INTRODUCTION

Gayby LLC (“Gayby,” “we,” “our,” or “us”) is committed to protecting your privacy and safety. This Privacy and Safety Policy outlines how we collect, use, share, and protect your information when you use our mobile application, website, and related services (collectively, the “Service”), and offers key safety guidance for interacting on our platform.

By accessing or using the Service, you confirm that you have read, understood, and agree to the terms of this Policy. If you disagree with any part of this Policy, please discontinue use of the Service.

SUMMARY OF KEY POINTS

• We collect sensitive data—including reproductive and family planning details—to deliver core features of our platform.
• Third-party services (e.g., Clevertap) assist in data analysis and performance monitoring.
• Data is used for matching, personalization, analytics, safety, and marketing.
• California residents have enhanced privacy rights under state law.
• Users can manage or delete their data through in-app settings or by contacting us.
• We provide safety guidelines for communicating and meeting with potential matches.

INFORMATION WE COLLECT

Personal Information

We may collect information that identifies or relates to you, including:

• Identifiers: Name, email address, phone number, IP address, device ID
• Demographic Information: Age, gender, location
• Profile Data: Photos, bios, preferences related to surrogacy, donation, co-parenting
• Reproductive Health Info: Fertility status, reproductive goals, timeline, medical history related to family planning
• User Communications: Messages exchanged with other users or Gayby
• Usage Information: Feature usage, time spent, interactions
• Device Details: Type, OS, browser, screen size, and settings

How We Collect Data

• Directly: When you register, complete your profile, or communicate within the app
• Automatically: Through cookies, APIs, SDKs, and analytics tools
• From Third Parties: Via service providers we work with to maintain and improve our platform

THIRD-PARTY DATA PROCESSING

Clevertap

We use Clevertap to:

• Track in-app activity
• Understand user behavior and trends
• Enhance matching algorithms
• Customize communications and marketing

Segment collects:

• User IDs, IP addresses, and device details
• In-app usage and feature engagement
• Profile metadata (including reproductive data)
• Communication timestamps (not message content)

For more on their practices, visit: https://segment.com/legal/privacy

Other Partners

We also work with:

• Analytics Tools: Google Analytics, Firebase
• Cloud Providers: Google Cloud Platform
• Messaging Systems: Twilio, Sendgrid
• Marketing Platforms: Meta Ads, Google Ads, Apple Search Ads, YouTube

All partners receive only the data necessary to fulfill their function and are contractually obligated to respect user privacy.

HOW WE USE YOUR INFORMATION

We use your data to:

Provide and Improve the Service

• Create and maintain user accounts
• Match users based on compatibility
• Respond to inquiries
• Develop and refine features

Personalize Your Experience

• Tailor suggestions and content
• Save your preferences and activity

Communicate With You

• Deliver service-related alerts
• Send updates and marketing content (with your consent)

Analyze and Research

• Generate insights to improve performance
• Test new functionality
• Build anonymized reports

Ensure Safety and Integrity

• Detect fraud and abuse
• Debug errors
• Enforce platform rules
• Protect users’ safety and rights

LEGAL BASIS FOR PROCESSING (EEA ONLY)

For users in the European Economic Area (EEA), we rely on the following legal bases to process your data:

• Consent
• Contractual necessity
• Legitimate interests (e.g., fraud prevention, platform improvement)
• Legal compliance

HOW WE SHARE YOUR INFORMATION

We may share information with:

• Other Users: Through your profile or direct communication
• Service Providers: Who help operate our platform
• During Business Changes: In a merger, acquisition, or asset transfer
• When Legally Required: In response to subpoenas or law enforcement
• For Protection: To prevent fraud or ensure user safety

We do not sell your data for monetary compensation.

DATA RETENTION

We keep your information only as long as necessary to fulfill the purposes described in this Policy or as required by law. When no longer needed, we securely delete or anonymize your data.

YOUR RIGHTS & CHOICES

All Users May:

• Access and update personal data via account settings
• Opt out of marketing communications
• Request deletion of their account and associated data

California Residents (under CCPA, CMIA, CIPA) May:

• Request a copy of the personal information we hold
• Request deletion of that data
• Opt out of data sharing practices
• Not face discrimination for exercising these rights

To exercise your rights, contact us at: hello@gayby.com

MEDICAL INFORMATION RIGHTS (CMIA)

If we collect reproductive health-related information considered “medical information” under California law, you have rights including:

• Authorization: No unauthorized disclosures
• Access: Right to view the medical information held
• Confidentiality: Information stored securely
• Damages: You may pursue claims if confidentiality is violated

Contact: hello@gayby.com to exercise these rights.

DATA SECURITY

We use industry-standard administrative, technical, and physical safeguards to secure your data. Despite our efforts, no digital system is completely secure—please use discretion when sharing personal information.

INTERNATIONAL USERS

If you reside outside the U.S., please note your data may be processed in the United States or other countries where data protection laws may differ. We implement suitable safeguards for international transfers when required.

CHILDREN’S PRIVACY

The Gayby platform is not intended for users under 18. We do not knowingly collect data from minors. If we become aware that data has been collected from a child under 18, we will delete it promptly.

CHANGES TO THIS POLICY

We may revise this Privacy and Safety Policy occasionally. Updates will be posted with a new “Last Updated” date. We encourage users to review this Policy regularly.

CALIFORNIA-SPECIFIC DISCLOSURES

CIPA Notice

We use services like Twilio Segment that process communication data to support our platform. You consent to this collection by using our Service.

CMIA Notice

We treat reproductive health data as “medical information” where required under California law, with applicable confidentiality protections.

Marketing Disclosure

California users may request a list of personal data shared with third parties for direct marketing by contacting: hello@gayby.com

SAFETY GUIDELINES

We care deeply about your physical and emotional safety. Follow these recommendations when engaging with others:

Before Meeting

• Communicate extensively via the app
• Always schedule a video chat first
• Research the person if possible
• Be clear about your intentions
• Trust your gut—walk away if something feels off

When Meeting in Person

• Choose public spaces
• Tell someone about your meeting plans
• Use your own transportation
• Avoid alcohol or substances
• Keep your home and work address private

Red Flags

• Inconsistent backstories
• Rush to meet in person
• Requests for money
• Push to move communication off-platform
• Avoidance of video calls

Reporting Concerns

Use our in-app reporting tool to alert us to harassment, scams, or inappropriate behavior. We take all reports seriously and investigate promptly.

DATA DELETION REQUESTS

You may request deletion of your account and associated data via the app’s settings page. This action is permanent and cannot be undone. Pending matches, conversations, or requests will be canceled.

CONTACT US

Gayby LLC
1027 N Genesee Ave #6
West Hollywood, CA 90046
📧 hello@gayby.com

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