Privacy Policy

Last Updated: August 31, 2024

This privacy policy (“Privacy Policy”) describes the information collected by Genesys Technologies, LLC. (“we,” “us,” or “our”), how that information may be used, with whom it may be shared, and your choices about such uses and disclosures. By using our website, located at http://www.lagunamatch.com (“Website”), our mobile apps, and/or other services we provide (collectively, “Laguna”), you agree to the practices set forth in this Privacy Policy.

Information we collect and how we collect it:

**Information collected automatically:**

When you use Laguna, we automatically collect and store certain information about your computer or mobile device and your activities. We may use this and other information described in this Privacy Policy to infer information, such as your interests. This information includes:

- **Mobile Device ID.** Your mobile device’s unique ID number (e.g., IMEI, AD ID).

- **Geolocation.** With your permission, your mobile device’s geographic location (GPS) when you first register for Laguna through our mobile app or when you enable location services within the app.

- **Device Information/Specifications.** Technical information about your computer or mobile device (e.g., type of device, web browser or operating system, IP address) to analyze trends, administer the site, prevent fraud, track visitor movement in the aggregate, and gather broad demographic information.

- **Usage Information.** How long and in what manner you use Laguna, which services and features you use and any content that you generate through and post on Laguna. This includes browsing and search history (including profiles you have viewed). We link your subscriber information with your activity on Laguna across all your devices using your email, phone number, or similar information.

- **Cookies:** We and our service providers and business partners use “cookies” to keep track of some types of information while you are visiting Laguna or using our services. “Cookies” are very small files placed on your computer, and they allow us to count the number of visitors to our Website and distinguish repeat visitors from new visitors. They also allow us and third parties we work with to save user preferences, track user trends, and advertise to you. We use both session and persistent cookies on our Website; session cookies expire at the end of a particular visit to our Website, while persistent cookies (also called stored cookies) remain active until you disable them through your browser settings, or until a pre-set expiration date. We rely on cookies for the proper operation of Laguna; therefore if your browser is set to reject all cookies, Laguna may not function properly. Without this information, we will not be able to provide you with all of the requested services, and any differences in services are related to your information.

- **Web Beacons:** “Web beacons” (also known as “clear gifs” and “pixel tags”) are small transparent graphic images that are often used in conjunction with cookies in order to further personalize Laguna for our users, collect a limited set of information about our visitors, and advertise to our users. We may also use web beacons in email communications in order to understand the behavior of our customers, such as whether an email has been opened or acted upon.

**Information we obtain from other sources:**

- **Google.** In order to register with certain Laguna apps, you may be asked to sign in using your Google login. If you do so, you are authorizing us to access and process certain Google account information, including your name and email address. By allowing us to access your Google account, you understand that we may obtain and process this information solely for the purpose of creating and managing your user profile within the app. We only obtain information from your Google account that you specifically authorize and grant us permission to obtain.

- **Facebook.** In order to register with certain Laguna apps, you may be asked to sign in using your Facebook login. If you do so, you are authorizing us to access and process certain Facebook account information, including information about you and your Facebook friends who might be common Facebook friends with other Laguna users. By allowing us to access your Facebook account, you understand that we may obtain and process certain information from your Facebook account, including your name, email address, birthday, work history, education history, current city, pictures stored on Facebook, and the names, profile pictures, relationship status, and information about your Facebook friends. We only obtain information from your Facebook account that you specifically authorize and grant us permission to obtain.

- **Third-Party Services:** We may receive the information described in this Privacy Policy from third-party services, such as analytics providers and advertising partners.

- **Other users.** Users of Laguna may provide us with information about you, including through customer support inquiries.

**Information you choose to provide:**

- **Information You Provide to Us.** When you register with certain Laguna apps, you must provide certain information, including your username and password, email address, zip code, birthday, gender, and gender preference. We will also ask you to upload photos for your profile and may collect any information (including location metadata and inferred characterizations or data) contained in these files. You may provide additional information about yourself (such as your school, occupation, current city, etc.) in order to build your Laguna profile. You may also provide “special categories of personal data” under applicable law, such as your race, ethnicity, religion, philosophical or political views, and information relating to your sex life or sexual orientation. By affirmatively providing Laguna with this information, you explicitly consent to our use of it for the purpose of fine-tuning your match criteria with other users. Any information that you provide in the non-personally identifiable section of your profile will be viewable by your match. When using Laguna, you may also provide payment information (where required for the purpose of payment). We collect and process your messages with other users as part of the operation of Laguna.

- **Referring Your Friends:** We encourage you to refer your friends to Laguna by sending us your friends’ email addresses or phone numbers. We will keep this information in our database and enable you to send these friends a one-time email or text message from your device containing your name and inviting them to visit our site. This email will also include instructions on how to opt-out and unsubscribe from our email list. You agree that you will not abuse this feature by entering the email addresses or phone numbers of those individuals who would not be interested in Laguna.

- **Emails:** We require an email address from you when you register with certain Laguna apps. We use your email for both “administrative” (e.g., confirming your registration, notifying you of matches) and “promotional” (e.g., newsletters, new product offerings, special discounts, event notifications, special third-party offers) purposes. Email messages we send you may contain code that enables our database to track your usage of the e-mails, including whether the e-mail was opened and what links (if any) were clicked. You may opt out of receiving promotional emails and other promotional communications from us at any time via the opt-out links provided in such communications, or by e-mailing privacy@laguna.com with your specific request. However, we reserve the right to send you certain communications relating to Laguna such as service announcements, security alerts, update notices, or other administrative messages) without affording you the opportunity to opt out of receiving such communications.

- **SMS Messages:** By providing your phone number to Laguna, you consent to Laguna sending you SMS messages with security codes.

- **Online Survey Data:** We may periodically conduct voluntary member surveys. We encourage our members to participate in such surveys because they provide us with important information regarding the improvement of Laguna.

- **Photo Verification and Biometrics:** In certain circumstances, Laguna may require you to verify your profile photo to prevent identity fraud and to improve Laguna’s platform as a safe place to meet online. To do so, we provide your data to a third-party, Persona, an identity verification company, who may use your information in accordance with its privacy policy, which you can review at https://withpersona.com/legal/privacy-policy. During this process, Persona may collect, capture, use, and store scans of your facial geometry extracted from photos you upload during the verification process, and retain any photos of identity documents you upload, photos of your face that you upload, or scans of facial geometry or related biometric information extracted from the photos during the verification process. We require Persona to destroy such data when these purposes have been satisfied, within no more than 3 years of your last interaction with Persona, unless otherwise required by law or legal process to retain the data.

**How we use the information:**

Pursuant to the terms of this Privacy Policy, we may use the information we collect from you for the following business purposes:

1. Facilitate matches with other Laguna users;

2. Respond to your comments and questions and provide customer service;

3. To tailor and provide communications to you about Laguna and related offers, promotions, advertising, news, upcoming events, and other information we think will be of interest to you;

4. Monitor and analyze trends, usage, and activities;

5. Investigate and prevent fraud and other illegal activities;

6. Provide, maintain, and improve Laguna and our overall business;

7. Where we otherwise have a legitimate interest in doing so, for example, direct marketing, research (including marketing research), network and information security, fraud prevention, and enforcing our terms, conditions, and policies or defending against legal claims; and

8. For any purposes disclosed to you at the time we collect your information or pursuant to your consent.

**Use for Research:** In addition to the uses outlined above, by using Laguna, you agree to allow us to anonymously use the information from you and your experiences to continue our research into successful relationships, including how to create and foster these relationships, so that we may continue to improve the Laguna experience. This research may be published in our blogs or interviews. However, all of your responses will be kept anonymous, and we assure you that no personal information will be published.

**Sharing Your Information:**

The information we collect is used to provide and improve the content and the quality of Laguna, and without your consent, we will not otherwise share your personal information to/with any other parties except: (a) to provide Laguna, (b) when we have your permission, or (c) under the following instances:

- **Other Users.** We may share your profile information with other Laguna users to facilitate matches in accordance with the functionality of our services. In addition, you may choose to share additional information with users of Laguna once you have matched with them.

- **Service Providers and Business Partners.** We may share your information with our third-party service providers and business partners that help us to accomplish certain business purposes (e.g., marketing and analytics providers, security and technology providers, advertising partners, and payment processors).

- **Legal Disclosures and Business Transfers.** We may disclose any information without notice or consent from you: (a) in response to a legal request, such as a subpoena, court order, or government demand; (b) to investigate or report illegal activity; or (c) to enforce our rights or defend claims. We may also transfer your information to (a) any affiliate of our corporate group or (b) another company in connection with a merger, financing due diligence, corporate restructuring, sale of any or all of our assets, or in the event of bankruptcy.

- **Third-Party Services You Interact With.** If you access third-party services, such as Facebook to log in to Laguna, these third-party services may be able to collect information about you, including information about your activity on Laguna, and they may notify your connections on the third-party services about your use of Laguna, in accordance with their privacy policies.

- **Aggregate Data.** We may aggregate or de-identify the information described in this Privacy Policy. Aggregated or de-identified data is not subject to this Privacy Policy.

Unless otherwise stated in this Privacy Policy, Laguna does not sell personal information to third parties. Laguna does permit third parties to collect the personal information described above through our service and shares personal information with third parties for business purposes as described in this Privacy Policy, including but not limited to providing advertising outside of our service based on users’ online activities over time and across different sites, services, and devices (so-called “interest-based advertising”). The information practices of these third parties are not covered by this Policy.

**Updating or Removing Account Information:**

You may review or edit your profile as you wish, by logging into your Laguna account using the information supplied during the registration process. If you would like to have us delete your account information, we may do so by deactivating your account first and then permanently deleting your account. Notwithstanding the foregoing, we may continue to contact you for the purpose of communicating information relating to your request for Laguna services, or to respond to any inquiry or request made by you, as applicable. To opt out of receiving messages concerning Laguna, you must cease requesting and/or utilizing services from Laguna and cease submitting inquiries to Laguna, as applicable.

**Your Privacy Rights**

In accordance with applicable law, you may have the right to:

- **Access Personal Information** about you, including: (i) confirming whether we are processing your personal information; (ii) obtaining access to or a copy of your personal information; or (iii) receiving an electronic copy of personal information that you have provided to us, or asking us to send that information to another company (aka the right of data portability);

- **Request Correction** of your personal information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal information;

- **Request Deletion** of your personal information;

- **Request Restriction** of or **Object** to our processing of your personal information; and

- **Withdraw Your Consent** to our processing of your personal information.

If you would like to exercise any of these rights, please contact us as set forth below. We will process such requests in accordance with applicable laws.

**Third-Party Sites**

Laguna may contain links to other websites and services. If you choose to click on a third-party link, you will be directed to that third party’s website or service. The fact that we link to a website or service is not an endorsement, authorization, or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third-party websites or services. These third parties may place their own cookies or other files on your computer, collect data, or solicit personal information from you. Other websites and services follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the other websites and services you visit.

**Data Retention**

Laguna retains the personal information we receive as described in this Privacy Policy for as long as you use our services or as necessary to fulfill the purpose(s) for which it was collected, provide our services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws. As outlined above, Laguna works with a third-party identity verification company, Persona, to use biometric identifiers and associated information for photo verification. Biometric data will be destroyed when the verification purposes have been satisfied, within no more than 3 years of your last interaction with Persona, unless otherwise required by law or legal process to retain the data.

**Securing Your Personal Information**

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unintentional disclosure. By providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of Laguna. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Site or sending an e-mail to you. You may have a legal right to receive this notice in writing.

**Your Choices**

- **Cookies.** You may be able to refuse or disable cookies by adjusting your browser settings. Because each browser is different, please consult the instructions provided by your browser. If you choose to refuse, disable, or delete cookies, some of the functionality of Laguna may no longer be available to you. Without this information, we are not able to provide you with all the requested services, and any differences in services are related to your information.

- **SMS Messages:** You may opt out of receiving SMS messages from us by following the instructions in the SMS message or by otherwise contacting us.

- **Mobile Devices:** We may send you push notifications through our mobile application. You may opt out from receiving these push notifications by changing the settings on your mobile device. Your mobile device may include a feature that allows you to opt out of some types of targeted advertising (“Limit Ad Tracking” on iOS and “Opt out of Interest-Based Ads” on Android). You can switch off GPS location information functionality on your mobile device if you do not wish to share GPS information.

- **“Do Not Track.”** Some browsers transmit “do-not-track” signals to websites. Because of differences in how browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. We currently do not take action in response to these signals.

**Supplemental Notice for California Residents**

This Supplemental California Privacy Notice only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA provides California residents with the right to know what categories of personal information Laguna has collected about them and whether Laguna disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding twelve months. California residents can find this information below:

**Sensory data**

The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth above.

**Additional Privacy Rights for California Residents:**

- **“Sales” of Personal Information under the CCPA:** For purposes of the CCPA, Laguna does not “sell” personal information, nor do we have actual knowledge of any “sale” of personal information of minors under 16 years of age.

- **Nondiscrimination:** California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.

- **Authorized Agent:** Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. To designate an authorized agent, please contact us as set forth below.

- **Verification:** When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include confirming the email address associated with any personal information we have about you.

If you are a California resident and would like to exercise any of your rights under the CCPA, please contact us as set forth below. We will process such requests in accordance with applicable laws.

- **“Shine the Light” requests:** You have the right to request and obtain from us once a year at no charge a list of all third parties, if any, to which we have disclosed your personal information during the preceding calendar year for those third parties’ direct marketing purposes. If you would like such a list, please contact us at privacy@lagunamatch.com. For all such requests, you must put the statement “Shine the Light Request” on your request, as well as your name, street address, city, state, and zip code. Please note that we will not accept these requests by telephone or fax and are not responsible for notices that are not labeled or sent properly or that do not have complete information.

**Using Laguna from outside the United States:**

If you are visiting Laguna from outside the United States, please be aware that your information may be transferred to, stored, and processed globally, including in the United States where our servers are located and our central database is operated. By using our services, you understand and agree that your information may be transferred to our facilities and those third parties with whom we share it for processing as described in this Privacy Policy. Where required by law, international transfers of personal information will be supported by an adequacy mechanism.

**Changes to this Privacy Policy:**

We may update this Privacy Policy from time to time. If there are any material changes to this Privacy Policy, Laguna will notify you by email or as otherwise required by applicable law. When we post changes to this Privacy Policy, we will revise the “last updated” date at the top of this Privacy Policy. We recommend that you check our Website from time to time to inform yourself of any changes in this Privacy Policy or any of our other policies.

**How to Contact Us:**

If you have any questions about our privacy practices, this Privacy Policy, or how to lodge a complaint with the appropriate authority, please contact us by email at privacy@lagunamatch.com.