PAIRA PRIVACY POLICY

Paira Technologies, Inc.

Effective date: August 15, 2026

This Privacy Policy explains how Paira Technologies, Inc. ("Paira," "we," "us," or "our") collects, uses, discloses, and retains personal information when you use the Paira mobile application, visit www.joinpaira.com, join our waitlist, register for an event we host, or otherwise interact with us. It also explains the choices and rights you have.

If you do not agree with this Policy, please do not use our services. If you have questions, contact us at admin@joinpaira.com.

1. Summary

• Paira is a dating platform. We process information that is sensitive by its nature, including sexual orientation, precise location, and, if you choose to provide it, race or ethnicity, religious beliefs, and political views. We process sensitive information with your consent.
• If you turn on contact sync, we upload and store the names and phone numbers in your device contacts, including people who are not Paira users. Section 4 explains this in detail, and it is the section to read if you are here because someone else’s contact list included you.
• We use automated tools and human review to moderate profile photographs and profile text. Authorized personnel can access stored photographs, reports, and message histories for safety, security, and legal purposes. Section 6 explains this.
• We do not sell your personal information, and we do not share it for cross-context behavioral advertising. If that changes, we will update this Policy, give notice, and provide an opt-out before the change takes effect.
• When you delete your account, we hold your data for thirty (30) days so you can change your mind, then permanently delete it, subject to the limited exceptions in Section 9.4.
• We do not collect biometric identifiers. We do not use facial recognition, face matching, or liveness detection. Section 11 explains what we would do before introducing any such feature.

2. Information We Collect

2.1 Information you give us

• Account information: name, phone number, email address, password, and date of birth.
• Profile information: photographs, biography, interests, dating intentions, height, education, hometown, languages, lifestyle information such as drinking, smoking, cannabis use, diet, and activity level, and information about children and family plans.
• Sensitive profile information: gender and sexual orientation, which are used for matching, and, at your option, race or ethnic origin, religious or philosophical beliefs, and political views.
• Wingmate and pairing information: the friend you pair with for a double date, and information you provide about that person.
• Communications: messages you send through the app, reports you submit, and correspondence with our support team.
• Event registration information: where registration for an event we host is operated through a third-party ticketing or form service, the information you submit through that service is passed to us, which may include your name, phone number, and the name and phone number of the person you are bringing.
• Waitlist and marketing information: contact details you give us to join a waitlist or to receive text messages.

2.2 Information collected automatically

• Precise location: with your permission, we collect precise GPS location from your device. Precise location is central to how the service works, because we use it to show you people and venues near you. You can turn it off at any time in your device settings, and if you do, features that depend on it will be limited or unavailable.
• Device and log data: IP address, device identifiers, device model, operating system and version, language settings, crash and diagnostic data, and records of how and when you use the app.
• Activity data: matches, pairings, chats initiated, events applied for, and Sparks balance, accrual, and redemption history, including which offer was redeemed, at which venue, and on what date.
• Website data: cookies and similar technologies on our website, described in our Cookies Policy at www.joinpaira.com/legal-pages/cookies-policy. Our mobile app does not use cookies.

2.3 Information from other sources

• From other users: another user may provide information about you, including your name and phone number, when they sync contacts, name you as a wingmate, or register you for an event.
• From the app store: transaction identifiers, subscription status, and receipt validation data. We do not receive your payment card number, billing address, app store password, or any age information about you.
• From our service providers: results of automated content moderation, attribution data indicating how you found the app, and analytics about how the app is performing.

We do not purchase personal information from data brokers.

3. How We Use Personal Information

• To create and operate your account, including authentication and confirming the date of birth you give us at registration.
• To provide the service, including matching, pairing, group chat, event administration, and showing your profile to other users.
• To administer subscriptions and purchases, including validating receipts and restoring purchases.
• To administer Sparks, including crediting, displaying balances, processing redemptions, and preventing abuse.
• To keep the service safe, including content moderation, investigating reports, detecting fraud and fake accounts, and enforcing our Terms of Service.
• To communicate with you, including transactional and administrative messages, support responses, and, where you have opted in or applicable law permits, marketing.
• To improve the service, including analyzing usage patterns and evaluating features.
• To comply with law and to establish, exercise, or defend legal claims.

4. Contacts, Ties, and People Who Are Not Users

4.1 What contact sync does. Contact sync is optional and off by default. If you turn it on, we upload and store the names and phone numbers of the contacts your device permission makes available to us, in a form associated with your account, in order to show mutual connections, called Ties, between you and other people on the platform. Once sync is on, the app reconciles against your accessible contacts each time it opens or returns to the foreground. You may also add individual contacts instead of syncing all of them.

4.2 Wingmate lookup. When you select a wingmate, the app sends the phone numbers available to it to our servers so we can identify which of them belong to existing Paira users. That lookup does not create stored contact records, although ordinary infrastructure logs may record that the request occurred.

4.3 We do not message your contacts. Turning on contact sync does not cause us to contact anyone. If you choose to invite a contact, your device’s own messaging application opens so that you send the message yourself. We do not send it.

4.4 How long we keep contact data. Ties records are kept while your account exists and contact sync remains enabled. If you revoke contact permission, we delete the Ties records associated with your account and disable sync.

4.5 Suppression records. If you remove a contact from Ties by hand, we keep a record of that person’s name and phone number for one purpose only, which is to prevent the contact from being added back automatically the next time sync runs. A suppression record functions as an instruction not to re-add, so it is kept while your account exists, it is not deleted when contact permission is revoked, and it has no expiration. Suppression records are never used for matching, invitations, marketing, analytics, or any other purpose, and are never shared with third parties. They are deleted when your account is permanently deleted.

4.6 If you are not a Paira user. If someone who uses Paira had your name and phone number in their device contacts and turned on contact sync, we may hold that information even though you do not have an account. We do not use it to contact you, to build a profile about you, or for advertising. You may ask us to delete it, or to suppress it so that it is not stored again, by emailing admin@joinpaira.com from an address you control or by writing to the address in Section 15, and telling us the phone number concerned. We will act on the request and will confirm when we have done so. You have this right regardless of the state you live in.

5. Sensitive Information and Consent

5.1 What we treat as sensitive. We treat the following as sensitive personal information: sexual orientation, race or ethnic origin, religious or philosophical beliefs, political views, and precise geolocation. Some state laws treat additional categories as sensitive, and we apply the same protections to those categories where they apply.

5.2 Consent. We ask for your consent before we process sensitive information, and we ask again if we want to use it for a materially different purpose. Gender and sexual orientation are needed to operate the matching features, and you cannot use those features without providing them. Race, religion, political views, and other lifestyle fields are optional, and you may leave them blank or remove them at any time in your account settings.

5.3 Sensitive information is visible to other users. Anything you put on your profile, including sensitive information, is shown to other users in the ordinary operation of matching. Do not put information on your profile that you do not want other users to see.

5.4 Withdrawing consent. You may withdraw consent at any time by removing the information from your profile, by adjusting your settings, or by emailing admin@joinpaira.com. Withdrawal does not affect processing that already occurred, and removing information that matching requires may prevent your profile from being shown.

6. Moderation, Message Storage, and Access by Our Personnel

6.1 Automated moderation. Profile photographs and profile text are screened automatically by a third-party content moderation service before or shortly after publication. Content that the service scores above our blocking threshold is rejected and removed. Content that scores below the blocking threshold but above our review threshold is published and placed in a queue for human review, and it may remain visible while it is in that queue.

6.2 Message filtering. Text you send in the app is checked against a list of prohibited terms and may be blocked from sending.

6.3 Human access. Messages you send through the app are stored on our systems. Authorized Paira personnel with moderation permissions can access stored photographs, reports, and message histories for operational, security, legal compliance, trust and safety, and investigative purposes, including investigating reports of harassment, abuse, fraud, or violations of our Terms of Service. Access is restricted to personnel we authorize. Moderation actions taken on an account or on content are recorded, and our systems keep authentication and service logs, although we do not currently keep a record of every occasion on which an administrator views a record. We do not read messages for advertising purposes, and we do not send message content to any artificial intelligence moderation service.

6.4 Group chat. A double date chat includes more than two people. Anything you send in a group chat is visible to every participant in it, and any participant may retain or repeat it. Treat a group chat as a conversation among all of its members.

7. How We Disclose Personal Information

7.1 Service providers. We use vendors to operate the service. They are permitted to process personal information only on our instructions and only for the purposes we authorize, and they are bound by contract to protect it. They include:

This list is current as of the effective date of this Policy. If we add a provider that processes personal information in a materially different way, we will update this Policy.

7.2 Other users. Your profile, including any sensitive information you add to it, is shown to other users through the matching features. Messages you send are visible to the people you send them to.

7.3 Venues. We do not give partner venues your personal information. Redemption of a Partner Offer happens on your device, and the venue applies the discount in its own system without receiving your name, contact details, or profile from us. We may give venues aggregate statistics, such as total redemption counts, that do not identify any individual.

7.4 Legal and safety. We may disclose personal information where we believe in good faith that it is necessary to comply with law, to respond to lawful requests from public authorities, to enforce our Terms of Service, to detect or prevent fraud or security incidents, or to protect the rights, property, or safety of any person.

7.5 Corporate transactions. If we are involved in a merger, financing, acquisition, or sale of assets, personal information may be transferred as part of that transaction. We will give notice of any transfer that materially changes how personal information is processed, and any acquirer will remain bound by this Policy until it gives notice of a change.

8. Selling and Sharing

8.1 Current practice. We do not sell personal information for money or other valuable consideration, and we do not share personal information for cross-context behavioral advertising, as those terms are used in California and comparable state laws. We have not done so in the twelve months preceding the effective date of this Policy.

8.2 If that changes. We may in the future want to provide information about redemption activity or audience characteristics to partner venues or to advertisers, or to deploy advertising and analytics technologies that involve disclosures of that kind. We will not do so under this version of the Policy. Before any such practice begins, we will update this Policy, give notice in the app or by email, provide a clear method to opt out, obtain opt-in consent where applicable law requires it for sensitive information or for users under sixteen, and honor opt-out preference signals.

8.3 Opt-out preference signals. Our website does not currently detect the Global Privacy Control signal, because at present we neither sell nor share personal information and there is nothing for the signal to opt out of. We will implement detection, and treat the signal as a valid opt-out request, before we begin any practice described in Section 8.2 and before we deploy any advertising or analytics technology on the website.

9. Retention

9.1 Active accounts. We keep personal information for as long as your account is open and you use the service.

9.2 Deletion. When you delete your account, we hold your information for thirty (30) days so that you can restore the account if you change your mind. During that period your profile is not visible to other users and access to the app is restricted. At the end of the thirty days we permanently delete, from our active systems, your profile information, photographs, sensitive information, location data, the messages you sent, your credentials, your contact and Ties data, your suppression records, and your Sparks records.

9.3 What deletion does not reach. Some information survives account deletion and it is fair that you know about it. A message you sent to another person remains in that person’s copy of the conversation, in the same way an email you sent stays in the recipient’s inbox. And if you separately joined a waitlist on our website or asked us to stop sending you text messages, those records are kept apart from your app account, are not removed when the account is deleted, and can be removed by writing to admin@joinpaira.com.

9.4 Limited exceptions. After deletion we retain: transaction and financial records, including purchase identifiers, subscription history, and Sparks accrual and redemption records, for up to seven (7) years to meet tax, accounting, and audit requirements, in a form that is not directly linked to your profile; records relating to fraud, abuse, safety, or legal disputes for as long as necessary to investigate or to establish, exercise, or defend a legal claim; aggregated or de-identified information that does not identify you; and copies in database backup archives until they are overwritten in the ordinary course, which for our database backups is within thirty (30) days. Files held in our storage service, including photographs, are not covered by those database backups and are deleted as described above.

10. Security

We maintain administrative, technical, and physical safeguards designed to protect personal information, including encryption of data in transit, access controls that limit administrative access to authorized personnel, logging of administrative access, and periodic review of our security practices. No system is completely secure, and we cannot guarantee the security of information transmitted to us. If a security incident affects your personal information, we will notify you and the appropriate authorities as required by applicable law.

11. Biometric Information

11.1 Current practice. We do not collect, capture, purchase, receive, or store biometric identifiers or biometric information. We do not use facial recognition, face geometry matching, liveness detection, voiceprints, or fingerprint scanning. The automated moderation described in Section 6 classifies image content and does not create or store a template of any person’s facial geometry.

11.2 If we introduce such a feature. If we adopt identity verification, face matching, or liveness detection, whether directly or through a vendor, we will do all of the following before the feature is enabled for any user: publish a written retention and destruction schedule providing for permanent destruction when the initial purpose for collecting the information has been satisfied or within three years of the individual’s last interaction with us, whichever occurs first; give written notice stating that biometric information is being collected and stored, the specific purpose, and the length of time it will be kept and used; obtain a written release from each user separately from these policies and from our Terms of Service; and not sell, lease, trade, or otherwise profit from biometric information. We will not disclose biometric information except with the subject’s consent, as required to complete a transaction the subject authorized, or as required by law or valid legal process.

12. Your Rights and Choices

12.1 Rights. Depending on where you live, you may have the right to know whether we process personal information about you and to access it, to obtain a copy in a portable format, to correct inaccuracies, to delete it, to opt out of targeted advertising, sale, sharing, or certain profiling, to limit our use of sensitive personal information, and not to be discriminated against for exercising any of these rights. These rights are subject to exceptions under applicable law.

12.2 How to exercise them. Use the privacy controls in your account settings, or email admin@joinpaira.com. We will verify your request, usually by confirming control of the email address or phone number associated with your account, and respond within the period applicable law requires. An authorized agent may submit a request on your behalf with proof of authorization.

12.3 Appeals. If we decline a request, you may appeal by emailing admin@joinpaira.com with the subject line "Privacy Appeal." We will respond in writing with our decision and the reasons for it. If your appeal is denied, you may complain to your state attorney general.

12.4 Limiting sensitive information. You may limit our use of sensitive personal information by removing optional fields from your profile or by emailing us. Gender and sexual orientation are necessary to operate matching, and limiting their use will prevent your profile from being shown to other users. We will not otherwise deny you goods or services, charge you a different price, or provide a different level of service because you exercised a privacy right.

12.5 Marketing. You may unsubscribe from marketing email using the link in any marketing message, and stop marketing text messages by replying STOP. You will still receive transactional messages about your account. We do not share mobile information or text message opt-in data with third parties or affiliates for their own marketing purposes. Service providers that help us send messages may process it solely to deliver them.

12.6 Location. You may turn off precise location in your device settings at any time. Features that depend on location will be limited.

12.7 Do Not Track and opt-out preference signals. There is no common industry standard for Do Not Track browser signals, and we do not respond to them. Our commitment on the Global Privacy Control signal is described in Section 8.3.

12.8 California Shine the Light. California residents may request information about personal information we disclosed to third parties for their direct marketing purposes in the preceding calendar year. We do not make disclosures of that kind. Requests may be sent to admin@joinpaira.com.

13. Sparks and Financial Incentives

We give Sparks to users who join our waitlist, refer friends, or take part in loyalty promotions. A program of that kind may be treated as a financial incentive under California law, so we describe it here. The information collected is the contact information you give us to join the waitlist or the referral, and the account identifiers needed to credit Sparks. The value of the incentive is the value of the Partner Offers for which Sparks can be redeemed, which we estimate by reference to the retail value of the offers made available to us by participating venues, and which is reasonably related to the value of the information to us because that information supports our ability to build the network of users the service depends on. Participation is voluntary, you may withdraw at any time by emailing admin@joinpaira.com, and Sparks already credited to your account will not be removed if you withdraw.

14. Children

The service is for adults. We do not knowingly collect personal information from anyone under eighteen, and we do not knowingly sell or share the personal information of anyone under sixteen. If we learn that we have collected information from a person under eighteen, we will close the account and delete the information. If you believe we hold information about a person under eighteen, contact admin@joinpaira.com.

15. Changes and Contact

15.1 Changes. We may update this Policy. If a change is material, we will give notice in the app or by email before it takes effect and, where applicable law requires consent, obtain it. The effective date at the top shows when this version took effect.

15.2 Contact. Questions, requests, and complaints may be sent to admin@joinpaira.com or by mail to:

Paira Technologies, Inc.
4444 2nd Avenue, PMB #3069
Detroit, Michigan 48201
United States
Telephone: 1-844-484-4419