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Privacy Policy

1. INTRODUCTION

Affection-Bolingo Inc. (“we”, “our”, “us”) operates the Affection mobile application and related services

(“the App”).

This Privacy Policy explains how we collect, use, disclose, store, and protect your personal information

when you use the App.

By accessing or using Affection, you consent to the practices described in this Privacy Policy.

We are committed to complying with the Personal Information Protection and Electronic Documents

Act (PIPEDA) and applicable provincial privacy laws.

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2. INFORMATION WE COLLECT

2.1 Personal Information You Provide

• Name

• Email address

• Date of birth

• Gender

• Location

• Password or login credentials

• Profile details and preferences

2.2 Profile & User-Generated Content

• Photos (blurred or unblurred)

• Biography and interests

• Match preferences

• Messages and interactions

• Content posted or shared on the App

2.3 Device & Technical Data

• IP address

• Device type and operating system

• Mobile identifiers• App usage statistics

• Log files

2.4 Automatically Collected Data

• Cookies and tracking technologies

• Analytics and performance data

• Diagnostic and crash data

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3. HOW WE COLLECT INFORMATION

We collect information through:

Direct Collection

When you create an account, fill out your profile, upload content, or interact with the App.

Automatic Collection

Through device logs, cookies, app interactions, and analytics services.

Third-Party Services

When you use tools integrated with the App (such as analytics or hosting providers).

User Consent

We obtain user consent through clear and affirmative actions. By creating an account, users are required

to actively check a consent checkbox confirming that they have read and agreed to this Privacy Policy, the

Terms & Conditions, and the processing of their personal data.

For sensitive personal data (including dating preferences and related information), explicit consent is

obtained through a separate, clearly labeled checkbox in compliance with applicable data protection laws,

including GDPR and PIPEDA.

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4. PURPOSES FOR COLLECTING YOUR INFORMATION

(Required under PIPEDA)

We collect personal information for the following purposes:

• To create and manage your account

• To provide matching and connection features• To personalize your experience

• To display your profile to other users

• To send notifications and communications

• To ensure safety, moderation, and user protection

• To analyze performance and improve our services

• To detect and prevent fraud, spam, or abuse

• To comply with legal and regulatory requirements

We will not use your information for purposes not listed above without obtaining additional consent.

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5. LEGAL BASIS FOR PROCESSING

While PIPEDA is consent-based, we also rely on:

• Your express consent when signing up

• Contractual necessity to provide the App

• Legitimate interests (improving features, security)

• Legal obligations (e.g., responding to law enforcement)

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6. SHARING & DISCLOSURE OF INFORMATION

We may share your information:

6.1 With Other Users

Information you choose to display in your profile will be visible to other users of the App.

6.2 With Service Providers

We may share limited information with:

• Hosting providers

• Analytics platforms

• Payment processors (if applicable)

• Security and fraud-monitoring services

These providers are contractually required to protect your data.

6.3 For Legal Reasons

We may disclose information if required:

• By law, regulation, or court order

• To respond to government requests

• To protect safety, rights, or property6.4 During Business Transactions

If the company is sold, merged, or restructured, information may be transferred to new owners under

privacy agreements.

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7. INTERNATIONAL TRANSFERS

Some of our partners or service providers may operate outside Canada.

Your information may be stored or processed in other countries.

We ensure appropriate safeguards, such as:

• Contractual protections

• Secure data-transfer mechanisms

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8. DATA RETENTION

We retain personal information for as long as necessary, including:

• While your account is active

• For backup, security, and fraud-prevention purposes

• As required by law

When you delete your account:

• Your profile becomes inactive

• Certain data (e.g., messages, logs) may be temporarily retained

• We may keep information needed for legal compliance

Data Retention

We retain personal data only for as long as necessary to fulfill the purposes outlined in this Privacy

Policy, unless a longer retention period is required or permitted by law.

• Account data is retained while the user account remains active.

• Upon account deletion, personal data is permanently deleted or anonymized within 30–90 days,

except where retention is required for legal, regulatory, security, or fraud-prevention purposes.

• Backup systems may retain encrypted data for a limited period until automatically overwritten.

This satisfies GDPR Article 5(1)(e) and Canadian standards.

 

9. SECURITY OF INFORMATION

We use reasonable administrative, technical, and physical safeguards to protect your information,

including:

• Encryption

• Secure servers

• Access controls

• Monitoring for suspicious activity

No system is completely secure, and we cannot guarantee absolute security.

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10. YOUR RIGHTS (PIPEDA-COMPLIANT)

You have the right to:

• Access the personal information we hold about you

• Request corrections or updates

• Withdraw your consent

• Request deletion of certain data (subject to legal requirements)

• Challenge our compliance through a complaint

To exercise these rights, contact us at the information below.

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11. COOKIES & TRACKING TECHNOLOGIES

Affection may use:

• Cookies

• Web beacons

• Analytics SDKs

• Tracking pixels

These help us:

• Improve user experience

• Analyze performance

• Personalize features

You may disable cookies in your device or browser settings, but some features may not work properly.

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12. THIRD-PARTY LINKSThe App may contain links to websites or services not operated by us.

We are not responsible for their privacy practices or content.

Users should review the privacy policies of any third-party services they use.

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13. CHILDREN’S PRIVACY

The App is intended only for users aged 18 or older.

We do not knowingly collect information from minors.

If we discover that a minor has provided information, we will delete it immediately.

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14. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy periodically.

When changes occur, we will:

• Update the “Effective Date”

• Provide notice within the App when appropriate

Continued use of the App constitutes acceptance of the updated policy.

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15. CONTACT INFORMATION

For questions, concerns, or privacy-related requests, contact:

Affection-Bolingo Inc.

Email: [info@affectionbolingo.com]

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