PRIVACY POLICY

Effective date: 27.11.2025

PLEASE READ THIS PRIVACY POLICY CAREFULLY ALONG WITH OUR TERMS OF USE, WHICH ARE REFERENCED HEREIN. BY USING THE SERVICES LISTED BELOW, YOU ACKNOWLEDGE THAT YOU HAVE REVIEWED THIS PRIVACY POLICY AND TERMS OF SERVICE AND AGREE TO BE BOUND BY THEM

1. General information

1.1. References in this Privacy Policy to “Pheromance”, “Service”, “Application”, “App” relate to the app, Pheromance, operated by RED PANDA APP LLC, a limited liability company registered in the USA under the company number 202211291642638, having its address at 11510 Old Oakland Blvd N Dr, Indianapolis, IN, 46236 (“Pheromance”).

1.2. The Company determines the purposes and means of processing Personal Data related to Services as outlined in this Privacy Policy. The Company is committed to protecting and respecting the privacy of its Users and Clients (hereafter “You”, “Client”, “User”) and ensures their security when using the Service. This Privacy Policy is intended to help the Client to understand what data and for which purposes the Company collects, and how collected data is processed and protected.

1.3.   By using the Services, you affirm that you are at least 18 years old or have reached the age of majority in your jurisdiction, or that you have reviewed this Privacy Policy with your parent or guardian who agrees to this Privacy Policy on your behalf.

Individuals under 18 years old are prohibited from using our App or Services, as they are not intended for that age group. We will delete any personal data we believe to be from users aged 18 or younger. If you suspect that we have collected personal data from someone under 18 (or the age of majority in your jurisdiction) or aware that a child or minor has provided personal information on the App or within the Services, please reach out to us at [email protected], so we can take appropriate action. 

By using the Service, you agree to the collection and use of information in accordance with this Privacy Policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms of Use.

1.3.1. The Company may and will terminate any Client’s account upon discovery that the respective account was created in violation of the provisions of this paragraph.

1.4. You may be required to register for an account ("Account") to use certain Services or access them through a social networking service ("SNS"). Your Account is personal, and you may not transfer, lease, or sell it to anyone. You agree to provide accurate and up-to-date information when registering and are solely responsible for maintaining the confidentiality of your login details.

By registering with the Service, the Client consents to the processing of the Client’s Personal Data by the Service in accordance with the provisions set below.

By registering with the Service, the Client gives consent to the Company to anonymize the Client’s Personal Data for the purposes of further use in anonymized form in order to improve the performance of the Service.

1.5. The Company reserves the right to amend this Privacy Policy; therefore, it is recommended that the Client of the Service checks the Privacy Policy on a regular basis. The service will send a notice or an email regarding such changes to the Client.

1.6. All the changes to this Privacy Policy are effective as of the “Last updated” date. We may notify you about changes to this Privacy Policy by placing a notice via the Services, this website or App. The Client who continues to use the Service after the Last updated date is deemed to accept the changes made to it. We encourage you to periodically check back and review this Privacy Policy so that you always know our current privacy practices.

2. Contact information

2.1. For any inquiries regarding this Privacy Policy, please contact us via the email provided herein or through the support options available in our Services.

3. Collection of data

3.1. When using the Services, the Client agrees to the processing of the following Personal Data:

3.1.1. Personal Data that the Client provides to the Service:

a. When creating an account, the Client provides the Service with at least the Client’s login credentials (including unique username and password combination for the Client’s account), as well as basic details necessary for the Service to work, such as the Client’s name, gender and age.

b. When completing the Client’s profile, the Client could provide additional information, such as details on the Client’s physical characteristics (including height, weight, body type and sexual preferences), background (including education, financial situation, housing situation and ownership of a vehicle), personality (including purpose of acquaintance, sociability and attitude towards children), lifestyle (including attitude towards alcohol and smoking), date of birth, interests and other details about the Client, as well as content, such as pictures and photos.

To add certain content, such as pictures and photos, the Client may be required to provide expressed approval to allow the Service to access the Client’s camera or device’s photo album. We understand the importance of protecting your privacy and want to provide transparency regarding the collection and usage of face data. Please see the "Face Data" section for more information on how we may use face data.

Some of the information provided by the Client may be classified as Sensitive Personal Information (SPI) under applicable U.S. privacy laws. This may include the Client’s racial or ethnic origin, sexual orientation, political opinions, or religious or philosophical beliefs. By placing such information in the Client’s account, the Client acknowledges that the information may be processed as part of the Service’s functionality. Where required by law, the Company will obtain the Client’s explicit consent before collecting or processing such information.

c. When contacting Support Service, available through a separate chat in the App: the information that the Client provides during the interaction. The Company reserves the right to monitor or record interactions between the Client and the Support Service for training purposes and to ensure high quality of service.

d. When participating in the Client verification procedures: the Client’s Personal Data, as requested by the Service for the Client identification purposes.

e. When participating in surveys or focus groups: insights and evaluation of the Company’s services, responses to the questions from the Service.

f. When communicating with other Clients through a chat in the App: the contents of the relevant chat (including cases when such contents include Personal Data);

3.1.2. Personal Data collected through the use of the Service:

When the Client is using the Company’s App, the Service may collect data regarding the device(s) the Client uses to access the Service (such as the Client’s IP address, device identifier (including unique advertising device identifiers, for example, Google Advertiser ID and IDFA), technical and statistical data (including data about the Internet connection, cellular service provider and application usage data) and location data (upon a separate consent from the Client).

3.1.3. Personal Data collected from third parties:

The Client can connect the Client’s account to a social network (including but not limited to Facebook) by way of registering through the corresponding social network. After connecting the Client’s account in a social network, the Client would be able to add the personal information from the Client’s profile in the corresponding social network to the Client’s profile in the Service. The following information could be received by the Client from the social network: the Client’s name, ID within the respective social network, photo, email address, IP address, phone number, age, gender, preferred language, country, information about the Client’s device, location, list of friends in the social network, data on the use of other networks (as contained in the respective social network). By connecting the Client’s account with the Company to a social network, the Client gives explicit consent to the processing of the Client’s Personal Data contained in the Client’s account in the respective social network.

3.2. By providing Personal Data to the Company, the Client warrants that such data is true, accurate and up to date.

3.3. For collecting the above-mentioned data we may use the following software and programs:

Name

Registered Seat

Facebook Ads (Meta Platforms, Inc., Meta Platforms Ireland Limited)

1601 Willow Road, Menlo Park, CA 94025, USA

Merrion Road, Dublin 4, D04 X2K5, Ireland

4. Use of Client’s personal data

4.1. The Company collects, processes, and uses the Personal Data of the Clients of the Service based on the following grounds:

a. Providing the Service – Including account creation, customer support, and transaction processing.

b. Legal Compliance – To comply with applicable laws, respond to legal requests, and enforce our rights.

c. Business Operations – Such as fraud prevention, security enhancements, analytics, and service improvements.

d. Marketing & Advertising – When required by law, the Company may seek the Client’s consent for marketing communications, targeted advertising, or processing of sensitive personal data.

e. Security & Fraud Prevention – To protect the Company, its Clients, and third parties from fraudulent, unauthorized, or illegal activities.

4.2. The Company collects and processes the Personal Data of the Service’s Clients in order to maintain, improve the functionality of the Service and to ensure compliance with legal and business-related requirements.

The Client’s Personal Data is processed for the following purposes:

4.2.1. Providing and managing the Client’s account and Service functionality:

a. to set up, operate and manage the Client’s account and, if necessary, to contact the respective Client through the means provided by the Client upon registration, in connection with the operation and management of the Client’s account;

b. to analyze the Client’s profile, activity on the Service, preferences and current location in order to recommend the Client’s profile to the other Clients of the Service and to recommend the other Clients’ profiles to the Client;

c. to proceed and respond to the requests and enquiries received from the Client;

d. for administrative purposes, such as password reminders, and service messages (including but not limited to the App’s maintenance messages, updates to the Service’s Privacy Policy and Terms of Use);

4.3.2. Under legitimate interests of the Service:

a. to connect the Client’s account to a social network (including but not limited to Facebook);

b. for Client verification purposes, conducted in relation to ongoing or alleged misbehavior, performed by the Client of the Service, in order to block accounts as part of the Services anti-spam procedures, to investigate possible fraud;

c. to evaluate the effectiveness of marketing and to perform market research and training.

4.3.3. Under an explicit consent from the Client:

a. to facilitate networking opportunities of the Client with the Service by way of allowing the Client to add additional information to the Client’s account (including information on the Client’s sexual orientation);

b. to process Personal Data from the Client’s account in a third-party social network, connected to the Client’s account with the Company;

c. to serve the Client with targeted in-App advertisements;

d. for remarketing purposes, allowing the Service to identify the Client who has previously visited the App and optimize advertising information according to the Client’s preferences. This feature is used by the Service through third-party services such as Google Advertising, myTarget and Facebook;

e. to prepare statistics regarding the use of the Services by the Client;

f. to identify possible technical malfunctions in the work of the Service, to assist internal research and development and to make improvements to the App or Services.

4.4. Face Data

4.4.1. When using our Apps and Services, we may collect your images to provide appropriate services, but this information is not used for identification or biometric recognition purposes.

4.4.2. Our Services do not employ facial recognition, biometric templates, or any regulated systems. We strictly comply with applicable laws, ensuring that no activities involving facial information ("Face Data") or the creation of biometric templates occur, thereby prioritizing user privacy.

4.4.3. We may collect photographs via your camera or camera roll, which may include Face Data. However, we do not access your photo albums, even if permission is granted. While photographs are not classified as biometric identifiers, we recognize that they require a high level of protection equivalent to other sensitive information.

In compliance with the law, we ensure that:

4.4.3.1. Face Data is used solely for specific features within the App. We may store Face Data for technical purposes without automated processing for identification. We do not extract or store face geometry or biometric identifiers.

4.4.3.2. Consent and Client Control: We obtain your explicit consent before collecting any personal data, including photographs with Face Data. You retain control over the face data shared with our application, and we will seek additional consent for any other intended use.

4.4.3.3. Storage and Security: We securely store photographs containing Face Data on our servers or locally on your device, implementing technical and organizational measures to protect against unauthorized access. Photographs will be retained only as long as necessary to fulfill their intended purpose. Upon completion of the purpose or withdrawal of consent, we will securely delete your data.

4.4.3.4. Third-Party Access and Data Sharing: We do not share or disclose your photographs containing Face Data to third parties unless explicitly stated and with your prior consent.

4.4.3.5. Data Retention: You have the right to request deletion of your photographs containing Face Data at any time. For more information, please see Section 5 on Data Retention.

4.4.3.6. Please note that we do not use your photographs for any purpose other than those mentioned above.

4.4.4. We do not sell, lease, trade, or profit from your biometric identifiers or information.

4.4.5. If you have questions or concerns about our practices, please contact us at [email protected].

5. Duration of the Сlient’s data retention

5.1. The Company retains your Personal Data only as long as necessary for the purposes outlined in this Privacy Policy or/and as permitted by applicable law in order to carry out relevant actions or provide relevant Services. We may retain Personal Data for a shorter period unless it is required for security enhancements or functional improvements.

Personal Data, that the Client has communicated to the Service upon registration and subsequently through the use of the Service, will be retained by the Service as long as the Client remains the Client of the Service.

5.2. To protect the safety and security of the Clients of the Service, the Company implements a safety retention window of 30 days following a Client’s account termination.

5.3. The Company reserves the right to store the Client’s Personal Data for a longer period of time than provided in paragraph 5.1., when it is performed in order to fulfill the legal obligations of the Service, ensure compliance with applicable law or when the relevant Personal Data is stored on the basis of the Service’s legitimate interests (including security reasons, prevention of fraud).

6. Disclosure of Personal Data

6.1. The Company may disclose the Client’s Personal Data if required by law, in response to a valid legal request such as a subpoena, court order, or government directive.

6.2. Company may disclose the Client’s Personal Data with third parties in the following cases:

a. Other Clients of the Company:

The Client shares information with other Clients of the Company by way of voluntarily disclosing information on the Service (including but not limited to information in the Client’s profile).

It is in the Client’s discretion to choose the information to be disclosed with the Service and the Company rescinds from responsibility for the other Clients of the Service regarding the way they might use such information, disclosed by the Client.

b. Third-party advertising services  (Data Processors or Service Providers). The Company uses the following services (list is provided alongside with privacy policies of the relevant services):

c. Third-party analytics services. The Company uses the following services (list of services is provided alongside with privacy policies of the relevant services):

d. Cloud services providers :

e. Client support services. All requests of Clients of the Company are processed by a third-party Client support service UseDesk (privacy policy available at  https://usedesk.com/privacy).

g. Providing Client’s data by law:

The Company may disclose the Client’s Personal Data when such disclosure is required by law, is reasonably necessary, or is in response to a valid legal request:

6.2. The Company may engage third parties to assist in processing the Client’s Personal Data or to support business operations. Such third parties are responsible for handling Personal Data in accordance with applicable laws and, where applicable, their respective agreements with the Company.

6.3. In the event of a merger, acquisition, or sale of assets, the Client’s Personal Data may be transferred as part of the transaction. The Company will ensure that any such transfer complies with applicable U.S. privacy laws.

7. Client’s Privacy Rights

7.1. The Client of the Service may have certain rights regarding the Client’s Personal Data under applicable U.S. privacy laws. These rights vary based on the Client’s state of residence and the scope of relevant regulations.

7.2. Depending on the Client’s state of residence, the Client may have the following rights regarding the Client’s Personal Data:

Right to Know (Access) – the Client may request information about whether the Company processes the Client’s Personal Data, including the categories of data collected, sources of collection, purposes of processing, and the categories of third parties with whom the data is shared.

Right to Delete (Erasure) – the Client may request deletion of the Client’s Personal Data collected by the Company, subject to certain exceptions such as legal compliance, security needs, or business requirements. If the Client requests deletion, the Company may retain necessary data as required by law.

Right to Correct (Rectification) – the Client may request that the Company correct any inaccurate Personal Data maintained about the Client.

Right to Opt-Out of Data Sales or Sharing – if the Company sells or shares the Client’s Personal Data with third parties for targeted advertising or other commercial purposes, the Client has the right to opt out of such sales or sharing.

Right to Data Portability – the Client may request a copy of the Client’s Personal Data in a portable format to transfer to another service provider or directly to a third party designated by the Client.

Right to Limit Processing of Sensitive Data (Where Applicable) – depending on the Client’s state, the Client may have the right to limit the processing of the Client’s sensitive Personal Data.

Right to Withdraw Consent (Where Applicable) – if the Company processes the Client’s Personal Data based on the Client’s consent, the Client may withdraw that consent at any time. However, withdrawing consent may affect the Client’s ability to use certain features of the Service.

Right to Appeal a Denied Request – if the Company denies the Client’s request, the Client may have the right to appeal the decision within a specified timeframe.

Right to Non-Discrimination – exercising the Client’s privacy rights will not result in denial of services, different pricing, or a lower quality of service.

7.3. The abovementioned rights are not absolute. In order to exercise some of the rights, the Client should meet certain conditions and requirements, specified by the law.

7.4. For more information regarding the Client’s rights over Personal Data, the Client of the Service should contact [email protected]. In order to exercise the Client’s rights, the Client should submit a request to [email protected].

7.5. The Client of the Service should also be acknowledged of the Client’s right to file a complaint with the appropriate consumer protection or privacy enforcement agency in the Client’s state of residence.

8. Protection measures

8.1. When using the App, the Client’s personal data is transferred by the Service as follows:

a. to the domain https://pheromance.com, which belongs to Company;

b. to the Amazon Cloud Services server (more information can be found on this link: https://aws.amazon.com/).

8.2. The Company works hard to protect its Clients from unauthorized access to or alteration, disclosure or destruction of their Personal Data. Yet, as with any other technology company, although the Company takes steps to secure the Clients’ information, it could not be promised or guaranteed, that unauthorised access, hacking, data loss, or other breaches will never occur.

The Company reserves the right to suspend the Client’s account without notice if there is a reasonable suspicion of breach of security or unauthorised access to such account. If you believe that your account or information is no longer secure, please notify the Company immediately by sending a message at  [email protected].

8.3. The Client should take reasonable steps in order to keep the Client’s Personal Data (including the account password) safe. It is recommended that the Client does not share the account password with anyone.

9. Cookies

9.1. In order to guarantee an optimal level of usability and performance and to ensure relevance of promoted services, the Company uses cookies and similar technologies in order to track the interaction of Clients with the App. This section explains the different types of cookies that may be set when the Client uses the App, helping to understand and manage them as the Client wishes.

9.2. A cookie is a small file that is stored locally on the Client’s technical device as soon as the App is visited. Cookies function by saving particular sets of data, such as, for example, the Client’s language selection. Should the Client open the App again later, a cookie will transmit this data back to the App. The App’s cookies don't store personal information like the Client’s name or address.

9.3. Types of Cookies

The Company’s App uses different types of cookies:

9.4. The Client can at any time reset device identifiers by activating the appropriate setting on the Client’s mobile device. The procedure for managing device identifiers is slightly different for each device.

9.5. Below is information about how the Company uses Clients’ cookies in the App:

Necessary cookies – these cookies are strictly necessary to provide the Client with the Company’s services.

Authentication cookies – these persistent cookies help the Service to identify the Clients so that the Client can log into the App automatically.

Analytics cookies – these cookies help the Service to understand how the App is being used, and help us customize and improve the Service.

List of relevant providers:

Google analytics – https://marketingplatform.google.com/about/analytics/terms/us/  , part 7, Privacy

AppMetrica – https://metrica.yandex.com/about/info/privacy-policy

AppsFlyer – https://www.appsflyer.com/services-privacy-policy  

Advertising cookies – these cookies are used to make advertising messages more relevant to the Client. They perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed for advertisers, selecting advertisements that are based on the Client’s interests and measuring the number of ads displayed and their performance, such as how many people clicked on a given ad.

List of relevant providers:

Google Advertising https://policies.google.com/privacy (www.google.com/settings/ads to opt-out from the Google Ads)

AppLovin https://www.applovin.com/privacy/

Appmetrica https://metrica.yandex.com/about/info/privacy-policy

MyTarget https://target.my.com/optout/

Mopub https://www.mopub.com/legal/privacy/

IronSource https://developers.ironsrc.com/ironsource-mobile/air/ironsource-mobile-privacy-policy/

Vungle https://vungle.com/privacy/

Inmobi https://www.inmobi.com/privacy-policy/

Tapjoy https://www.tapjoy.com/legal/advertisers/#privacy-policy

AdColony https://www.adcolony.com/privacy-policy/

Social networking cookies – these cookies are used to enable the Client to connect the Client’s account to third-party social networks.

List of relevant providers: 

Facebook https://www.facebook.com/policy.php

9.6. Below is information about how the Company uses the Clients’ cookies on the website:

Necessary – Necessary cookies help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies.

Name: __cfduid, CookieConsent

Provider: HTTP Cookie

Purpose:__cfduid: Used by the content network to identify trusted web traffic., 

CookieConsent: Stores the user's cookie consent state for the current domain.

Expiry

Type: Necessary.

10. International Data Transfers

10.1. The transfer of the Client’s Personal Data may involve international data transfers, including to and from the United States and other jurisdictions where the Company operates, stores, or processes data. The Company implements appropriate safeguards to ensure that the Client’s Personal Data is protected in accordance with applicable privacy laws and recognized industry standards.

If the Client is located in the European Union (EU) or a jurisdiction where specific data protection laws apply, the processing of the Client’s Personal Data may be subject to additional rights and protections.

11. Service Provider

We may engage third-party companies to assist in delivering our Service, including analytics, advertising, and customer support. These Service Providers have access to your data only to perform specific tasks on our behalf and are obligated not to disclose or use it for other purposes.

12. Links to Other Sites

Our Service may link to other websites not operated by us. We advise you to review their privacy policies. We are not responsible for the content or practices of any third-party sites you visit and assume no responsibility for the content or practices of any third-party sites or services.

Analytics

We may use third-party Service Providers to monitor and analyze the use of our Service.

For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: http://www.google.com/intl/en/policies/privacy/

Behavioral Remarketing

The Company uses remarketing services to advertise on third-party websites to you after you visit our Service. We and our third-party vendors use cookies to inform, optimize and serve ads based on your past visits to our Service.

You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950

To opt out from Facebook's interest-based ads follow these instructions from Facebook: https://www.facebook.com/help/568137493302217

Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA  http://www.aboutads.info/choices, the Digital Advertising Alliance of Canada in Canada  https://youradchoices.ca/  or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.

For more information on the privacy practices of Facebook, please visit Facebook's Data Policy: https://www.facebook.com/privacy/explanation

Customer support

The Company may use third-party customer support services to provide customer support within the Service.

13. Children’s Privacy

Our Service is not intended for users under 18 years of age. We do not knowingly collect data from children under 18 years. If we learn that we have collected such data, we will take the necessary steps to remove it.

14. Changes to This Privacy Policy

We may update this Privacy Policy periodically. Changes will be posted on this page, and you may be notified through a prominent notice on our Service prior to the change taking effect.