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Effective Date: The earlier of 2024-12-23 or user acknowledgment.Below we provide specific information about our privacy practices for certain U.S. residents and describe the specific rights afforded to them in accordance with applicable U.S. privacy laws. Where available, we provide links to sections within our Privacy Policy where these rights and additional information may already be described such as the section: “<a href="https://www.grindr.com/privacy-policy/en-us" >Your Choices and Rights</a >”.If you are a Washington State or Nevada consumer, you may also view our Consumer Health Data Privacy Policy <a href="https://www.grindr.com/privacy-policy/consumer-health-data-privacy-policy" >here</a >.<h3>Personal Information Collected, Sold, Shared, or Disclosed and Sources</h3>For ease of reference, the table below describes the categories of personal information we collect and share, and have collected and shared in the preceding 12 months, for business purposes:<table><thead><tr><td colspan="1" rowspan="1">Category of Personal Information Collected</td><td colspan="1" rowspan="1">Source</td><td colspan="1" rowspan="1">Disclosed for Business Purpose, or Sold/Shared With</td><td colspan="1" rowspan="1">Purposes for Collecting, Selling, or Sharing Personal Information</td><tbody></tbody></tr><tr><td colspan="1" rowspan="1">A. Identifiers and contact information, such as email, phone number, online identifiers (e.g., IDFA, GAID, IDFV) and IP address</td><td colspan="1" rowspan="1"><ul><li>You</li><li>Your Device</li><li>Service Providers</li></ul></td><td colspan="1" rowspan="1"><ul><li>Disclosed<ul><li>Service Providers</li><li>Other Partners</li></ul></li></ul><ul><li>Sold/Shared<ul><li>Ad / Marketing Partners (only IP Address and certain online identifiers, e.g., IDFA)</li></ul></li></ul></td><td colspan="1" rowspan="1">1. Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance;2. Helping to ensure security and integrity to the extent the use of the consumer's personal information is reasonably necessary and proportionate;3. Debugging to identify and repair errors that impair existing intended functionality;4. Short-term, transient use, including but not limited to non-personalized advertising shown as part of a consumer's current interaction with the business, provided that the consumer's personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer's experience outside the current interaction with the business;5. Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business;6. Providing advertising and marketing services, except for cross-context behavioral advertising, to the consumer, provided that for the purpose of advertising and marketing, a service provider or contractor shall not combine the personal information of opted-out consumers which the service provider or contractor receives from or on behalf of the business with personal information which the service provider or contractor receives from or on behalf of another person or persons, or collects from its own interaction with consumers;7. Undertaking internal research for technological development and demonstration; and8. Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business</td></tr><tr><td colspan="1" rowspan="1">B. Customer records (including as defined in California Civil Code § 1798.80), such as contact details and communications we collect through our support channels and marketing activities, health-related profile fields (e.g., HIV status, Last Tested Date, and poz), vaccination information (e.g., vaccination status) and Consumer Health Data (as defined in General Statutes of Connecticut § 42-515)</td><td colspan="1" rowspan="1"><ul><li>You</li><li>Your Device</li></ul></td><td colspan="1" rowspan="1"><ul><li>Disclosed<ul><li>Service Providers</li><li>Other Partners</li></ul></li></ul></td><td colspan="1" rowspan="1">1. Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance;2. Debugging to identify and repair errors that impair existing intended functionality;3. Short-term, transient use, including but not limited to non-personalized advertising shown as part of a consumer's current interaction with the business, provided that the consumer's personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer's experience outside the current interaction with the business;4. Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business;5. Providing advertising and marketing services, except for cross-context behavioral advertising, to the consumer, provided that for the purpose of advertising and marketing, a service provider or contractor shall not combine the personal information of opted-out consumers which the service provider or contractor receives from or on behalf of the business with personal information which the service provider or contractor receives from or on behalf of another person or persons, or collects from its own interaction with consumers;6. Undertaking internal research for technological development and demonstration; and7. Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business</td></tr><tr><td colspan="1" rowspan="1">C. Characteristics of protected classifications under state or federal law (if you choose to provide them), such as age, gender identity, marital status, sexual orientation, race, and medical information (i.e., HIV status, and Last Tested Date, and vaccination status)</td><td colspan="1" rowspan="1"><ul><li>You</li></ul></td><td colspan="1" rowspan="1"><ul><li>Disclosed<ul><li>Service Providers</li></ul></li></ul></td><td colspan="1" rowspan="1">1. Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance;2. Helping to ensure security and integrity to the extent the use of the consumer's personal information is reasonably necessary and proportionate;3. Debugging to identify and repair errors that impair existing intended functionality;4. Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business;5. Undertaking internal research for technological development and demonstration; and6. Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business</td></tr><tr><td colspan="1" rowspan="1">D. Commercial information, such as information related to payment for services and features you purchase through the Grindr Properties</td><td colspan="1" rowspan="1"><ul><li>You</li><li>Your Device</li><li>Service Providers</li></ul></td><td colspan="1" rowspan="1"><ul><li>Disclosed<ul><li>Service Providers</li></ul></li></ul></td><td colspan="1" rowspan="1">1. Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance;2. Debugging to identify and repair errors that impair existing intended functionality;3. Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business; and4. Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business</td></tr><tr><td colspan="1" rowspan="1">E. Biometric information</td><td colspan="1" rowspan="1">N/A - Grindr does not collect this information from individuals covered by this policy</td><td colspan="1" rowspan="1">N/A - Grindr does not collect this information from individuals covered by this policy</td><td colspan="1" rowspan="1">N/A - Grindr does not collect this information from individuals covered by this policy</td></tr><tr><td colspan="1" rowspan="1">F. Internet and other electronic network activity information, such as information generated from interactions with the Grindr Properties (e.g., data collected through server logs and cookies and similar technologies)</td><td colspan="1" rowspan="1"><ul><li>You</li><li>Your Device</li></ul></td><td colspan="1" rowspan="1"><ul><li>Disclosed<ul><li>Service Providers</li></ul></li></ul></td><td colspan="1" rowspan="1">1. Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance;2. Helping to ensure security and integrity to the extent the use of the consumer's personal information is reasonably necessary and proportionate;3. Debugging to identify and repair errors that impair existing intended functionality;4. Short-term, transient use, including but not limited to non-personalized advertising shown as part of a consumer's current interaction with the business, provided that the consumer's personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer's experience outside the current interaction with the business;5. Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business;6. Providing advertising and marketing services, except for cross-context behavioral advertising, to the consumer, provided that for the purpose of advertising and marketing, a service provider or contractor shall not combine the personal information of opted-out consumers which the service provider or contractor receives from or on behalf of the business with personal information which the service provider or contractor receives from or on behalf of another person or persons, or collects from its own interaction with consumers; and7. Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business</td></tr><tr><td colspan="1" rowspan="1">G. Geolocation data, such as Distance Information and precise location</td><td colspan="1" rowspan="1"><ul><li>You</li><li>Your Device</li></ul></td><td colspan="1" rowspan="1"><ul><li>Disclosed<ul><li>Service Providers</li></ul></li></ul></td><td colspan="1" rowspan="1">1. Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance;2. Helping to ensure security and integrity to the extent the use of the consumer's personal information is reasonably necessary and proportionate;3. Debugging to identify and repair errors that impair existing intended functionality;4. Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business; and5. Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business</td></tr><tr><td colspan="1" rowspan="1">H. Audio, electronic, visual or similar information, such as photos, audio, and videos</td><td colspan="1" rowspan="1"><ul><li>You</li></ul></td><td colspan="1" rowspan="1"><ul><li>Disclosed<ul><li>Service Providers</li></ul></li></ul></td><td colspan="1" rowspan="1">1. Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance;2. Helping to ensure security and integrity to the extent the use of the consumer's personal information is reasonably necessary and proportionate;3. Debugging to identify and repair errors that impair existing intended functionality;4. Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business;5. Undertaking internal research for technological development and demonstration; and6. Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business</td></tr><tr><td colspan="1" rowspan="1">I. Professional or employment-related information</td><td colspan="1" rowspan="1">N/A to individuals covered by this policy; see the <a href="https://www.grindr.com/privacy-policy/applicant-privacy-policy/" >Grindr Employee, Contractor, Vendor, and Applicant Privacy Policy</a ></td><td colspan="1" rowspan="1">N/A to individuals covered by this policy; see the <a href="https://www.grindr.com/privacy-policy/applicant-privacy-policy/" >Grindr Employee, Contractor, Vendor, and Applicant Privacy Policy</a ></td><td colspan="1" rowspan="1">N/A to individuals covered by this policy; see the <a href="https://www.grindr.com/privacy-policy/applicant-privacy-policy/" >Grindr Employee, Contractor, Vendor, and Applicant Privacy Policy</a ></td></tr><tr><td colspan="1" rowspan="1">J. Education information as defined in the Family Educational Rights and Privacy Act</td><td colspan="1" rowspan="1">N/A to individuals covered by this policy; see the <a href="https://www.grindr.com/privacy-policy/applicant-privacy-policy/" >Grindr Employee, Contractor, Vendor, and Applicant Privacy Policy</a ></td><td colspan="1" rowspan="1">N/A to individuals covered by this policy; see the <a href="https://www.grindr.com/privacy-policy/applicant-privacy-policy/" >Grindr Employee, Contractor, Vendor, and Applicant Privacy Policy</a ></td><td colspan="1" rowspan="1">N/A to individuals covered by this policy; see the <a href="https://www.grindr.com/privacy-policy/applicant-privacy-policy/" >Grindr Employee, Contractor, Vendor, and Applicant Privacy Policy</a ></td></tr><tr><td colspan="1" rowspan="1">K. Inferences that we derive from the preceding information collected</td><td colspan="1" rowspan="1"><ul><li>Grindr</li></ul></td><td colspan="1" rowspan="1"><ul><li>Disclosed<ul><li>Service Providers</li></ul></li></ul></td><td colspan="1" rowspan="1">1. Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance;2. Helping to ensure security and integrity to the extent the use of the consumer's personal information is reasonably necessary and proportionate;3. Debugging to identify and repair errors that impair existing intended functionality;4. Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business; and5. Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business</td></tr><tr><td colspan="1" rowspan="1">L. Sensitive personal information, including certain identifiers listed in the preceding categories B, C and G, account log-in credentials, and the contents of communications where Grindr is not an intended recipientSee note on sensitive personal information below.</td><td colspan="1" rowspan="1"><ul><li>You</li><li>Your Device</li></ul></td><td colspan="1" rowspan="1"><ul><li>Disclosed<ul><li>Service Providers</li><li>Other Partners</li></ul></li></ul></td><td colspan="1" rowspan="1">1. Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance;2. Debugging to identify and repair errors that impair existing intended functionality;3. Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business; and4. Undertaking internal research for technological development and demonstration</td></tr></thead></table>Note on sensitive Personal Information. We limit our use and/or disclosure of sensitive personal information to the purposes necessary to provide the Grindr Services. See <a href="https://www.grindr.com/privacy-policy/personal-information-collected-and-data-retention/en-us" >Personal Information We Collect and Data Retention</a > and <a href="https://www.grindr.com/privacy-policy/legal-bases/en-us" >Legal Bases</a > for more information. You can limit the use of sensitive Personal Information by (1) opting to not include such information in your Profile (e.g., ethnicity, position, etc.) or chat messages and/or (2) by opting to not allow Grindr to use your “sensitive” Personal Information for AI model training. Data Retention. We retain your Personal Information for no longer than is necessary to fulfill the purposes for which the information was collected or as otherwise permitted or required by applicable law or pursuant to Grindr <a href="https://www.grindr.com/terms-of-service/" >Terms and Conditions of Service</a > and/or <a href="https://www.grindr.com/community-guidelines/" >Grindr Community Guidelines</a >. See <a href="https://www.grindr.com/privacy-policy/personal-information-collected-and-data-retention/en-us" >Personal Information We Collect and Data Retention</a > for more information.Your Additional Rights as a California Resident.<ol start="1"><li>You can request the following information about how we have collected and used your Personal Information during the past 12 months:<ol><li>The categories of Personal Information we have collected (see <a href="https://www.grindr.com/privacy-policy/personal-information-collected-and-data-retention/en-us" >Personal Information We Collect and Data Retention</a > and <a href="https://www.grindr.com/privacy-policy/legal-bases/en-us" >Legal Bases</a >). Specifically, we collected the following categories of Personal Information, or disclosed such data for a business purpose (see <a href="https://www.grindr.com/privacy-policy/how-we-may-share/en-us" >How We Share Personal Information</a >), in the past 12 months</li><li>The categories of sources from which we collected the Personal Information (see <a href="https://www.grindr.com/privacy-policy/legal-bases/en-us" >Legal Bases</a >)</li><li>The business or commercial purpose for collecting and/or selling (or sharing for cross-contextual behavioral advertising) Personal Information (see <a href="https://www.grindr.com/privacy-policy/legal-bases/en-us" >Legal Bases</a >)</li><li>The categories of third parties with whom we share the Personal Information (see <a href="https://www.grindr.com/privacy-policy/how-we-may-share/en-us" >How We Share Your Personal Information</a >)</li><li>The categories of Personal Information that we sold or shared for cross-contextual behavioral advertising (i.e., Ad / Marketing Partners) or disclosed for a business purpose (e.g., Service Providers and Other Partners) (see <a href="https://www.grindr.com/privacy-policy/legal-bases/en-us" >Legal Bases</a >)</li><li>The categories of third parties to whom the Personal Information was sold or shared for cross-contextual behavioral advertising, or disclosed for a business purpose (see <a href="https://www.grindr.com/privacy-policy/how-we-may-share/en-us" >How We Share Your Personal Information</a >)</li></ol></li><li>You can request a copy of the Personal Information that we have collected about you during the past 12 months (see <a href="https://www.grindr.com/privacy-policy/?lang%3Den-US%23:~:text%3DYOUR%2520CHOICES%2520AND%2520RIGHTS" >Your Choices and Rights</a >).</li><li>You can ask us to delete the Personal Information that we have collected from you (see <a href="https://www.grindr.com/privacy-policy/?lang%3Den-US%23:~:text%3DYOUR%2520CHOICES%2520AND%2520RIGHTS" >Your Choices and Rights</a >).</li><li>You can correct inaccurate Personal Information (see <a href="https://www.grindr.com/privacy-policy/?lang%3Den-US%23:~:text%3DYOUR%2520CHOICES%2520AND%2520RIGHTS" >Your Choices and Rights</a >). You can review and change your Profile Information at any time by accessing the "Edit Profile" section of the Services.</li><li>You can easily opt-out of selling or sharing your Personal Information for cross-contextual behavioral advertising purposes with our Ad / Marketing Partners (see <a href="https://www.grindr.com/privacy-policy/?lang%3Den-US%23:~:text%3DYOUR%2520CHOICES%2520AND%2520RIGHTS" >Your Choices and Rights</a > - you can also click <a href="https://help.grindr.com/hc/en-us/requests/new?ticket_form_id%3D360006692913%26tf_360056453953%3Dform__privacy_request__do_not_sell" >here</a > to submit an opt-out request).</li></ol>Your Additional Rights as a Colorado Resident. In addition to the choices and rights outlined <a href="https://www.grindr.com/privacy-policy/en-us">here</a>, Grindr will attempt to recognize Universal Opt-Out Mechanisms (“UOOM”) so you can easily opt-out of selling or sharing your Personal Information for targeted advertising purposes with our Ad / Marketing Partners. The <a href="https://coag.gov/uoom/">Colorado Attorney General</a> recognizes the Global Privacy Control as a UOOM. Please see the “Opt-Out Preference Signals” section described below as UOOM are synonymous with Opt-Out Preference Signals and will behave in the same manner. In order to utilize certain AI-supported features within the Grindr App, Grindr may make inferences based upon <a href="https://www.grindr.com/privacy-policy" >“sensitive” Personal Information</a > you have chosen to make available within the Grindr Services. You provide consent for Grindr to process such information for  inferences when you either (1) choose to make such optional, “sensitive” Personal Information available within the App and (2) if you elect to allow Grindr to use “sensitive” Personal Information for AI model training and development. Grindr does not share inferences based on “sensitive” Personal Information with advertising partners. For residents of Virginia, Utah, Connecticut, Texas, Oregon, New Hampshire, Delaware, Montana, Iowa, and New Jersey please refer to the “<a href="https://www.grindr.com/privacy-policy/en-us" >Your Choices and Rights</a >” section of this Privacy Policy for your privacy rights. <h3></h3><h3>Exercising Your Rights</h3>Authorized Agents. Grindr will accept requests from authorized agents on behalf of individuals who reside in a state that allows requests through an authorized agent. If you are an authorized agent for an individual who resides in a state that allows requests through an authorized agent, please click <a href="https://help.grindr.com/hc/en-us/requests/new?ticket_form_id%3D360006692913%26tf_360050725894%3Dyes-ca-agent" >here</a > to submit a request and attach a signed designation form from the individual that you represent authorizing you to serve as the individual's agent for the purposes of exercising the individual's rights under the applicable privacy law. Individuals can optionally notarize the document or provide a Power of Attorney document along with the signed designation form. If you do not provide the signed designation form, we cannot honor any requests you submit on behalf of the individual.Appeals. Depending on the state in which you reside, you may be able to appeal a decision made regarding your privacy request by submitting a request <a href="https://help.grindr.com/hc/en-us/requests/new?ticket_form_id%3D360006692913%26tf_360056453953%3Dform__privacy_request__privacy_appeal" >here</a >. In the event we deny your appeal, you will provide a written explanation of the decision, and instructions on how to contact your local Attorney General, or relevant authority, for further review where permitted under certain U.S. state privacy laws.Opt-Out Preference Signals. Grindr will attempt to recognize and process opt-out preference signals in a seamless manner. In addition to opting out of the sale (or sharing for cross-contextual behavioral advertising) of your Personal Information via settings in the Grindr Services or submitting a request <a href="https://help.grindr.com/hc/en-us/requests/new?ticket_form_id%3D360006692913%26tf_360056453953%3Dform__privacy_request__do_not_sell" >here</a >, you can also opt-out by broadcasting an opt-out preference signal ("Signal"), such as the Global Privacy Control ("GPC") on a browser and/or a browser extension that support such a Signal. The ability to process your Signals may depend on the Grindr Properties that you are browsing:<ol start="1"><li>If you are browsing Grindr Web (either on a mobile or web browser), your request to opt-out of sale via the Signal will be processed and linked to your account (i.e., the opt out will be in effect when you log in to the Grindr App).</li><li>If you are browsing a non-Grindr Services web domain (e.g., Grindr Site) or if you are not logged into your Grindr account (e.g., Grindr Web's landing page), your request to opt-out of sale via the Signal will be processed and linked to your browser identifier only (and not linked to your Grindr account because the connection between your browser and the account is not known to us).</li><li>If you are browsing the Grindr App, your request to opt-out of sale via the Signal will not be processed as Signals are currently only supported by browser experiences.</li></ol>Do Not Track. Some web browser settings may allow you to automatically transmit a "Do Not Track" signal to online services you visit. Note, however, there is no consensus as to what "Do Not Track" means in this context. Like many online services, Grindr currently does not recognize automated browser signals regarding tracking mechanisms, which may include "Do Not Track" instructions. To find out more about "Do Not Track," you can visit <a href="https://www.allaboutdnt.com/" >https://www.allaboutdnt.com </a >.<h3>How To Contact Us</h3>You can visit our <a href="https://help.grindr.com/hc/en-us/sections/4402729693971-Privacy" >Privacy Help Center</a > to learn more about our features that support your privacy and choices. Statistics pertaining to Grindr's processing of access, erasure and opt-out requests can be found <a href="https://www.grindr.com/privacy-policy/privacy-rights-requests/" >here</a >.If you would like to request a copy of information regarding our disclosure to third parties for their direct marketing purposes in the preceding calendar year, or if you have questions about your California privacy rights, please contact us by email at <a href="mailto:[email protected]">[email protected]</a> or by postal mail at: Grindr LLC, Attn: Privacy Office, PO Box 69176, West Hollywood, CA 90069.<h3>Policy Changes</h3>The latest version of the policy available at <a href="https://www.grindr.com/privacy-policy/" >https://www.grindr.com/privacy-policy/</a > will govern our use of your Personal Information. Grindr may revise this policy from time to time. If Grindr determines, in its sole discretion, that the changes we make to this policy are material, we will notify you in advance (e.g., within the Services).

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