Privacy Policy

Our Pledge to You

At Orra, safeguarding your privacy is our utmost priority. It's the cornerstone of how we craft and deliver the services and products you rely on, allowing you to trust them completely and focus on forming meaningful connections.

We deeply value the trust you place in us when sharing your information, and we take this responsibility seriously.

Our Promise to Privacy: Every product and service we develop is meticulously designed with your privacy as the guiding principle. Our process involves collaboration with experts from various domains, including legal, security, engineering, and product design, ensuring that every decision we make respects your privacy.

Our Commitment to Transparency: Recognizing that privacy policies often suffer from lack of clarity and unnecessarily complex language, we take a different approach. Our aim is to present our Privacy Policy and related documents in clear, understandable terms. We want you to read and comprehend our policies, empowering you to understand our privacy practices fully.

Our Dedication to Security: We maintain dedicated teams focused on securing your data. Continual updates to our security protocols and ongoing investments in security measures underscore our commitment to enhancing the protection of your information.

Welcome to our Privacy Policy. Thank you for taking the time to read it.

If you are a California resident, please see our California Privacy Statement, which supplements this Privacy Policy.

We appreciate that you trust us with your information and we intend to always keep that trust. This starts with making sure you understand the information we collect, why we collect it, how it is used and your choices regarding your information. This Policy describes our privacy practices in plain language, keeping legal and technical jargon to a minimum.

This Privacy Policy applies from January 1, 2024. The previous version of this Privacy Policy applies until then.

Welcome to Our Privacy Policy. Thank you for taking the time to review it.

If you're a California resident, please refer to our California Privacy Statement, which complements this Privacy Policy.

We value the trust you place in us by sharing your information, and we're committed to maintaining that trust. This begins with ensuring you have a clear understanding of the information we collect, why we collect it, how it's used, and the choices you have regarding your information. Our Policy explains our privacy practices in simple language, minimizing legal and technical terminology.

This Privacy Policy is effective from January 1, 2024. The previous version remains applicable until then.

1. Scope of This Privacy Policy

This Privacy Policy pertains to websites, applications, events, and other services operated under the Orra brand. For simplicity, we collectively refer to these as our "services" throughout this Privacy Policy. We've included links to this Privacy Policy on all relevant services to ensure clarity.

Certain services may necessitate their own distinct privacy policy. In such cases, the privacy policy specific to that service supersedes this Privacy Policy.

2. Data Collection

It's evident that we can't facilitate meaningful connections without some information about you, such as basic profile details and your preferences for meeting people. Additionally, we gather data about your interactions with our services, including access logs, and may obtain information from third-party sources, such as when you link your social media account to access our services or import data from your social media profile to complete your own. For further insight, we provide a more comprehensive breakdown below.

Information Provided by You

You opt to provide us with specific information when utilizing our services. This includes:

1. **Account Creation**: When creating an account, you furnish us with at least your phone number and email address, along with essential details necessary for service functionality, such as your gender, date of birth, and preferences for connections.

2. **Profile Completion**: Upon completing your profile, you have the choice to disclose your sexual orientation to us. By providing such details, you consent to their utilization for the purposes outlined in this Privacy Policy. Additionally, you can share supplementary information, including bio details, interests, and content like photos and videos. To upload certain content, such as pictures or videos, you may grant us access to your camera or photo album.

3. **Subscription/Purchase**: When subscribing to a paid service or making direct purchases from us (rather than via platforms like iOS or Android), you furnish us with information pertinent to your transactions. This may include your debit or credit card number and other financial details, which we provide to our payment processors.

4. **Surveys and Studies**: Participation in surveys, focus groups, or market studies entails providing us with insights into our products and services, responses to inquiries, and testimonials.

5. **Promotions and Events**: Your registration or entry into our promotions, events, or contests necessitates the collection of the information you provide during the registration or entry process.

6. **Customer Care Interaction**: When reaching out to our customer care team, we gather the information you provide during the interaction.

7. **Information Sharing**: If you share information about other individuals with us (e.g., using a friend's contact details for a particular feature), we process this information on your behalf to fulfill your request.

8. **Chat and Content Processing**: Naturally, we process your conversations with other members and the content you publish to operate and safeguard our services, ensuring the safety of our community.

Aside from the information you provide directly, we also receive information about you from various sources, including:

1. **Members**: Other members may provide information about you as they engage with our services, such as through interactions or by submitting reports concerning you.

2. **Social Media**: You may choose to share information with us through your social media accounts. For example, if you create or log into your account using your social media credentials (e.g., Facebook, Google, or Apple), or if you upload photos from your social media accounts (e.g., Instagram or Spotify) onto our services.

3. **Affiliates**: As part of the Orra family of businesses, we prioritize the safety and security of our members. If you have been banned from another Orra service, your information may be shared with us to enable necessary actions, such as closing your account or preventing you from creating an account on our services.

4. **Other Partners**: Information about you may be received from our partners, particularly where our advertisements are featured on their platforms. In such cases, they may provide details regarding the success of advertising campaigns. Additionally, in compliance with applicable laws, we may receive information about individuals with suspected or convicted malicious intent from third parties as part of our efforts to ensure the safety and security of our members.

When you engage with our services, various types of technical data are automatically generated or collected. Here's a breakdown:

1. **Usage Information**: Your activity on our services generates data, including details about how you use the platform (such as login times, features utilized, actions taken, displayed information, referral webpage addresses, and interactions with advertisements) and your interactions with other members (like connections made, interactions, and message exchanges).

2. **Device Information**: We gather information about the device(s) you use to access our services, encompassing hardware and software specifics such as IP address, device ID and type, app settings, crashes, advertising IDs (which are randomly generated numbers resettable through device settings and sometimes disablement), and identifiers linked to cookies or other technologies that uniquely identify devices or browsers.

3. **Data from Cookies and Similar Technologies**: We and authorized parties utilize cookies and akin technologies (e.g., web beacons, pixels, SDKs) to identify you and/or your device(s). Further details on why we use these technologies and how you can manage their use are available in our Cookie Policy.

4. **Do Not Track (DNT) Signals**: Some web browsers (like Safari, Internet Explorer, Firefox, and Chrome) offer a "Do Not Track" (DNT) feature, indicating the user's preference to not have online activity tracked. However, not all browsers support DNT, and the signals aren't standardized yet. Consequently, many businesses, including ours, presently do not react to DNT signals.

With your explicit consent, we may collect additional information, including:

1. **Precise Geolocation Data**: If you grant us permission, we can gather your precise geolocation (latitude and longitude) from your device. This collection may occur in the background, even when you're not actively using our services, provided your consent explicitly permits such data collection. If you opt not to grant permission for precise geolocation collection, we won't gather it, and certain services reliant on this data may not be accessible to you.

2. **Photo Verification Data**: Should you choose to utilize our Photo Verification feature, we collect your face geometry data to confirm your identity. In certain jurisdictions, this data may be classified as biometric information. You can find more details about Photo Verification and our processing of your face geometry data.

3. **ID + Photo Verification Data**: If you opt for our combined ID + Photo Verification feature, we collect your face geometry data, potentially considered biometric data in some jurisdictions, along with a copy of your identification to verify your identity. Further information about ID + Photo Verification and our data processing procedures is available.

4. **Other Information**: With your authorization, we may gather additional information, such as photos and videos. This could include uploading photos or videos to your profile or engaging in streaming features on our services.

Here's how we use your information to enhance your experience and ensure the safety of our community:

A. **Administering Your Account and Providing Services**:

- Creating and managing your account.

- Providing customer support and addressing your inquiries.

- Keeping you updated about our services.

- Personalizing pricing, discounts, and promotions.

- Managing sweepstakes and contests.

B. **Facilitating Connections with Other Users**:

- Recommending you to other members and vice versa.

- Displaying members' profiles to each other.

- Enabling search and connection functionalities.

C. **Introducing New Orra Services**:

- Registering you for and displaying your profile on new Orra features and apps.

- Managing your account on these new features and apps.

D. **Offering and Operating Advertising and Marketing Campaigns**:

- Performing and evaluating advertising campaigns on and off our platform.

- Informing you about products or services that might interest you.

E. **Improving and Developing Our Services**:

- Conducting focus groups, market studies, and surveys.

- Reviewing interactions with customer care teams to enhance service quality.

- Understanding member usage patterns to improve services.

- Developing new features and services based on member feedback.

F. **Preventing, Detecting, and Combating Fraud and Illegal Activities**:

- Identifying and addressing violations of our Terms of Use.

- Designing strategies to counteract violations.

- Retaining data related to violations for investigation and prevention.

- Enforcing our rights as outlined in our Terms of Use.

- Communicating with individuals who report violations and informing them of actions taken.

G. **Ensuring Legal Compliance**:

- Meeting legal obligations.

- Assisting law enforcement agencies.

For details on how we handle personal information through profiling and automated decision-making, refer to our FAQ section.

Here's how we rely on legal bases to process your information:

1. **Providing our Service to You**:

- We process your information to fulfill our contract with you. This includes maintaining your account, making your profile visible to others, and providing both free and paid features to you and other members.

2. **Legitimate Interests**:

- We process your information based on our legitimate interests for purposes such as analyzing user behavior to improve our services, suggesting offers of interest, promoting our services, ensuring member safety, enforcing our rights, assisting law enforcement, and defending ourselves legally.

3. **Compliance with Laws and Regulations**:

- We process your information to comply with applicable laws and regulations, as well as to demonstrate our compliance. This includes retaining data required by accounting, tax, and other statutory regulations, responding to law enforcement requests, and documenting member consents and preferences.

4. **Consent**:

- If you provide us with sensitive information, such as your sexual orientation, you're consenting to our processing of that information as described in this Privacy Policy. Additionally, we may seek your consent for specific processing activities, such as collecting precise geolocation data. You can withdraw your consent at any time by adjusting your settings or contacting us directly.

These legal bases ensure that we process your information responsibly and transparently, in accordance with applicable laws and regulations. If you have any questions or concerns about how we process your information, please feel free to reach out to us.

Here's how we share your information:

1. **With Other Members**:

- You share information with other members when you voluntarily disclose it on the service, including your public profile. Be mindful of the information you share.

2. **With Service Providers and Partners**:

- We use vendors to assist us in operating, distributing, marketing, and improving our services. These vendors may include data hosting, analytics, customer care, and advertising partners. We have strict confidentiality obligations with these partners.

3. **With Our Affiliates**:

- We share information with other Orra companies for purposes such as ensuring safety across all Orra platforms, data processing operations, corporate audit, analysis, and reporting.

4. **Sharing Functionality**:

- You and other members may choose to share each other's profiles outside of our services using the sharing functionality.

5. **For Corporate Transactions**:

- Your information may be transferred in the event of a merger, sale, acquisition, or other change of ownership or control.

6. **With Law Enforcement or When Required by Law**:

- We may disclose your information to comply with legal processes, assist in crime prevention, protect the safety of individuals, or enforce legal rights.

7. **To Enforce Legal Rights**:

- Information may be shared to mitigate liability, protect legal rights, enforce agreements, or investigate illegal activity.

8. **With Your Consent or at Your Request**:

- We may ask for your consent to share your information with third parties and will clarify why we want to share it.

We may also use and share non-personal information or personal information in hashed, non-human readable form for various purposes, including targeted advertising and analysis. This information may be combined with data from other sources. For more details on our use of cookies and similar technologies, please refer to our Cookie Policy.

Cross-Border Data Transfers

We acknowledge that sharing information may involve transferring data across borders, particularly to the United States of America and other jurisdictions with different data processing laws. When we transfer personal information outside of certain regions with established data protection laws, such as the EEA, the United Kingdom, Switzerland, or other countries deemed adequate by relevant authorities, we ensure compliance with data protection regulations.

To safeguard your data privacy, we utilize standard contract clauses or other suitable transfer mechanisms. These clauses establish commitments between companies involved in data transfer, ensuring the protection and security of your personal information.

In response to recent developments, such as the Court of Justice for the European Union's ruling on data transfers to the USA, we are actively reviewing our data transfer processes, including those involving vendors, and assessing their legal basis. This ongoing review reflects our commitment to maintaining the privacy and security of your data across borders.

We want to ensure that you have control over your information, so we've provided the following options and tools:

1. **Access/Update Tools**: Utilize the tools and account settings within the service to access, rectify, or remove information associated with your account. If you need assistance with these tools, feel free to contact our customer care team.

2. **Device Permissions**: Adjust your device settings for specific types of data and notifications. You can consent to or oppose the collection or processing of certain information or notifications. Note that changing these settings may affect certain service functionalities.

3. **Uninstall**: Stop information collection by uninstalling the app using your device's standard uninstall process. Remember, uninstalling the app does not close your account. To close your account, use the corresponding functionality within the service.

4. **Account Closure**: Close your account directly within the service using the corresponding functionality.

Additionally, we want you to be aware of your privacy rights, which may include:

- **Access/Know**: Request a copy of the information we hold about you, and in some cases, receive it in a portable format. You can initiate this request within the service.

- **Delete/Erase**: Ask us to delete the personal information we have about you by submitting a request.

- **Correct/Rectify/Update**: Correct most information you provided by editing your profile within the service. Contact us if you believe the information we hold about you is inaccurate.

- **Object/Restrict**: Object to or request restrictions on certain processing. Contact us to make such requests.

For your protection, we may require proof of identity before addressing your requests. Please note that we may reject requests if they are unlawful or invalid, or if they infringe on the rights of others. If you wish to receive information about another member, that member must provide their written consent before releasing the information.

Residents of Virginia, Colorado, or Connecticut, USA, have the right to appeal if their privacy request is denied. Please contact us with explicit reference to "Privacy Request Appeal." If you have concerns about the appeal outcome, you may contact the attorney general for your state.

In certain countries, including in the European Economic Area and the United Kingdom, you have the right to lodge a complaint with the appropriate data protection authority if you have concerns about how we process your personal information. You can find information about your data protection regulator in the European Economic Area and the United Kingdom on their respective websites.

We retain your personal information only for as long as necessary for legitimate business purposes and as permitted by applicable law. If you choose to stop using our services, you can close your account, and your profile will no longer be visible to other members. However, if your account remains inactive for two years, we will automatically close it. After account closure, we follow the retention practices outlined below:

1. **Safety Retention Window**: We implement a safety retention window of three months following account closure, or one year following an account ban, to protect the safety and security of our members. During this period, we may retain your information to investigate unlawful or harmful conduct.

2. **Limited Retention for Specified Purposes**:

- **Legal Data Retention Obligations**: We maintain limited data to comply with legal data retention obligations. For example, transaction data is kept for 10 years for tax and accounting purposes, credit card information is retained until the user may challenge the transaction, and traffic data/logs are kept for one year to comply with legal requirements.

- **Legitimate Interest**: We retain certain information based on our legitimate interests, such as customer care records and supporting data, imprecise location of download/purchase, information on past accounts and subscriptions, profile data for potential litigation, and data necessary to prevent banned members from opening new accounts.

- **Outstanding or Potential Issues**: We may maintain information based on our legitimate interest in cases where there is an outstanding or potential issue, claim, or dispute, or if we receive a valid legal subpoena or request asking us to preserve data.

We take these measures to ensure the safety, security, and vital interests of our members, as well as to comply with legal obligations and protect our rights.

No Children Allowed

Our platform is exclusively for individuals aged 18 and above; those under 18 are not permitted to use our services. If you believe a member is under 18, please report them using the available mechanism on the platform.

For job candidates, contractors, and vendor representatives, we process personal information as part of our recruitment, talent management, and service management operations. If you fall into one of these categories, certain sections of this Privacy Policy apply to you, including those discussing the entity responsible for processing your data, data transfers, your rights under applicable law, and how to contact us.

For job applicants, the personal information processed may vary depending on the position applied for, typically including application details, professional qualifications, and background information. This information is used to support the recruitment process, potentially leading to an employment contract.

For contractors and vendor representatives, we may process identification and work-related information to manage our relationship with you and your employer. This processing is necessary for the performance of service agreements and to establish, exercise, or defend legal claims.

We may share personal information with service providers assisting with recruitment and technical processing, as well as with Orra affiliates if there's a business relationship involving employees of an affiliate. Your personal information is retained only as long as necessary for these purposes.

Because we’re always looking for new and innovative ways to help you build meaningful connections and strive to make sure explanations about our data practices remain up-to-date, this policy may change over time. We will notify you before any material changes take effect so that you have time to review the changes.