Legal

Privacy Policy

Last update: December 8 2024

Ringle Dating Ltd., an Israeli company, company registration number 516697034

(the “Company” or “we”), based at 4 Abba Even St. Jerusalem respects your right to privacy.

Your ability to make informed decisions about the use of your information is important to us.

The Company serves as the data controller for the database referenced in this privacy policy.

Should you wish to contact us, you may do so through the methods provided in the “Contact

Us” section of the website. The purpose of this privacy policy (the “Privacy Policy”) is to

explain the Company’s procedures in relation to the Personal Information (as defined below)

collected when you use our website, application and Services (as defined below) and how the

Company collects, uses, transfers and secures the Personal Information collected by it. Our website and application (the “Platform”) are designed to help Black individuals seeking meaningful, long-term relationships and marriage. The Platform, together with all related features and offerings, are referred to collectively as the “Services.” In order to connect to the application and use the Services, you will be asked to confirm the Terms of Use (as defined below) and the Privacy Policy. If you do not agree to that, you may not use the Services.

Terms in this document that are not expressly defined will be interpreted in accordance with the definitions given to them in the Terms of Use, published at [Terms of Use] (“Terms of Use”). The terms “you” or “you are” appearing in this document

refer to every user of the Services. For any questions or problems related to the Privacy

Policy, please contact: support@aria.dating

“Personal Information” is information related to a person such as a name, address, phonenumber or email address or as defined by law. You are not under any legal obligation toprovide us with Personal Information; the provision of Personal Information is done withyour consent only. If you do not agree to provide Personal Information, some or all of theServices may not be available to you.Regarding the information collected under this policy, we act as the databaseowner/controllers of the Personal Information.Comment on the requirement for a legal basis for processing the information: Somejurisdictions only allow the processing of personal information when there is a legal basis fordoing so. According to the EU General Data Protection Regulation (“GDPR”), the possiblelegal bases include (but are not limited to) the following: your consent, the processing isnecessary to perform the agreement with you, the processing is necessary to fulfill our legalobligations, or that the Company has a legitimate business interest in processing yourPersonal Information. When we are the controller of the information, we collect and processdata only when there is a legal basis for doing so. Additional details can be found below.

1. Information we collect and legal basis. We collect information if necessary and in accordance with your use of the Services. Therefore, the collection and processing of Personal Information depends on the type of Services you use, as follows:

1.1. Inquiries and/or Contact. When you contact us with a request and/or question, we may record our communication with you and thereby any information you provide us, such as your name, contact details, including phone, e-mail, and the content of the request or question.

1.1.1. We process this information to fulfill the agreement with you.

1.2. Sign up and Login. To access the Services, you must sign up to the Services. If you choose direct sign up, you will be required to provide us with at least your phone number and email address, along with some basic details necessary for our Services to function, such as your gender, date of birth, and the types of connections you are interested in. Alternatively, you may sign up using your account with third-party providers (e.g., Google or Apple). By signing up through a third-party, you consent to their terms of use. In this case, we may receive information about you from the third party, so we recommend reviewing their policies to understand what information will be shared with us. You can also upload information to us, including photos from your camera.

1.2.1. When we process your sign-up information to provide you with our Services, we do so to fulfill our agreement with you, specifically our Terms of Use. When we process your sign-up information to maintain our Services – such as preventing fraud, protecting security and addressing any issues – we do so based on our legitimate interest in safeguarding our assets.

1.3. Materials Uploaded to the Services. You can also share additional information with us, such as biography details and interests, or upload photos or videos. To add certain content, such as photos or videos, we may get access to your camera or photo library.

1.3.1. We process this information to fulfill our agreement with you, specifically our Terms of Use.

1.4. The Content of Chats with Other Users. We have access to and process the content that comes up in chats with other users.

1.4.1. We process this information based on our legitimate interest in safeguarding our assets.

1.5. Participation in Promotions, Events or Contests. We collect the information you used to sign up or enter.

1.6. Payment Services. When purchasing a subscription to a paid service or when making a purchase directly from us (and not through a platform such as iOS or Android), we receive details related to the purchases you made. Additionally, our payment service provider receives details from you such as your credit or debit card number or financial information. Information we receive may include credit card number, validity, full name and identification number of the cardholder, and email address for sending invoices.

1.6.1. We process this information to fulfill our agreement with you, specifically our Terms of Use.

1.7. Information Collected Automatically. Certain information is automatically collected about your device, browser, operating system, IP address, Device ID of the mobile device, app settings and properties, app crashes, advertising identifiers (randomly generated numbers that you can reset by going to your device settings, and in some cases disable completely), and identifiers related to cookies or other technologies that may uniquely identify a device or browser. We also collect information about your use of the Services, for example, login times, features you used, actions you performed, information presented to you, the addresses of the websites that referred you to us and ads you clicked on, as well as your interactions with other members (for example, members with whom you have a relationship, the dates of creating a match and the dates of correspondence between you).

1.7.1. We process this information based on our legitimate interests to develop and improve our products and Services, and to prevent fraud.

1.7.2. We process this information based on your consent.

1.8. Location. Subject to your consent, we will collect information about your location (geographic coordinates) from your device. It is your responsibility to decide whether to display the last location from which you were active, or a residential address, and change the settings accordingly. The collection of your geographic data may occur in the background, even when you are not using the Services, provided that the consent you have given us expressly permits this. If we do not receive permission from you to collect your precise geographic location, we will not collect it, and our Services that rely on precise geographic location may not be available to you.

1.8.1. We process this information based on your consent. You may withdraw your consent by changing your mobile settings.

Information we receive from other users: Other users may provide us with information about you in connection with your use of our Services, for example if they interact with you or if they submit a report related to you.

2. How We Use Information. You agree and confirm that the Company is entitled to retain in its databases the details provided by you, along with any additional Personal Information that may accumulate about you. The Company may use these databases in accordance with legal provisions and the Privacy Policy, including for the purposes detailed below:

2.1. Services and Adaptations. We and/or our service providers may use your Personal Information for the following purposes: (1) providing access to the Services; (2) helping you connect with other users, including recommending you to other users and recommending other users to you, including displaying users’ profiles to each other; (3) providing support and assistance in solving problems that you or other users may encounter; (4) contacting you if necessary; (5) examining questions that arise,

including through the Services, and providing a response accordingly; and (6) preventing fraudulent or illegal activities, safeguarding the security of the Services, and addressing any issues related to their use. If a user submits a report about another user, we will use that information to maintain the safety of the Services and protect the users, at our sole discretion. We may update the complaining user regarding the status of their report, and any action taken.

2.2. Internal Needs. We may use your Personal Information for internal purposes, including diagnosing operational problems, conducting reviews and evaluations for the development of new services and/or content, improving and customizing the Services to meet specific needs (both ours and users’), developing new products, analysing scope of activity, performing financial assessments and forecasts, evaluating potential customer usage, utilizing information for research, development and testing, and adjusting server capacities to accommodate the expected workload.

2.3. Statistics and Analytical Tools. We and/or our service providers use analytical tools, including “Google Analytics” to collect and analyse information about the use of the Services, such as the frequency of visits to the Services by users, the pages visited, and any websites or applications accessed before visiting the Services. By analysing the data we collect, we may compile statistical information across a variety of platforms and users, which helps us improve our Services, understand trends and customer needs, consider new products and services, and adapt existing products and services to customer desires. The information we collect is aggregated and not linked to Personal Information. We may share the aggregate data with our partners, without limitation, on commercial terms determined at our sole discretion. For more details on how Google collects information you can control such use can be found on Googles’ policy page: https://policies.google.com/technologies/partner-sites.

2.4. Advertising. We may use your Personal Information to deliver targeted offers and/or advertisements from third parties based on your personal preferences. If you do not wish to continue receiving these offers, you can change your user settings in the Services and thus stop the use of your Personal Information for the purpose of receiving these offers.

2.5. Access to Information. Currently, Aria employees in the positions of CEO, VP R&D, CTO, as well as employees in support positions, have access to your information. The types of positions may change from time to time.

3. Artificial intelligence. We process certain personal information using artificial intelligence algorithms, specifically Google Vision AI. We use these algorithms to process the images that users like you upload to our Services, to help us ensure that the images meet the Terms of Use of our Services, and to ensure that our Services are safe for other users. For any question or problem related to this you can contact: support@aria.dating .

4. Sharing Your Personal Information. You agree that we will share your Personal Information in accordance with the following:

4.1. Service Providers and Third Parties.

4.1.1. We may share information, including Personal Information, with service providers of the following types: storage and server services, infrastructure, databases and marketing service providers (“Third Party Providers”). These providers may use the information to: (1) help us provide and/or operate the Services; (2) assist us in understanding how the Services are used; and (3) tailor the advertisements shown to you in the application based on your personal preferences across our Services and other websites and/or applications you visit.

4.1.2. Third Party Providers may be located in countries outside the State of Israel. Some of these countries may have different levels of protection for Personal Information or other information than those provided in Israel. You consent to the transfer of your Personal Information to these countries.

4.2. Transfer of Ownership. We may disclose and/or transfer our databases that contain your Personal Information as part of or during negotiations for a merger, sale of Company assets or acquisition (including in cases of liquidation). In such instances, your Personal Information will remain subject to the terms of this Privacy Policy, in accordance with applicable law.

4.3. Complaints and Reports. If someone submits a report related to you (such as an allegation that you violated our Terms of Use), we may forward to the reporter information about actions taken in response to their report, if any. However, we do not undertake to provide any information to a user who has reported another user.

4.4. Advertisers. When you click on an advertisement on our Services or on our advertisement displayed on another website or application, the advertiser will know that someone has clicked on their advertisement, and they may be able to identify you through certain methods, such as cookies. We may share your Personal Information with advertisers in our application: (a) with your consent, (b) when it pertains to encrypted IP addresses and/or device identifiers, or (c) when it pertains to Personal Information that is visible to all users of our Services, such as profile information.

4.5. Transfer of Information Required by Law. We will cooperate with law enforcement authorities or any judicial order that requires or instructs us to disclose the identity, behavior, digital content, or any other Personal Information of any user suspected of actions deemed illegal or in violation of the law. We may also share your Personal Information with third parties if we believe in good faith that the disclosure of the information is appropriate and intended to protect our rights, assets or safety (including the enforcement of the Privacy Policy) or the rights, property or safety of third parties.

4.6. Sharing Additional Information. We will transfer your Personal Information to relevant third parties in the following cases: (1) if the Company discovers that your actions within the Services violate the Terms of Use or were intended to commit fraud

of any kind; or (2) if the Company faces legal action (criminal or civil) as a result of actions you performed using the Services.

4.7. Security. We implement and maintain technical and organizational measures, policies and procedures designed to reduce the risk of accidental destruction or loss, or unauthorized disclosure or access to Personal Information in a manner inappropriate to the nature of that information. The measures we take include:

4.7.1. Protection Measures - The physical, electronic and procedural measures we use to protect your Personal Information include secure servers, firewalls, antivirus, and SSL encryption of the data.

4.7.2. Access Control - We strive to properly manage a dedicated login system and limit access only to authorized staff based on specific needs according to the basic authorization rules. We periodically review permissions and revoke access immediately upon the conclusion of each employee’s employment.

4.7.3. Internal Policy - We maintain and frequently review our privacy and information security policy.

4.7.4. Personnel - We require each new employee to maintain confidentiality in accordance with applicable laws and accepted industry practices.

4.7.5. Encryption - We encrypt data in transit using secure HTTPS protocols.

4.7.6. Database Backup - Our databases are backed up on a periodic basis for certain data and verified regularly. The backups are encrypted and stored in the production environment to maintain their confidentiality and integrity, are regularly tested to ensure availability, and are only accessible by authorized personnel.

4.7.7. However, no method of Internet transfer or electronic storage is completely secure. Therefore, while we strive to employ commercially acceptable measures to protect your Personal Information, we cannot guarantee its absolute security.

4.7.8. Since information security partly depends on the security of the device you use to communicate with us and the measures you take to protect your usernames and passwords, you must take appropriate steps to safeguard this information.

5. International Transfers.

5.1. We hire subcontractors and service providers located in other countries and transfer the information we receive, including Personal Information, to them. We carry out these international transfers to achieve the goals mentioned above. We will ensure that these third parties are bound by written agreements that provide the same level of privacy and data protection as outlined in this Privacy Policy, including

appropriate legal remedies in the event of a breach of your data protection rights in the third country.

5.2. When we transfer the Personal Information of users located in the European Economic Area (“EEA”) to third parties located outside the EEA and where required by applicable law, we will ensure that the information is accorded a similar level of protection by providing one of the following protections:

5.2.1. We will transfer your Personal Information only to countries recognized as providing an appropriate level of protection for Personal Information by the European Commission (adequacy ruling).

5.2.2. When we use certain service providers that are not located in countries with a level of protection that meets the conditions of the European Commission, we may use certain contracts approved by the European Commission which give Personal Information the same protection as it would receive in EEA countries.

5.2.3. Contact us at support@aria.dating if you wish to receive more information about the mechanism we use when we transfer Personal Information outside the EEA.

6. Your Rights - How to access and limit our use of specific Personal Information. Subject to applicable law and certain exemptions, and in some cases depending on the processing activity we perform, you have certain rights in relation to your Personal Information that we or other controllers hold about you, as detailed below. For any request to exercise these rights in relation to information held by other controllers, please contact the relevant controller directly. If you would like us to notify all other controllers, please state this request when you contact us to exercise your rights. We will investigate and attempt to address complaints and disputes and will make every reasonable effort to respect your desire to exercise your rights as quickly as possible and, in any case, within the time frames provided by applicable data protection laws. We reserve the right to request reasonable evidence to verify your identity before we provide you with any information and/or respond to any of your requests, as detailed below:

6.1. Right of Access. You have a right to know what Personal Information we collect about you, and in some cases, even have this information provided to you. Pursuant to Sections 13 and 14 of the Privacy Protection Law, 5571-1981, you are entitled to review your Personal Information either personally, through an authorized representative with written authorization, or via a legal guardian, as applicable. If you request to review this information, we will facilitate access in accordance with the conditions set forth by law and subject to any applicable legal requirements. In cases where the information is held by a third party (the “Holder”), we will direct you to the Holder and instruct the Holder to allow the review. Should you determine after reviewing the information that it is inaccurate, incomplete, unclear, or outdated, you have the right to contact us (or, if you are a foreign resident, the Holder) to request

correction or deletion of the information. Subject to applicable law, we may charge you a fee. Please note that we may not be able to provide you with all the information you request, in which case we will try to explain why.

6.2. Right of Data Portability. If the processing is based on performance of a contract with you and is carried out by automated means, you may be entitled (to ask us) to provide you or another party with a copy of the Personal Information you have provided to us in a structured, commonly used and machine-readable format.

6.3. Right to Correct Personal Information. Subject to applicable law, you may request that we update, complete, correct or delete inaccurate, incomplete or outdated Personal Information. This right exists in accordance with Section 14 of the Privacy Protection Law, 5571-1981.

6.4. Deletion of Personal Data (“Right to Be Forgotten”). If you are a resident of the European Union, you have the right to request the deletion of your Personal Information under the following circumstances: (i) it is no longer necessary for the purpose for which it was collected, (ii) you have successfully exercised your right to object (see below), (iii) the processing was unlawful, or (iv) we are required to delete it to comply with a legal obligation. We will not be able to recover information after it has been deleted. Please note that to ensure that we do not collect additional Personal Information, you must clear your cookies from any device where you used our Services. We may retain certain Personal Information (including after your request for deletion) for auditing and record-keeping purposes or as otherwise permitted and/or required by applicable law.

6.5. Right to Restrict Processing. If you are a resident of the European Union, you may request that we restrict the processing of your Personal Information under any of the following conditions: (i) you have contested the accuracy of the information and requested a restriction until it has been verified; (ii) the processing is unlawful, but you do not wish us to delete the Personal Information; (iii) it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise or defend a legal claim; (iv) you have exercised your right to object (below), and we are in the process of verifying our permitted grounds for processing. We may continue to use your Personal Information after a restriction request under certain circumstances.

6.6. Right to Object. If you are a resident of the European Union, you can object to any processing of your Personal Information for which our legitimate interests are the legal basis, if you believe that your fundamental rights and freedoms outweigh those interests. If you raise an objection, we will have the opportunity to demonstrate that we have compelling legitimate interests that override your rights and freedoms.

6.7. Right to Lodge a Complaint with Your Local Supervisory Authority. If you are a resident of the European Union, you may have the right to lodge a complaint with the relevant supervisory authority for the protection of Personal Information if you have

concerns about how we process your Personal Information. However, we kindly ask that you first attempt to resolve these concerns with us directly.

7. Data Retention.

7.1. Subject to applicable law, we retain Personal Information as necessary and for the purposes listed above. We may delete information from our systems without prior notice when we believe that information is no longer needed for these purposes. Data retention by each of our processors may vary based on the processor’s specific retention policy.

7.2. In certain circumstances, we may retain your Personal Information extended periods, such as when required by law, regulations, tax, audit, or accounting rules and in order to maintain an accurate record of your transactions in the event of a complaint or if we believe litigation regarding your Personal Information or transactions is likely. To determine the appropriate retention period, we take into account the amount, nature and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your information, the purposes for which we process it, and whether these purposes can be achieved by other means, alongside legal requirements.

7.3. Please contact us at support@aria.dating if you would like to receive details regarding the data retention periods for the various types of Personal Information.

8. Cookies

8.1. Cookies are short text files that are sent to or accessed from your device via your browser or your device’s memory. There are several types of similar technologies, such as web beacons, pixel tags, device IDs, and we will include them all in the definition of “cookies”.

8.2. There are first-party and third-party cookies. First-party cookies are placed directly on your device by us. For example, we use first-party cookies to adapt our Services to your browser’s language preferences and to better understand how you use our Services. Third-party cookies are placed on your device by our partners and service providers. You can learn more about these partners and service providers through our Services and the consent management tools within the app.

8.3. We use cookies to provide, secure and improve our Services, including by remembering your preferences, identifying you when you visit our Services, measuring the success of our marketing campaigns and personalizing advertisements to match your interests. To achieve these goals, we may also link information from cookies with other Personal Information we have about you.

8.4. Third parties we work with, such as service providers or business partners, may set cookies in your browser to collect information in connection with advertisements displayed on third-party websites. Third parties that are advertising companies may

participate in self-regulatory programs that allow you to opt out of interest-based ads associated with them. Opting out does not mean you will stop seeing ads, but you will no longer see personalized ads from companies participating in these opt-out programs. In addition, if you delete cookies from your device after opting out, you will need to opt out again. For more information, you can visit the applications/websites of the following: Digital Advertising Alliance; Interactive Digital Advertising Alliance; Appchoices; (apps only).

8.5. There are several options for managing cookies. Please note that changes made by you to your cookie preferences may make your experience less satisfactory because they will make it less personalized. In some cases, it may even be impossible to use some or all of our Services.

` 8.5.1. Browser and device management. Some web browsers provide settings that allow you to control cookies, reject them or receive a notification when a cookie is placed on your device/browser. The procedure for managing cookie files varies slightly between web browsers and/or devices. You can check the specific steps in the help menu of the browser and/or device used.

8.5.2. It may be possible to reset device identifiers or opt out of the collection or processing of identifiers by using the appropriate setting on your mobile device. The procedures for managing identifiers vary slightly from device to device. You can check the specific steps in your device’s help or settings menu. The cookies we use may change from time to time. In any case, the types of cookies we will use usually fall into one of the following types:

Essential - These cookies are essential for the proper operation of the Services. They allow you to access the Services, navigate within the Services, and use various features, such as enabling you to log in to an account.

Operational - These remember your preferences between visits.

Safety - These help us identify you and prevent other users from changing your username and password and other safety actions of this type.

Analytical - These cookies help us understand how all users use our services. This information helps us improve the Services, such as which pages or features are popular, and which are less so.

Advertising - These cookies are intended to provide you with advertisements that may be relevant to you. This helps advertisers show you targeted ads or ads you haven’t already seen. They help make sure ads are showing correctly for advertisers, choose ads that are relevant to you, and measure the number of ads shown and their performance, for example how many people clicked on a given ad.

In addition, we may use cookies from social networks or third parties for advertising purposes.

If you have any questions regarding our cookie policy, you can contact us at

9. Third Party Services. Some of our Services include the use of third-party services and

applications. Any use of these services is at your own risk and subject to the terms of use and

privacy policy related to that service.

10. Children. To register, you must be eighteen (18) years of age or older. The Company

does not knowingly collect Personal Information on children under the age of eighteen (18).

If you become aware that an individual under the age of eighteen (18) is using the Services,

or a case where Personal Information of a minor has been uploaded as content to the

Services, we ask that you notify us as soon as possible.

11. Communications and Notices. We reserve the right to send you Service-related notices

via email, including service notices and administrative notices relating to your account

without offering you the option to opt-out unless you close your account.

12. Changes to the Privacy Policy. Our Privacy Policy may change from time to time. If

substantial changes are made to the Privacy Policy, a notice will be posted on this page.