips, donations, payouts, stored value, wallet balances, gift cards, cryptocurrency services, money transmission, banking, lending, investment services, adult content monetization, sexual services, escort services, compensated dating, sugar arrangements, or other prohibited services.

3.2 Accounts, Profiles, Discovery, and Messaging

We use personal information to create, authenticate, maintain, secure, recover, and manage accounts; operate account settings; support profile creation and display; provide discovery, recommendation, visibility, matching, or connection features if supported; and personalize parts of the Service.

We use profile information, preferences, location-related information where used, account activity, and Service activity to show your profile to other users, show other users’ profiles to you, support communication features, and operate safety, privacy, and visibility controls.

We use messages, content, reactions, likes, matches or similar interactions if supported, reports, and related metadata to transmit communications to intended recipients, maintain conversation functionality, provide reporting and blocking tools, investigate reports, detect abuse, enforce our Terms, and protect users and the Service.

Cuddle does not guarantee matches, messages, responses, meetings, dates, relationships, compatibility, user truthfulness, user identity, user intentions, user safety, visibility to any particular user, or any particular outcome.

3.3 Payments, Billing, and Paid Features

We use personal information to process purchases of Cuddle-operated digital Service functionality and to support checkout, payment authorization, billing, receipts, taxes, paid feature access, cancellations, refunds, chargebacks, payment disputes, fraud prevention, payment-risk management, accounting, audit, legal compliance, and billing support.

This may include account information, billing information, limited payment-related information, transaction records, refund and cancellation records, chargeback records, support communications, device information, IP address information, fraud-prevention signals, and payment-risk signals.

Payments on Cuddle are made only to Cuddle for Cuddle-operated Service functionality. Paid features are not payments to or for another user and do not create any right to receive money, value, goods, services, in-person interaction, off-platform interaction, sexual content, sexual services, matches, conversations, meetings, dates, relationships, or any particular result.

3.4 Safety, Moderation, Fraud Prevention, and Verification

We use personal information to support safety, moderation, reporting, appeals, fraud prevention, payment-risk management, account security, age eligibility, account integrity, verification where used, legal compliance, privacy compliance, and enforcement.

This may include reviewing accounts, profiles, messages, content, reports, transaction-related information, device information, IP address information, support communications, and related records to detect, prevent, investigate, document, or respond to fraud, scams, account takeover, unauthorized payment use, payment abuse, chargeback abuse, bots, spam, impersonation, harassment, threats, blackmail, extortion, sextortion, doxxing, stalking, minor safety concerns, prohibited services, prohibited payments, user-to-user transfers of value, adult content monetization, sexual services, escort services, compensated dating, and other unsafe or restricted activity.

Where verification is used, we may use personal information for email, phone, age, identity, selfie, photo, liveness, payment-method, billing, account ownership, device, fraud, payment-risk, safety, legal compliance, and privacy compliance checks.

No verification, badge, screening result, account indicator, safety feature, fraud-prevention tool, payment-risk tool, or third-party review guarantees that a user is safe, truthful, eligible, available, compatible, trustworthy, verified, or appropriate to interact with.

3.5 Communications, Cookies, Personalization, and Improvement

We use personal information to send account, purchase, billing, cancellation, refund, safety, security, verification, support, privacy, legal, policy, feature, enforcement, appeal, and Service-change communications. We may send service-related or transactional communications even if you opt out of marketing communications.

We use cookies, analytics information, device information, usage information, and similar technologies to operate the Service, maintain sessions, remember preferences, debug errors, improve performance, analyze usage, support checkout security, prevent fraud, manage payment risk, support privacy choices, and improve the Service.

We may use personal information to personalize parts of the Service, including discovery, recommendations, ranking, visibility, communication features, safety features, and user experience.

Unless we expressly disclose otherwise and obtain any consent required by applicable law, Cuddle does not use the substance of private, in-Service direct messages to train unrelated third-party general-purpose artificial intelligence models.

3.6 Legal Compliance, Records, and Privacy Requests

We use personal information to comply with applicable law, legal process, tax, accounting, audit, payment processor, card-network, bank, service-provider, sanctions, export-control, privacy, data-security, consumer-protection, and other legal or compliance requirements.

We may also use personal information to process privacy requests, verify identity or account ownership, respond to user choices, preserve records, respond to disputes and chargebacks, investigate security issues, exercise, establish, or defend legal claims, and protect users, Cuddle, the Service, service providers, payment processors, card networks, banks, and lawful authorities.

4.1 Overview

We share personal information only as reasonably necessary to provide, operate, secure, support, improve, and enforce Cuddle.

Because Cuddle is an 18+ online dating and social connection service, some information you choose to provide may be visible to other users or shared with intended recipients through the Service. We may also share information with service providers, payment processors, banks, card networks, safety and moderation vendors, fraud-prevention and payment-risk vendors, verification providers where used, professional advisors, lawful authorities, corporate transaction parties, and other recipients described below.

When we use “share” in this Privacy Policy, we mean disclose, make available, transfer, display, or provide access to information. This does not mean that Cuddle sells personal information or shares personal information for cross-context behavioral advertising, targeted advertising, or similar purposes.

4.2 Other Users and Intended Recipients

Some personal information may be visible to other users depending on your settings, actions, and features used. This may include profile information, photos, prompts, display name or profile identifier, age or age range if displayed, approximate location or distance if displayed, preferences, account indicators if provided, messages and content you send, and other information you choose to make available.

When you send a message, reaction, media item if supported, report, or other communication, we share or make available the relevant information with the intended recipient or appropriate Cuddle review channel so that the Service can function.

Other users may copy, save, screenshot, record, forward, disclose, misuse, or distribute information outside the Service.

4.3 Service Providers and Vendors

We share personal information with service providers, vendors, contractors, and processors that help us provide, host, store, transmit, secure, monitor, analyze, support, improve, and enforce the Service.

These recipients may support hosting, storage, communications, customer support, billing support, analytics, security, privacy requests, safety, moderation, fraud prevention, payment-risk management, verification where used, legal, tax, accounting, audit, and compliance.

Where required by law, we use safeguards designed to require service providers to protect personal information and process it only for permitted purposes.

4.4 Payment-Related Sharing

We share limited payment-related, billing-related, refund-related, cancellation-related, chargeback-related, fraud-related, tax, accounting, audit, and payment-risk information with authorized third-party payment processors and payment-related providers.

We share this information to process purchases of Cuddle-operated Service functionality, provide receipts, manage billing, process refunds and cancellations, respond to chargebacks or payment disputes, prevent fraud, manage payment risk, comply with payment, bank, tax, accounting, audit, and legal requirements, enforce our Terms, and protect users and the Service.

Cuddle does not collect, store, or process full payment card numbers, card security codes, or full bank account credentials on Cuddle-controlled systems.

4.5 Safety, Legal Compliance, and Protection

We may share personal information where reasonably necessary to protect users, enforce our Terms, prevent fraud, manage payment risk, protect account security, comply with law, respond to legal process, or exercise, establish, or defend legal claims.

Recipients may include safety, moderation, fraud-prevention, payment-risk, and verification providers where used; professional advisors; regulators; courts; law enforcement; tax authorities; payment processors; banks; service providers; and other lawful recipients.

We may limit, redact, delay, or decline disclosures where appropriate or permitted by law to protect user safety, reporter privacy, account security, payment security, investigations, legal compliance, confidential information, trade secrets, or the integrity of the Service.

4.6 Corporate Transactions and Your Direction

We may share personal information in connection with an actual or potential merger, acquisition, financing, investment, restructuring, sale of assets, bankruptcy, change of control, affiliate transfer, service-provider transition, payment processor transition, or similar corporate transaction.

We may also share personal information with third parties at your direction, with your consent, or as otherwise disclosed to you. If you direct us to share information with a third party, that third party may process the information under its own terms, privacy policies, and legal obligations.

4.7 No Sale, No Targeted Advertising Sharing, and No Prohibited Sharing

As of the Effective Date, Cuddle does not sell personal information, private messages, sensitive personal information, or payment-related personal information. Cuddle does not knowingly sell or share personal information of minors. Cuddle does not share personal information for cross-context behavioral advertising, targeted advertising, or similar advertising purposes.

Cuddle does not share personal information to provide, support, facilitate, or permit user-to-user payments, user payouts, stored value, wallet balances, gift cards, cryptocurrency services, money transmission, banking, lending, investment services, adult content monetization, sexual services, escort services, compensated dating, sugar arrangements, paid companionship, or other prohibited services.

If users submit information relating to prohibited services or prohibited payments, we may share that information as reasonably necessary to detect, prevent, investigate, enforce against, report, preserve records of, or otherwise respond to prohibited activity, fraud, payment abuse, safety risks, legal obligations, user reports, chargebacks, payment disputes, or violations of our Terms.

5. Payments, Billing, and Paid Features

5.1 Overview

Cuddle may offer optional paid digital features. This Section explains how we process personal information in connection with paid features, checkout, payment authorization, billing, receipts, taxes, cancellations, refunds, chargebacks, payment disputes, fraud prevention, payment-risk management, and billing support.

Paid features are sold only for access to Cuddle-operated Service functionality. They may include fixed-term access, non-renewing memberships, passes, boosts, discovery features, visibility features, communication features, account features, safety features, promotional access, subscriptions if clearly disclosed at checkout, or similar non-transferable digital functionality made available by Cuddle.

Payments on Cuddle are made only to Cuddle for Cuddle-operated Service functionality. Paid features are not payments to or for another user and do not create any right to receive money, value, goods, services, in-person interaction, off-platform interaction, content, companionship, sexual content, sexual services, matches, conversations, meetings, dates, relationships, or any particular result.

5.2 Payment Processors

Cuddle uses authorized third-party payment processors to process purchases of Cuddle-operated Service functionality. Stripe may be used only if Stripe has approved and enabled payment processing for Cuddle’s applicable business model and jurisdiction.

Third-party payment processors and related providers may process payment information under their own terms, privacy policies, security practices, processor requirements, card-network rules, bank requirements, and legal obligations.

5.3 Payment and Billing Information We Process

When you purchase a paid feature or interact with checkout, billing, cancellation, refund, chargeback, or payment-dispute processes, we may process limited payment-related and billing-related information.

This may include your name, email address, account identifier, billing information, billing location, payment method type, limited payment method details where available, transaction amount, currency, tax information, purchase date, paid feature purchased, payment status, receipt or invoice information, refund records, cancellation records, chargeback records, payment-dispute records, payment processor transaction identifiers, billing-support communications, device information, browser information, session information, IP address information, fraud-prevention signals, payment-risk signals, and records reasonably necessary for payment, billing, refund, cancellation, chargeback, tax, accounting, audit, legal-compliance, and support purposes.

5.4 How We Use Payment Information

We use payment-related and billing-related information to present checkout flows, process payment authorization, confirm payment status, provide receipts, provide access to paid features, calculate or document taxes, manage billing support, process cancellations and refunds where applicable, respond to chargebacks and payment disputes, prevent fraud, manage payment risk, comply with payment processor, card-network, bank, tax, accounting, audit, legal, and compliance requirements, enforce our Terms, and protect users and the Service.

We may create and retain checkout records, payment authorization records, purchase records, cancellation records, refund records, chargeback records, payment-dispute records, fraud-prevention records, and payment-risk records where reasonably necessary or permitted by law.

Account deletion, content deletion, message deletion, unmatching, blocking, suspension, termination, cancellation, refund, chargeback, payment dispute, or the end of your relationship with Cuddle does not require us to delete records that we are permitted or required to retain.

5.5 Cancellations, Refunds, and Chargebacks

We process personal information to receive, verify, review, document, and respond to cancellation requests, refund requests, chargebacks, payment disputes, unauthorized-transaction claims, duplicate-charge inquiries, unrecognized-charge inquiries, and related billing issues.

Billing questions may be sent to billing@cuddle-global.com Cancellation requests may be sent to cancellations@cuddle-global.com, unless a different method is required by applicable law, stated at checkout, or provided in applicable purchase terms.

Please include enough information for us to identify your account and the relevant purchase. Do not send full payment card numbers, card security codes, full bank account credentials, passwords, authentication codes, private keys, cryptocurrency wallet credentials, or other highly sensitive information by ordinary email.

Nothing in this Privacy Policy limits any non-waivable cancellation, refund, payment, unauthorized-transaction, chargeback, consumer-protection, disability-related, death-related, relocation-related, or other right you may have under applicable law.

5.6 No User Payments, Stored Value, or Prohibited Payment Activity

Cuddle does not provide, support, facilitate, or permit user-to-user payments, peer-to-peer payments, tips, donations, user payouts, creator payouts, cash-outs, revenue sharing, stored value, wallet balances, gift cards, prepaid value, cash-equivalent instruments, cryptocurrency services, digital asset services, money transmission, remittance, banking, lending, credit, investment services, brokerage services, securities services, financial advisory services, or other financial products or services.

Cuddle also does not process payment information to provide, support, facilitate, or permit payments for adult content monetization, pornography, adult live-chat, sexual services, escort services, prostitution, compensated dating, sugar arrangements, paid companionship, paid intimate content, paid sexual messaging, commercial sexual services, paid meetings, payment for access to a user, payment for a date, payment for a conversation, payment for intimacy, payment for sexual content, or any other prohibited service or prohibited payment.

If users submit payment handles, wallet addresses, QR codes, external payment links, bank transfer instructions, cryptocurrency information, payment-app usernames, gift-card information, transaction screenshots, or similar information, we may process that information to detect, prevent, investigate, enforce against, report, preserve records of, or otherwise respond to prohibited activity, fraud, payment abuse, payment-risk concerns, safety risks, legal obligations, user reports, chargebacks, payment disputes, and violations of our Terms.

Processing such information for safety, fraud prevention, payment-risk management, legal compliance, or enforcement does not mean that Cuddle provides, supports, facilitates, endorses, guarantees, or assumes responsibility for user-to-user transfers of value, financial services, adult services, or prohibited payments.

6. Safety, Moderation, Reports, and Verification

6.1 Overview

Cuddle is an 18+ online dating and social connection service. We process personal information to help protect users, enforce our Terms, prevent fraud, manage payment risk, support moderation, review reports, process appeals, verify eligibility where used, and maintain the integrity of the Service.

Online dating involves real-world risks. Safety tools, reporting tools, moderation systems, fraud-prevention tools, payment-risk tools, verification tools, account indicators, and user notices are designed to support safety and Service integrity, but they do not eliminate all risks and do not guarantee that any user is safe, truthful, eligible, available, compatible, trustworthy, verified, or appropriate to interact with.

6.2 Reports and Safety Reviews

We may process personal information when users submit reports, safety concerns, fraud concerns, payment-abuse concerns, prohibited-services concerns, prohibited-payments concerns, appeals, support requests, screenshots, evidence, or other information relating to conduct on or connected to Cuddle.

This information may include account identifiers, profile information, messages, content, screenshots, links, dates, approximate times, descriptions of conduct, device information, IP address information, payment-related information, transaction records, support communications, and other information reasonably relevant to the report or review.

We use this information to review reports, investigate concerns, respond to users, identify unsafe conduct, detect scams, prevent fraud, manage payment risk, enforce our Terms, preserve records, comply with law, and protect users and the Service.

Submitting a report does not guarantee that Cuddle will remove content, restrict an account, reverse a payment, issue a refund, provide a response, notify you of the outcome, preserve evidence, report to law enforcement, or take any particular action.

6.3 Moderation, Fraud Prevention, and Enforcement

We may use personal information to detect, prevent, investigate, document, and enforce against fraud, scams, romance scams, account takeover, unauthorized payment use, card testing, payment-method testing, payment abuse, refund abuse, chargeback abuse, promotional abuse, bots, spam, scraping, impersonation, harassment, threats, blackmail, extortion, sextortion, doxxing, stalking, financial exploitation, minor safety concerns, prohibited services, prohibited payments, user-to-user transfers of value, adult content monetization, sexual services, escort services, compensated dating, and other unsafe, unlawful, abusive, fraudulent, or restricted activity.

We may use human review, automated review, machine-assisted tools, service-provider tools, payment processor tools, fraud-prevention tools, payment-risk tools, safety tools, moderation tools, and related records for these purposes.

We may restrict, suspend, terminate, remove content, limit visibility, limit messaging, block users, block payment methods, delay or decline transactions, require additional verification, preserve records, notify users where appropriate or required, cooperate with service providers or lawful authorities, and take other action permitted by our Terms and applicable law.

We are not required to disclose detailed fraud, risk, ranking, recommendation, moderation, security, account-linking, or enforcement logic where disclosure could compromise user safety, fraud prevention, payment security, account security, investigations, legal compliance, confidential information, trade secrets, or the integrity of the Service.

6.4 Verification and Eligibility

Cuddle is intended only for users who are at least eighteen (18) years old. We may process age-related, eligibility-related, verification-related, safety-related, fraud-prevention, payment-risk, and account-integrity information to help enforce our 18+ requirement, prevent minors from using the Service, protect users, comply with law, manage payment risk, prevent fraud, and enforce our Terms.

Where verification is used, we may process information for email verification, phone verification, age verification, identity verification, selfie or photo verification, liveness checks, payment-method verification, billing verification, account ownership verification, location or residency verification, device checks, fraud review, payment-risk review, safety review, legal compliance, and privacy compliance.

Verification features may be optional, required, limited, unavailable, incomplete, delayed, inaccurate, or dependent on user-provided information, third-party vendors, payment processors, safety signals, fraud signals, payment-risk signals, legal requirements, or service-provider requirements.

Unless we expressly state otherwise for a specific feature, program, jurisdiction, or user category, Cuddle does not conduct criminal background checks, sex offender registry checks, identity verification checks, relationship-status checks, marital-status checks, intention checks, employment checks, financial checks, health checks, immigration checks, social-media checks, or safety clearances on all users.

6.5 Sensitive Information in Safety and Verification Contexts

Safety reports, moderation reviews, fraud investigations, payment-risk reviews, verification processes, and appeals may involve sensitive personal information or sensitive data.

This may include contents of communications, information about sex life or sexual orientation, dating preferences, relationship-related information, government identification information if used, selfie or photo verification information if used, liveness or biometric-related information if used, precise geolocation if enabled, payment-related information, information about harassment, blackmail, extortion, doxxing, stalking, impersonation, fraud, payment abuse, prohibited services, prohibited payments, or other sensitive incidents.

6.6 Off-Service Conduct and External Payment Requests

We may process personal information relating to off-Service conduct if the conduct arises out of, relates to, or is enabled by Cuddle, another user’s account, a Cuddle interaction, a paid feature, a transaction, a payment request, a refund request, a chargeback, a support interaction, or information obtained through the Service.

If another user asks you to send money, buy gift cards, transfer cryptocurrency, use an external payment app, provide payment credentials, provide verification codes, open an account, receive funds, forward funds, or participate in a financial transaction, you should not proceed and should report the user through the Service or contact safety@cuddle-global.com

6.7 Safety Records and Emergency Limits

We may retain safety, moderation, fraud-prevention, payment-risk, verification, report, appeal, enforcement, and related records for as long as reasonably necessary or permitted by law to protect users, prevent fraud, manage payment risk, enforce our Terms, comply with law, resolve disputes, respond to chargebacks, and exercise, establish, or defend legal claims.

Cuddle support channels, reporting tools, moderation tools, safety tools, emails, legal channels, privacy channels, security channels, billing channels, cancellation channels, and appeals are not emergency-response channels. If you are in immediate danger or need emergency assistance, contact local emergency services, law enforcement, crisis services, medical professionals, or another appropriate emergency resource immediately.

7. Cookies, Analytics, and Communications

7.1 Overview

We use cookies, analytics tools, communications tools, security tools, fraud-prevention tools, payment-risk tools, consent-management tools, and similar technologies to provide, operate, secure, support, improve, and enforce Cuddle.

This Section explains how these technologies and communications may work in connection with the Service. More specific details may be provided in our Cookie / Tracking Policy, cookie banner, consent-management tool, account settings, checkout disclosures, or other notice we make available.

7.2 Cookies and Similar Technologies

Cookies and similar technologies are tools that help websites, applications, browsers, devices, and service providers recognize users, remember choices, maintain sessions, measure usage, improve performance, support security, and operate features.

We may use cookies, pixels, tags, scripts, local storage, session storage, browser identifiers, device identifiers, analytics tools, security tools, fraud-prevention tools, payment-risk tools, communications tools, and similar technologies.

These technologies may collect or process information such as IP address, browser type, device type, operating system, identifiers, session information, authentication status, pages viewed, links clicked, features used, dates and times of access, approximate location inferred from IP address, cookie choices, consent choices, error data, security events, fraud-prevention signals, payment-risk signals, and other technical or usage information.

7.3 Why We Use These Technologies

We use cookies and similar technologies to operate the Service, authenticate users, maintain sessions, remember preferences, support account settings, provide profile and discovery features, support messaging functionality, operate paid features, support checkout security, prevent fraud, manage payment risk, detect abuse, debug errors, analyze performance, improve reliability, support privacy choices, support consent choices, and comply with legal and operational requirements.

We may also use these technologies to help detect account takeover, bots, spam, scraping, suspicious login activity, suspicious checkout activity, unauthorized payment use, card testing, payment abuse, chargeback abuse, prohibited services, prohibited payments, user-to-user payment requests, scams, and other unsafe or restricted activity.

7.4 Analytics and Product Improvement

We may use analytics information to understand how users access and use the Service, measure feature performance, identify errors, improve usability, test features, maintain reliability, support safety, improve fraud-prevention systems, improve payment-risk controls, and improve the overall user experience.

Analytics may involve account activity, profile activity, discovery activity, messaging activity, paid feature usage, checkout activity, support-channel activity, device information, browser information, session information, and aggregated or de-identified information.

Different users may see different features, interfaces, notices, offers, payment methods, checkout flows, privacy choices, support options, or product experiences depending on lawful factors such as location, jurisdiction, account history, feature availability, product testing, safety needs, fraud-prevention needs, payment-risk signals, compliance requirements, and operational needs.

7.5 Communications From Cuddle

We may use personal information to send service-related communications, including account notices, login messages, authentication messages, security alerts, safety notices, fraud notices, verification requests, policy updates, privacy notices, legal notices, support responses, billing notices, purchase confirmations, receipts, refund communications, cancellation information, chargeback or payment-dispute communications, enforcement notices, appeal notices, product updates, and other communications relating to your account or use of the Service.

You may not be able to opt out of service-related, transactional, legal, safety, security, billing, account, privacy, policy, support, cancellation, refund, payment-dispute, fraud, enforcement, or appeal communications because they are necessary to provide the Service, protect users, process payments, prevent fraud, manage payment risk, comply with law, or enforce our Terms.

You are responsible for keeping a valid email address and any other required contact information associated with your account. You are also responsible for ensuring that Cuddle communications are not blocked by spam filters, device settings, browser settings, account settings, email-provider settings, or other technical settings.

7.6 Marketing and Advertising Choices

Cuddle may send marketing communications where permitted by law. Where required by law, we will obtain consent before sending certain marketing communications.

Marketing communications may include information about Cuddle features, product updates, offers, promotions, trials, discounts, surveys, events, or other information about the Service. You may opt out of marketing communications by using the unsubscribe instructions provided in the communication or by using any other method we make available.

Opting out of marketing communications does not prevent us from sending service-related or transactional communications.

7.7 Your Cookie and Tracking Choices

Depending on where you live and applicable law, you may have choices regarding cookies, tracking technologies, analytics, advertising technologies if any, consent choices, opt-out choices, universal opt-out signals, and related preferences.

You may be able to manage certain choices through a cookie banner, consent-management tool, account settings, browser settings, device settings, unsubscribe links, or other methods we make available.

Browser or device settings may not control all technologies, and some choices may need to be set separately for each browser, device, account, or Service experience.

If there is a conflict between this Privacy Policy and a more specific Cookie / Tracking Policy regarding cookies, tracking technologies, analytics, advertising technologies if any, consent choices, opt-out choices, universal opt-out signals where applicable, or related preferences, the Cookie / Tracking Policy controls for that specific subject matter.

8. Data Retention

8.1 Overview

We retain personal information for as long as reasonably necessary and proportionate for the purposes described in this Privacy Policy.

Those purposes may include operating and securing Cuddle, maintaining accounts, supporting profiles, discovery, messaging, reporting, safety tools, and paid features, processing purchases, providing billing support, processing cancellations and refunds, preventing fraud, managing payment risk, handling chargebacks and payment disputes, complying with law, responding to privacy requests, maintaining consent and opt-out records, enforcing our Terms, and protecting users and the Service.

We do not retain every category of personal information for the same period. Retention periods may vary based on the type of information, how you use the Service, the features you use, the purchases you make, the reports or requests you submit, legal requirements, payment requirements, safety needs, fraud-prevention needs, payment-risk needs, dispute-resolution needs, and operational requirements.

8.2 How We Determine Retention Periods

When deciding how long to retain personal information, we consider the type and sensitivity of the information, the purpose for which it was collected, whether it is needed to provide the Service, whether your account is active or deleted, whether it relates to a paid feature or transaction, whether it relates to a report or safety matter, and whether it is needed for fraud prevention, payment-risk management, tax, accounting, audit, legal, compliance, dispute-resolution, or claims purposes.

Where applicable law requires a shorter retention period, a specific deletion process, consent, notice, or another retention-related protection, we will apply those requirements to the extent required by law.

8.3 Account, Profile, Messages, and Content

We retain account information, profile information, settings, preferences, and Service activity for as long as reasonably necessary to provide and manage your account, operate the Service, support user interactions, maintain safety and security, prevent fraud, enforce our Terms, and comply with law.

If you delete your account or request deletion, we may remove or disable certain information from active display. However, account deletion may not immediately or completely delete all personal information from recipient inboxes, shared conversations, reports, support records, safety records, fraud-prevention records, payment-risk records, legal-compliance records, logs, backups, archives, or service-provider systems.

We may retain messages, content, reports, and related records where reasonably necessary to support intended recipients, investigate reports, prevent abuse, protect users, respond to disputes, comply with law, enforce our Terms, or preserve evidence.

8.4 Payment, Billing, Safety, and Legal Records

We may retain payment, billing, checkout, receipt, refund, cancellation, chargeback, payment-dispute, tax, accounting, audit, fraud-prevention, payment-risk, support, and legal records for longer periods where reasonably necessary or permitted by law.

These records may be needed to document purchase authorization, provide billing support, process refunds or cancellations, respond to chargebacks, prevent unauthorized payment use, detect payment abuse, comply with payment processor, card-network, bank, tax, accounting, audit, legal, and compliance requirements, enforce our Terms, and protect users and the Service.

We may also retain safety, moderation, report, appeal, verification, fraud-prevention, payment-risk, and enforcement records to detect repeat abuse, scams, account takeover, impersonation, harassment, minor safety concerns, prohibited services, prohibited payments, user-to-user transfers of value, adult content monetization, sexual services, escort services, compensated dating, and other unsafe or restricted activity.

Retaining information for safety, fraud prevention, payment-risk management, legal compliance, or enforcement does not mean that Cuddle provides, supports, facilitates, endorses, or assumes responsibility for prohibited services, prohibited payments, user-to-user transfers of value, or financial services.

8.5 Sensitive Information, Deletion, and Backups

Some retained information may be sensitive personal information or sensitive data under certain privacy laws. This may include precise geolocation if enabled, government identification information if used, selfie or photo verification information if used, liveness or biometric-related information if used, payment-related information where treated as sensitive, contents of communications, dating preferences, safety reports, fraud reports, payment-abuse reports, prohibited-services reports, or other sensitive incidents.

We retain sensitive information only as reasonably necessary for the purposes described in this Privacy Policy. Identity, document, selfie, liveness, biometric-related, or similar verification materials, if used, may be retained for a shorter period where feasible and legally appropriate, unless longer retention is reasonably necessary or legally permitted.

We may delete, de-identify, anonymize, aggregate, or otherwise limit personal information when it is no longer reasonably needed, unless retention is required or permitted by law.

Some information may remain for a limited time in backups, logs, caches, archives, disaster-recovery systems, security systems, fraud-prevention systems, payment-risk systems, legal-compliance systems, or service-provider systems before it is deleted or overwritten.

We may preserve information subject to a legal hold, safety review, fraud review, payment dispute, chargeback, tax requirement, accounting requirement, audit requirement, regulatory request, law-enforcement request, court order, subpoena, privacy request, security incident, dispute, investigation, or legal claim.

We may also retain aggregated, de-identified, anonymized, or non-identifying information for lawful business purposes, provided that such information is not intended to identify you.

9. Security

9.1 Overview

We use administrative, technical, physical, and organizational safeguards designed to protect personal information against unauthorized access, acquisition, use, disclosure, alteration, loss, destruction, misuse, fraud, abuse, and other security risks.

These safeguards may include access controls, authentication controls, logging, monitoring, encryption where appropriate, security testing, fraud-prevention tools, payment-risk tools, account-integrity tools, service-provider controls, incident-response procedures, internal policies, and other measures designed to protect the Service and personal information.

However, no method of transmission, storage, authentication, encryption, fraud prevention, payment-risk management, moderation, verification, or processing is completely secure. Cuddle cannot guarantee that personal information, accounts, messages, content, payment-related information, or communications will always remain secure, private, confidential, undiscovered, or unavailable to unauthorized persons.

9.2 Account Security

You are responsible for maintaining the security of your account, login credentials, passwords, authentication codes, linked email accounts, phone numbers, devices, browsers, payment methods, and any other access methods associated with your account.

You should use a secure password, protect your email account and devices, avoid sharing login credentials, keep your contact information current, review suspicious activity, and log out when using shared, public, household, workplace, borrowed, managed, monitored, or otherwise non-private devices or networks.

If another person has access to your device, browser, email account, phone number, payment method, authentication code, local storage, browser history, notifications, or account credentials, that person may be able to discover, access, copy, forward, screenshot, record, or misuse your account or information.

Privacy settings, visibility controls, blocking tools, safety tools, and account settings do not eliminate these risks.

9.3 Payment Security

Cuddle does not collect, store, or process full payment card numbers, card security codes, or full bank account credentials on Cuddle-controlled systems.

Payment card data is submitted directly to a third-party payment processor through processor-hosted, processor-controlled, or processor-approved payment fields or payment flows.

We may process limited payment-related information, billing-related information, device information, IP address information, fraud-prevention signals, payment-risk signals, checkout records, refund records, cancellation records, chargeback records, and payment-dispute records to support payment security, fraud prevention, payment-risk management, legal compliance, and billing support.

Payment processors and related providers may process payment information under their own terms, privacy policies, security practices, payment rules, card-network rules, bank requirements, and legal obligations.

9.4 Security Monitoring and Incident Response

We may process personal information to protect the security, availability, confidentiality, integrity, and resilience of the Service.

This may include processing information to authenticate users, secure accounts, monitor suspicious activity, detect unauthorized access, detect account takeover, detect credential theft, detect phishing, detect malware, detect bots, detect scraping, detect spam, detect checkout abuse, detect payment security risks, investigate security reports, respond to security incidents, preserve security records, notify users where required or appropriate, improve security systems, prevent future misuse, comply with law, and enforce our Terms.

We may use human review, automated review, machine-assisted tools, service-provider tools, security tools, fraud-prevention tools, payment-risk tools, account-integrity tools, and related records for these purposes.

9.5 Security Reports

If you believe your account, credentials, device, email address, phone number, payment method, or other access method has been compromised, contact:

security@cuddle-global.com

You may also contact:

support@cuddle-global.com

If you believe you have discovered a security vulnerability or other security issue involving the Service, contact:

security@cuddle-global.com

Please do not publicly disclose a vulnerability, access another user’s account or information, disrupt the Service, conduct testing that may harm the Service, or use security research as a way to bypass access controls, payment controls, fraud-prevention systems, rate limits, moderation systems, or privacy controls.

Do not send full payment card numbers, card security codes, passwords, authentication codes, full bank account credentials, government identification documents, biometric information, private keys, cryptocurrency wallet credentials, or other highly sensitive information by ordinary email unless Cuddle specifically requests it through an appropriate method.

9.6 Limits on Security Disclosures

We may limit, redact, delay, or decline to disclose detailed security, fraud-prevention, payment-risk, account-linking, moderation, ranking, recommendation, or enforcement information where disclosure could compromise user safety, fraud prevention, payment security, account security, investigations, legal compliance, confidential information, trade secrets, or the integrity of the Service.

We may also preserve, use, and disclose security-related information where reasonably necessary or permitted by law to investigate security issues, prevent fraud, manage payment risk, respond to incidents, comply with legal obligations, cooperate with lawful authorities, enforce our Terms, protect users, and exercise, establish, or defend legal claims.

Cuddle support channels, security channels, reporting tools, and email channels are not emergency-response channels. If you are in immediate danger or need emergency assistance, contact local emergency services immediately.

10. Your Privacy Rights and Choices

10.1 Overview

Depending on where you live and applicable law, you may have rights and choices regarding your personal information.

These rights and choices may include the right to access, confirm, correct, delete, obtain a copy of, opt out of certain processing, limit certain uses or disclosures of sensitive personal information, withdraw consent where applicable, appeal a denied request, and not be discriminated against or retaliated against for exercising privacy rights.

Privacy laws differ by jurisdiction. Some rights may apply only to certain users, certain types of information, certain processing activities, or businesses that meet specific legal thresholds.

If applicable law gives you greater privacy rights than this Privacy Policy provides, those rights apply to the extent required by law.

10.2 Rights That May Be Available to You

Depending on your location and applicable law, you may have the right to:

request access to personal information;
confirm whether we process your personal information;
request correction of inaccurate personal information;
request deletion of personal information;
request a copy or portability of certain personal information;
receive information about the categories of personal information we collect, use, share, disclose, retain, sell, or share for advertising purposes where applicable;
receive information about the categories of sources from which we collect personal information;
receive information about the purposes for which we process personal information;
receive information about the categories of recipients to whom we disclose personal information;
opt out of the sale of personal information, where applicable;
opt out of sharing for cross-context behavioral advertising, targeted advertising, or similar advertising purposes, where applicable;
opt out of certain profiling or automated decision-making activities, where applicable;
limit certain uses or disclosures of sensitive personal information, where applicable;
withdraw consent where processing is based on consent and withdrawal is permitted by law;
appeal a denied privacy request, where applicable; and
exercise other rights provided by applicable law.

These rights are subject to legal exceptions and limitations.

10.3 How to Submit a Privacy Request

You may submit privacy requests by contacting:

privacy@cuddle-global.com

You may also use any privacy request form, account settings tool, privacy portal, help center page, cookie or consent-management tool, or other method we make available.

Please include enough information for us to identify your account, understand your request, verify your identity or authority, and respond appropriately.

Do not send full payment card numbers, card security codes, passwords, authentication codes, full bank account credentials, government identification documents, biometric information, private keys, cryptocurrency wallet credentials, medical records, intimate content, information about children, or other highly sensitive information by ordinary email unless Cuddle specifically requests it through an appropriate method.

10.4 Verification and Authorized Requests

Before fulfilling a privacy request, we may need to verify your identity, account ownership, residency, or authority to act.

Verification may involve account information, email confirmation, phone confirmation, account identifiers, request history, transaction information where relevant, support records, device information, IP address information, or other information reasonably necessary to verify the request and protect privacy, security, fraud-prevention, and payment-risk interests.

If you authorize another person to submit a privacy request on your behalf, we may require proof of authorization and may also require you to verify your identity directly, where permitted by law.

We may deny, delay, or limit a request if we cannot verify it, if the request appears fraudulent, abusive, unsafe, excessive, or unauthorized, or if fulfilling the request would compromise another person’s privacy, safety, rights, account security, payment security, fraud prevention, legal compliance, or the integrity of the Service.

10.5 When We May Limit or Deny Requests

We may deny, limit, delay, or retain information despite a request where permitted by law.

This may include where personal information is necessary for account security, fraud prevention, payment processing, billing support, refund processing, cancellation processing, chargeback handling, payment disputes, tax, accounting, audit, safety, moderation, legal compliance, privacy compliance, dispute resolution, enforcement of our Terms, protection of users and the Service, debugging, security, or establishment, exercise, or defense of legal claims.

10.6 Consent, Sensitive Information, and Cookie Choices

Where applicable law requires consent to process sensitive personal information or sensitive data, we will obtain consent before processing such information and will provide a method to withdraw consent as required by law.

Withdrawal of consent may limit or prevent your ability to use features that depend on that processing, such as verification features, location-based features, discovery features, safety features, account-security features, checkout features, fraud-prevention features, payment-risk features, or paid features.

You may also have choices regarding cookies, tracking technologies, analytics, marketing communications, universal opt-out signals, and related preferences. More information is provided in the Cookies, Analytics, and Communications section of this Privacy Policy and in any Cookie / Tracking Policy or cookie notice we make available.

10.7 Appeals and Non-Discrimination

If applicable law gives you the right to appeal our decision on a privacy request, we will provide an appeal process as required by that law.

If we deny your privacy appeal and applicable law requires us to provide information about how to contact a state Attorney General, data protection authority, regulator, or other complaint authority, we will provide that information in our appeal response or through another legally permitted method.

We will not discriminate or retaliate against you for exercising privacy rights. However, exercising certain rights may affect your ability to use features that depend on the information at issue.

10.8 No Sale and No Targeted Advertising Use of Sensitive Information

As of the Effective Date, Cuddle does not sell personal information, private messages, sensitive personal information, or payment-related personal information.

Cuddle does not knowingly sell or share personal information of minors.

Cuddle does not share personal information for cross-context behavioral advertising, targeted advertising, or similar advertising purposes, and does not use private messages, payment-related personal information, or sensitive personal information for targeted advertising.

If our practices change in a way that requires additional notice, consent, opt-out rights, limitation rights, universal opt-out signal recognition, appeal rights, or other rights under applicable law, we will update this Privacy Policy and provide any required choices.

11. U.S. State Privacy Notice

11.1 Overview

This Section provides additional information for residents of U.S. states with privacy laws that apply to Cuddle.

State privacy laws differ in scope, thresholds, definitions, exemptions, request procedures, response periods, appeal rights, opt-out requirements, universal opt-out signal requirements, sensitive-data rules, profiling rules, and available remedies.

Some state privacy laws apply only if a business meets certain revenue, data-volume, consumer-volume, sale-of-data, targeted-advertising, or other legal thresholds. If a state privacy law does not apply to Cuddle, to you, to a particular request, or to a particular category of information, we may still choose to respond voluntarily. Doing so does not mean that the law applies or that we waive any legal exception.

If applicable law gives you greater privacy rights than this Privacy Policy provides, those rights apply to the extent required by law.

11.2 Categories of Personal Information

The categories of personal information we may collect, use, share, disclose, or retain are described throughout this Privacy Policy.

Depending on how you use Cuddle, these categories may include:

identifiers, such as name, display name, email address, phone number, account identifiers, device identifiers, and similar information;
account, profile, and eligibility information;
profile photos, profile videos if supported, prompts, preferences, messages, content, reports, and other communications;
payment, billing, transaction, refund, cancellation, chargeback, and payment-dispute information;
device, browser, usage, cookie, analytics, location-related, security, fraud-prevention, and payment-risk information;
safety, moderation, verification where used, account-integrity, appeal, support, and enforcement information;
information from other users, service providers, payment processors, fraud-prevention vendors, payment-risk vendors, verification vendors where used, and other lawful sources;
inferences, classifications, or signals used to operate, secure, personalize, moderate, improve, and enforce the Service; and
sensitive personal information or sensitive data where applicable.

We do not collect every category of information from every user.

11.3 Sources, Purposes, and Recipients

We may collect personal information directly from you, automatically when you use the Service, from other users, from payment processors, from service providers, from safety, moderation, fraud-prevention, payment-risk, and verification vendors where used, and from other lawful sources.

We use personal information for the purposes described in this Privacy Policy, including to provide the Service, operate accounts and profiles, support discovery and messaging, process paid features, support billing and cancellations, process refunds and chargebacks, prevent fraud, manage payment risk, support safety and moderation, enforce our Terms, comply with law, respond to privacy requests, improve the Service, and protect users and Cuddle.

We may disclose personal information to the categories of recipients described in this Privacy Policy, including other users as directed by Service functionality, service providers, payment processors, banks, card networks, fraud-prevention vendors, payment-risk vendors, safety and moderation vendors, verification providers where used, professional advisors, lawful authorities, corporate transaction parties, and third parties at your direction or with your consent.

11.4 Sale, Sharing, Targeted Advertising, and Profiling

As of the Effective Date, Cuddle does not sell personal information, private messages, sensitive personal information, or payment-related personal information.

Cuddle does not knowingly sell or share personal information of minors.

Cuddle does not process personal information for profiling in furtherance of decisions that produce legal or similarly significant effects concerning a user, unless we expressly disclose otherwise and provide any rights required by applicable law.

If our practices change in a way that requires additional notice, consent, opt-out rights, limitation rights, appeal rights, universal opt-out signal recognition, or other rights under applicable law, we will update this Privacy Policy and provide any required choices.

11.5 Sensitive Personal Information

Some information processed through Cuddle may be considered sensitive personal information or sensitive data under certain laws.

This may include precise geolocation if enabled, government identification information if used, selfie or photo verification information if used, liveness or biometric-related information if used, account login credentials, payment-related information where treated as sensitive, contents of communications, dating preferences, information about sex life or sexual orientation, safety reports, fraud reports, harassment reports, payment-abuse reports, prohibited-services reports, or other sensitive incidents.

11.6 How to Exercise State Privacy Rights

Depending on your state and applicable law, you may have the right to access, confirm, correct, delete, obtain a copy of, or opt out of certain processing of your personal information. You may also have the right to limit certain uses or disclosures of sensitive personal information, withdraw consent where applicable, appeal a denied request, and not be discriminated against or retaliated against for exercising privacy rights.

You may submit privacy requests by contacting:

privacy@cuddle-global.com

You may also use any privacy request form, privacy portal, account settings tool, cookie or consent-management tool, or other method we make available.

We may need to verify your identity, account ownership, residency, or authority to act before fulfilling a request. We may deny, limit, delay, or retain information despite a request where permitted by law, including where information is necessary for account security, fraud prevention, payment processing, billing support, refunds, cancellations, chargebacks, payment disputes, tax, accounting, audit, safety, moderation, legal compliance, privacy compliance, dispute resolution, enforcement of our Terms, protection of users and the Service, or legal claims.

If applicable law gives you the right to appeal our decision on a privacy request, we will provide an appeal process as required by that law.

12. International Processing and Service Availability

12.1 United States Operation

Cuddle is operated from the United States.

The Service is intended to serve eligible adult users in the United States, subject to availability, applicable law, payment processor requirements, bank requirements, card-network requirements, service-provider requirements, safety requirements, fraud-prevention requirements, payment-risk requirements, and other operational or compliance requirements.

If you access or use Cuddle from outside the United States, you understand that Cuddle may collect, process, store, and transfer your personal information in the United States and other countries where Cuddle or our service providers operate.

12.2 Cross-Border Processing

Your personal information may be processed by Cuddle, service providers, payment processors, fraud-prevention vendors, payment-risk vendors, safety and moderation vendors, verification providers where used, analytics providers, communications providers, professional advisors, and other recipients described in this Privacy Policy.

These recipients may be located in the United States or in other countries. The privacy and data-protection laws of those countries may differ from the laws of your state, province, territory, or country of residence.

Where applicable law requires safeguards for cross-border transfers of personal information, we will use appropriate safeguards to the extent required by that law.

12.3 Service Availability by Location

Cuddle, paid features, checkout, payment methods, account creation, messaging, discovery features, verification features, support channels, privacy request methods, safety tools, and other features may not be available in all countries, states, territories, regions, or jurisdictions.

We may restrict, refuse, suspend, terminate, delay, review, block, or condition access to the Service or any feature where we determine that providing access may create legal, regulatory, sanctions, safety, security, privacy, payment, fraud, chargeback, tax, operational, reputational, or business risk.

We may also restrict access where online dating, matchmaking, paid digital features, payment processing, privacy compliance, safety compliance, consumer notices, cancellation rights, refund rights, screening disclosures, or related services are prohibited, restricted, unsupported, or subject to additional requirements.

12.4 Payment, Bank, and Processor Requirements

The availability of paid features, checkout, payment methods, refunds, cancellations, chargebacks, billing support, fraud-prevention tools, and payment-risk controls may depend on third-party payment processors, banks, card networks, payment-method providers, fraud-prevention vendors, payment-risk vendors, service providers, and applicable law.

Cuddle may limit or refuse payment processing, paid feature access, payment methods, checkout access, account access, or feature availability where a payment processor, bank, card network, service provider, regulator, or lawful authority requires or recommends such action, or where Cuddle reasonably determines that such action is necessary for compliance, fraud prevention, payment-risk management, user safety, or Service integrity.

Nothing in this Section means that Cuddle provides payment processing services to users, user-to-user payments, stored value, wallet balances, money transmission, cryptocurrency services, financial services, adult content monetization, sexual services, escort services, compensated dating, or any other prohibited service.

12.5 Location-Based Notices and Rights

Within the United States, certain features, notices, privacy choices, safety notices, cancellation rights, refund rights, screening disclosures, fraud notices, purchase terms, payment methods, support options, or privacy request methods may vary by state where required or permitted by applicable law.

Outside the United States, additional privacy, consumer, payment, safety, or platform rules may apply depending on your location and whether those laws apply to Cuddle.

If applicable law gives you privacy rights greater than those described in this Privacy Policy, those rights apply to the extent required by law.

12.6 International Access at Your Initiative

If you access or use Cuddle from outside the United States, you are responsible for ensuring that your access to and use of the Service is lawful in your location and consistent with any obligations that apply to you.

Cuddle does not guarantee that the Service, paid features, payment methods, privacy choices, safety notices, cancellation rights, refund rights, support channels, or any specific feature will be available, lawful, appropriate, or compliant in every jurisdiction.

We may change, limit, suspend, or discontinue availability in any location to the fullest extent permitted by applicable law.

13. Third-Party Services and Off-Service Interactions

13.1 Overview

Cuddle may include links to, integrations with, or interactions involving third-party services. This may include payment processors, payment gateways, banks, card networks, fraud-prevention vendors, payment-risk vendors, verification providers where used, hosting providers, cloud providers, analytics providers, communications providers, customer-support tools, security providers, consent-management tools, privacy request tools, social media services, messaging services, device platforms, browser platforms, app stores if applicable, external websites, and other services that Cuddle does not own or control.

This Section explains how third-party services and off-Service interactions may affect your privacy, safety, payment, and data-handling risks.

13.2 Third-Party Terms and Privacy Practices

Third-party services may collect, use, share, store, transfer, secure, retain, delete, or otherwise process your information under their own terms, privacy policies, cookie policies, security practices, payment rules, refund procedures, cancellation procedures, dispute procedures, and legal obligations.

Cuddle does not control third-party services that we do not own or operate. We are not responsible for the privacy, security, payment, refund, cancellation, content, safety, availability, reliability, accuracy, or data-handling practices of third-party services, except to the extent required by applicable law.

You should review the applicable third-party terms and privacy policies before using a third-party service, clicking an external link, submitting information to a third party, using a payment flow, using a verification flow, or moving a conversation outside Cuddle.

13.3 Payment Processors and Payment Flows

Cuddle uses authorized third-party payment processors to process purchases of Cuddle-operated Service functionality.

When you enter payment information in a checkout flow, your payment information may be submitted directly to a third-party payment processor through processor-hosted, processor-controlled, or processor-approved payment fields or payment flows.

Cuddle does not collect, store, or process full payment card numbers, card security codes, or full bank account credentials on Cuddle-controlled systems.

Payments on Cuddle are made only to Cuddle for Cuddle-operated Service functionality. Cuddle does not provide user-to-user payments, peer-to-peer payments, tips, donations, user payouts, stored value, wallet balances, gift cards, cryptocurrency services, money transmission, banking, lending, investment services, or other financial services.

13.4 External Links and Off-Service Communications

If you click an external link, scan a QR code, use an external messaging app, use a payment app, visit an external website, provide information to another platform, or move a conversation off Cuddle, you do so at your own risk.

Off-Service communications may be copied, saved, screenshotted, recorded, forwarded, disclosed, misused, or distributed by other users or third parties. Cuddle may have limited ability to detect abuse, prevent fraud, investigate reports, preserve evidence, enforce our Terms, block users, protect you, respond to payment-related concerns, or provide support for activity that occurs outside the Service.

You should be cautious before sharing personal information, contact information, photos, videos, workplace details, home address, travel plans, family information, intimate content, payment information, identity documents, authentication codes, account credentials, payment-app usernames, cryptocurrency wallet information, or other sensitive information outside the Service.

13.5 No Evasion Through Third-Party Services

You may not use third-party services, external links, QR codes, usernames, handles, payment handles, wallet addresses, external messaging platforms, external payment apps, websites, marketplaces, file-sharing services, or off-Service communications to evade this Privacy Policy, our Terms, our Prohibited Services, Payments & Commerce Policy, payment-risk controls, fraud-prevention systems, safety tools, moderation systems, privacy choices, or enforcement actions.

You may not use third-party services or off-Service communications to solicit, arrange, advertise, promote, facilitate, sell, purchase, monetize, process, or exchange adult content, sexual services, escort services, prostitution, compensated dating, sugar arrangements, paid companionship, user-to-user payments, tips, donations, payouts, stored value, gift cards, cryptocurrency, digital assets, money transmission, financial services, or anything else of value between users.

If another user asks you to use an external payment app, send money, buy gift cards, transfer cryptocurrency, provide payment credentials, provide verification codes, open an account, receive funds, forward funds, or participate in a financial transaction, you should not proceed and should report the user through the Service or contact safety@cuddle-global.com

13.6 Information We May Process About Off-Service Conduct

This may include messages, reports, screenshots, links, payment handles, wallet addresses, external platform identifiers, transaction-related information, device information, IP address information, fraud-prevention signals, payment-risk signals, support communications, and related records.

We may use this information to detect, prevent, investigate, enforce against, report, preserve records of, or otherwise respond to prohibited activity, fraud, payment abuse, safety risks, legal obligations, user reports, chargebacks, payment disputes, and violations of our Terms.

14. Changes, Contact, and Additional Information

14.1 Changes to This Privacy Policy

We may update this Privacy Policy from time to time.

If we make material changes, we will update the Effective Date and provide notice as required by applicable law. Notice may be provided by posting the updated Privacy Policy on the Service, sending an email, providing an in-product notice, displaying a website notice, updating the applicable Legal page, updating our Contact / Legal Notices, or using another method permitted by law.

Where applicable law requires consent before a change applies to you, we will seek consent as required.

Your continued access to or use of the Service after an updated Privacy Policy becomes effective means that you acknowledge the updated Privacy Policy, except where applicable law requires a different process or consent.

If you do not agree to an updated Privacy Policy, you should stop using the Service and may submit any privacy request available to you under applicable law.

14.2 No Change Authorizes Prohibited Activity

No update to this Privacy Policy permits users to use Cuddle for prohibited services, prohibited payments, user-to-user transfers of value, financial services, adult content monetization, sexual services, escort services, compensated dating, sugar arrangements, or any activity prohibited by our Terms, Prohibited Services, Payments & Commerce Policy, payment processor requirements, card-network rules, bank requirements, service-provider requirements, or applicable law.

Processing information for safety, fraud prevention, payment-risk management, legal compliance, privacy compliance, support, dispute resolution, or enforcement does not mean that Cuddle provides, supports, facilitates, endorses, guarantees, or assumes responsibility for prohibited services, prohibited payments, user-to-user transfers of value, or financial services.

14.3 How to Contact Us

Cuddle is operated by:

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

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

Wilmington, DE 19801

United States

For privacy-related questions or requests, contact:

Privacy Requests: privacy@cuddle-global.com

For other matters, please use the contact channel that best matches your request:

General Support: support@cuddle-global.com

Billing Support: billing@cuddle-global.com

Cancellation Requests: cancellations@cuddle-global.com

Safety Reports: safety@cuddle-global.com

Security Reports: security@cuddle-global.com

Legal Notices: legal@cuddle-global.com

Appeals: appeals@cuddle-global.com

Additional contact information, mailing addresses, legal notice instructions, support instructions, cancellation instructions, billing instructions, privacy request methods, safety report channels, security report channels, and appeal channels may be provided in our Contact / Legal Notices.

If there is a conflict between this Privacy Policy and our Contact / Legal Notices regarding official contact channels, mailing addresses, legal notice addresses, or notice methods, the Contact / Legal Notices controls for that specific subject matter, except where this Privacy Policy or applicable law provides a more specific privacy-request method.

14.4 Sending Information to Cuddle

Please do not send full payment card numbers, card security codes, passwords, authentication codes, full bank account credentials, government identification documents, biometric information, private keys, cryptocurrency wallet credentials, medical records, intimate content, information about children, or other highly sensitive information by ordinary email unless Cuddle specifically requests it through an appropriate method.

Please include enough information for us to understand, route, verify, and respond to your request. If you send a request to the wrong channel, our response may be delayed, and we may ask you to resend the request through the appropriate channel.

14.5 Emergency Limits

Cuddle support channels, reporting tools, moderation tools, safety tools, legal channels, privacy channels, security channels, billing channels, cancellation channels, appeals, and other Service channels are not emergency-response channels.

We may not review reports, emails, messages, support requests, legal notices, safety reports, security reports, billing inquiries, cancellation requests, privacy requests, appeals, or other communications in real time.

If you are in immediate danger, believe another person is in immediate danger, or need emergency assistance, do not rely on Cuddle. Contact local emergency services, law enforcement, crisis services, medical professionals, or another appropriate emergency resource immediately.

14.6 Additional Rights

Nothing in this Privacy Policy limits any non-waivable privacy, consumer-protection, cancellation, refund, safety, payment, unauthorized-transaction, accessibility, anti-discrimination, data-security, breach-notification, sensitive-data, consent, opt-out, appeal, or other right that may apply to you under applicable law.

If applicable law gives you greater privacy rights than this Privacy Policy provides, those rights apply to the extent required by law.

Cuddle Privacy Policy

1. Introduction, Scope, and Service Summary

1.1 Welcome to Cuddle

1.2 Who We Are

1.3 Where This Policy Applies

1.4 Adults Only

1.5 Service, Payments, and Prohibited Uses

1.6 Profiles, Messages, and Privacy Limits

2. Personal Information We Collect

2.1 Overview

2.2 Information You Provide and Content You Share

2.3 Payment, Device, Usage, and Technical Information

2.4 Safety, Moderation, Fraud Prevention, Payment Risk, and Verification Information

2.5 Information From Others and Sensitive Information

3. How We Use Personal Information

3.1 Overview

3.2 Accounts, Profiles, Discovery, and Messaging

3.3 Payments, Billing, and Paid Features

3.4 Safety, Moderation, Fraud Prevention, and Verification

3.5 Communications, Cookies, Personalization, and Improvement

3.6 Legal Compliance, Records, and Privacy Requests

4. How We Share Personal Information

4.1 Overview

4.2 Other Users and Intended Recipients

4.3 Service Providers and Vendors

4.4 Payment-Related Sharing

4.5 Safety, Legal Compliance, and Protection

4.6 Corporate Transactions and Your Direction

4.7 No Sale, No Targeted Advertising Sharing, and No Prohibited Sharing

5. Payments, Billing, and Paid Features

5.1 Overview

5.2 Payment Processors

5.3 Payment and Billing Information We Process

5.4 How We Use Payment Information

5.5 Cancellations, Refunds, and Chargebacks

5.6 No User Payments, Stored Value, or Prohibited Payment Activity

6. Safety, Moderation, Reports, and Verification

6.1 Overview

6.2 Reports and Safety Reviews

6.3 Moderation, Fraud Prevention, and Enforcement

6.4 Verification and Eligibility

6.5 Sensitive Information in Safety and Verification Contexts

6.6 Off-Service Conduct and External Payment Requests

6.7 Safety Records and Emergency Limits

7. Cookies, Analytics, and Communications

7.1 Overview

7.2 Cookies and Similar Technologies

7.3 Why We Use These Technologies

7.4 Analytics and Product Improvement

7.5 Communications From Cuddle

7.6 Marketing and Advertising Choices

7.7 Your Cookie and Tracking Choices

8. Data Retention

8.1 Overview

8.2 How We Determine Retention Periods

8.3 Account, Profile, Messages, and Content

8.4 Payment, Billing, Safety, and Legal Records

8.5 Sensitive Information, Deletion, and Backups

9. Security

9.1 Overview

9.2 Account Security

9.3 Payment Security

9.4 Security Monitoring and Incident Response

9.5 Security Reports

9.6 Limits on Security Disclosures

10. Your Privacy Rights and Choices

10.1 Overview

10.2 Rights That May Be Available to You

10.3 How to Submit a Privacy Request

10.4 Verification and Authorized Requests

10.5 When We May Limit or Deny Requests

10.6 Consent, Sensitive Information, and Cookie Choices

10.7 Appeals and Non-Discrimination

10.8 No Sale and No Targeted Advertising Use of Sensitive Information

11. U.S. State Privacy Notice

11.1 Overview

11.2 Categories of Personal Information

11.3 Sources, Purposes, and Recipients

11.4 Sale, Sharing, Targeted Advertising, and Profiling

11.5 Sensitive Personal Information