Privacy Policy

This Privacy Policy explains how The Great Connection LLC ("Company", "We", "Us", "Our") collects, uses, discloses, and protects Your information when You use the Happn'IN Live mobile application (Android package com.seewhatshappnin.app) and related services (together, the "Service"), and describes Your privacy rights and how the law protects You.

Who We Are (Data Controller)

The Great Connection LLC is the controller (and, under U.S. state privacy laws, the "business") responsible for Your Personal Data.

• Entity: The Great Connection LLC
• Postal address: 711 W Lake St, Minneapolis, MN 55408, United States
• Privacy contact: privacy@seewhatshappnin.com
• General contact: support@seewhatshappnin.com

We have not appointed a Data Protection Officer, as We are not required to do so under Article 37 GDPR. Privacy enquiries should be sent to the privacy contact above.

EEA/UK users: The Service is directed to users in the United States. We do not currently offer the Service to individuals in the European Economic Area or the United Kingdom and have not appointed an Article 27 representative. Where a user in those regions nonetheless uses the Service, We apply the GDPR/UK GDPR protections described in this Policy.

Interpretation and Definitions

Interpretation

Words whose initial letters are capitalized have the meanings defined below. The definitions apply equally in the singular and the plural.

Definitions

• Account means a unique account created for You to access the Service or parts of it.

• Affiliate means an entity that controls, is controlled by, or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest, or other securities entitled to vote for election of directors or other managing authority.

• Application refers to Happn'IN Live, the software program provided by the Company.

• Business Account / Host means an Account used to create a business profile, broadcast live streams, publish clips, or list events on the Service.

• Country/State refers to Minnesota, United States.

• Device means any device that can access the Service, such as a computer, cell phone, or tablet.

• Personal Data (or "Personal Information") means any information that relates to an identified or identifiable individual. We use "Personal Data" and "Personal Information" interchangeably unless a specific law uses a defined term.

• Processor / Service Provider means any natural or legal person that processes Personal Data on behalf of the Company, including third-party companies engaged to facilitate or provide the Service, to perform Service-related functions, or to help Us analyze how the Service is used.

• Sensitive Personal Information has the meaning given under the California Consumer Privacy Act, as amended by the CPRA, and includes precise geolocation and Account log-in credentials.

• Service refers to the Application and any related websites and back-end services operated by the Company.

• Stream Content means live video and audio broadcasts, recorded clips, thumbnails, cover images, captions, hashtags, and comments You create, upload, or transmit through the Service.

• Usage Data refers to data collected automatically, generated either by use of the Service or by the Service infrastructure itself.

• User means any individual who accesses or uses the Service.

• You means the individual accessing or using the Service, or the company or other legal entity on whose behalf such individual accesses or uses the Service.

Collecting and Using Your Personal Information

Types of Data Collected

Personal Data You Provide

When You register for and use the Service, We may ask You to provide:

• Identity and contact data: first and last name, display name, username, email address, and email verification status.
• Date of birth, which We use to confirm that You meet the minimum age for the Service and to apply age-appropriate restrictions to age-restricted (18+) event listings.
• Account credentials: Your password, which We store only in salted, hashed form, and authentication and refresh tokens issued to Your Device.
• Third-party sign-in identifiers: where You choose to sign in with Google or Apple, the identity token supplied by that provider and the basic profile fields it returns (name, email address, and a stable user identifier).
• Profile content: biography, tagline, profile photo, cover image, and social media links.
• Address data: street address, city, state/province, ZIP/postal code, and country.

Additional Data Collected From Business Accounts (Hosts)

If You create a Business Account, We additionally collect:

• Legal business name, business trading name, and business description or tagline.
• Employer Identification Number (EIN) and the legal name and date of birth of the business owner or authorized representative, which We collect to verify that a business is legitimate and that the person registering it is authorized to do so.
• Business address, business geographic coordinates, Google Place identifier, operating hours, parking information, and business categories.
• Business logo and cover imagery.

Business-verification data such as EIN and owner date of birth is used solely for identity and eligibility verification, fraud prevention, and legal compliance. It is not used for marketing and is not published on Your public profile.

Location Data

With Your prior permission, We collect precise geolocation (latitude and longitude) from Your Device in order to:

• show You live streams and events near You;
• power the in-app discovery map;
• send You optional notifications about streams and events within a radius You choose; and
• pre-fill the city and state of a business location when You register a Business Account.

Precise geolocation is treated as Sensitive Personal Information under California law and as sensitive data under several other U.S. state privacy laws. We collect it only with Your opt-in consent, use it only for the purposes listed above, and never sell or share it for cross-context behavioral advertising. You can withdraw location permission at any time in Your Device settings; discovery features will then rely on an address or city You enter manually.

Camera, Microphone, Photos, and Stream Content

With Your prior permission, and only when You actively use the relevant feature, We access:

• Your Device camera and microphone to capture the live video and audio You broadcast through the Service. We do not access Your camera or microphone in the background or when You are not broadcasting.
• Your Device photo library to let You select images for a profile photo, business logo, cover image, or event image. We access only the images You select.

Stream Content You broadcast or upload is transmitted to and processed by Our streaming and storage providers and is stored on Our servers. Live streams You broadcast, and the clips, comments, and reactions associated with them, are visible to other Users of the Service and may be recorded, screenshotted, or redistributed by viewers in ways We cannot control. Do not broadcast anything You would not want to be public and permanent.

We do not extract facial geometry, voiceprints, or any other biometric identifier from Stream Content, and We do not use it to train facial-recognition or voice-recognition systems.

Social and Interaction Data

We collect the actions You take on the Service, including comments You post, likes, saves, shares, businesses You follow, event attendance and RSVP records, streams You view and for how long, and Your notification preferences (including Your chosen notification radius and whether You have enabled nearby-live and event-reminder alerts).

Usage and Device Data

Usage Data is collected automatically and may include Your Device's Internet Protocol (IP) address, device model and type, operating system and version, unique device identifiers, mobile network information, app version, browser type and version where applicable, the pages and screens of the Service You visit, the time and date of Your visit, the time spent on those screens, and other diagnostic data.

Push Notification Tokens

If You enable push notifications, We collect and store the push token assigned to Your Device by Firebase Cloud Messaging, together with Your Device platform, so that We can deliver notifications You have requested. You can disable push notifications at any time in Your Device settings or in the Application's notification settings, and We will delete the associated token.

Crash and Diagnostic Data

We collect crash reports, stack traces, device state at the time of a crash, and performance diagnostics so We can find and fix defects in the Application.

Analytics, Advertising Identifiers, and Tracking Technologies

We use Google Analytics for Firebase to understand how the Application is used in aggregate. On Android, this may involve the Android Advertising ID; on iOS, We do not request App Tracking Transparency permission and do not access the IDFA for cross-app tracking.

We do not serve third-party advertising in the Application, and We do not use analytics or advertising identifiers to build cross-context behavioral advertising profiles or to track You across other companies' apps and websites.

The Application does not use browser cookies. Our back-end services and any Company websites may use strictly necessary cookies and similar technologies (such as local storage on Your Device and session tokens) to keep You signed in and to maintain security. Where non-essential tracking technologies are used on a Company website, We will present a cookie notice and obtain consent where required.

You can reset or limit the advertising identifier on Your Device at any time through Your Device settings ("Delete advertising ID" or "Opt out of Ads Personalization" on Android; "Limit Ad Tracking" / App Tracking Transparency on iOS).

Do Not Track and Opt-Out Preference Signals

We honor opt-out preference signals, including the Global Privacy Control (GPC), where they are transmitted to Our web properties, and treat them as a valid request to opt out of the sale or sharing of Personal Information for that browser or device. Because there is no common industry standard for "Do Not Track" browser signals, We do not otherwise respond to DNT headers.

How We Use Your Personal Data and Our Legal Bases

We use Personal Data only where We have a valid legal basis. The table below sets out each purpose, the data involved, and the legal basis We rely on under the GDPR and UK GDPR. Where We rely on consent, You may withdraw it at any time without affecting the lawfulness of processing carried out before withdrawal.

Providing Your name, email address, password, and date of birth is necessary to create an Account; without it We cannot provide the Service. Providing location, camera, microphone, and photo access is optional, but the related features will not function without it.

Automated decision-making: We do not use Your Personal Data to make decisions based solely on automated processing that produce legal effects concerning You or similarly significantly affect You. Automated tools may flag content or accounts for review, but enforcement decisions involve human review.

How We Share Your Personal Data

We do not sell Your Personal Data for money, and We do not share it for cross-context behavioral advertising. We disclose Personal Data only as follows:

• With other Users: Your display name, profile photo, biography, business profile details, live streams, clips, comments, and event listings are visible to other Users of the Service. Your precise location is not shown to other Users; business listings display the business address You provide.
• With Service Providers: We share Personal Data with the vendors listed in the section below, each of which processes it on Our behalf under a written data processing agreement and is prohibited from using it for its own purposes.
• With Affiliates: We may share Personal Data with Our Affiliates, who are required to honor this Privacy Policy.
• For business transfers: in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or part of Our business.
• For legal reasons: as described under "Disclosure of Your Personal Data" below.
• With Your consent: for any other purpose You agree to.

Service Providers We Use

The following third parties process Personal Data on Our behalf. Each link goes to that provider's own privacy policy.

• Google LLC — Firebase Cloud Messaging: delivery of push notifications. Data: push token, device identifiers, IP address. Firebase privacy
• Google LLC — Google Analytics for Firebase: product analytics. Data: Usage Data, device identifiers, advertising identifier (Android), IP address. Google privacy policy
• Google LLC — Firebase Crashlytics: crash and stability reporting. Data: crash logs, device state, installation identifier. Firebase privacy
• Google LLC — Google Sign-In: optional authentication. Data: identity token, name, email address. Google privacy policy
• Google LLC — Google Maps and Google Places: map display and place lookup for business and event locations. Data: precise geolocation, IP address, search queries. Google privacy policy
• Apple Inc. — Sign in with Apple: optional authentication on iOS. Data: identity token, name, email or private relay address. Apple privacy policy
• api.video: live video ingestion and delivery. Data: Stream Content (video and audio), stream metadata, IP address. api.video privacy policy
• Mux, Inc.: video processing, recording, and delivery. Data: Stream Content, playback and viewer metrics, IP address. Mux privacy policy
• Our cloud hosting and object storage provider: hosting of Our back-end services and storage of uploaded images and recorded clips. Data: all categories.
• Our transactional email provider: delivery of verification, password reset, and Service emails. Data: email address, message content and delivery status.

We update this list when Our vendors change. If You would like the current list of Our sub-processors, contact Us at the privacy address above.

Text (SMS) Messages

The Service does not currently send SMS text messages and We do not currently collect mobile phone numbers. If We introduce SMS messaging in the future, We will update this Policy before doing so, and the following terms will apply.

You will have the option to opt in to receive text messages from Us. If You opt in, We will collect and store Your phone number, the date and method of Your consent, and message delivery information. Consent to receive text messages will never be a condition of any purchase or use of the Service. Categories of messages may include customer care and support, account notifications, authentication messages such as one-time passcodes, security alerts, and — where separately consented to — marketing and promotional content.

No mobile information will be shared with or sold to third parties or affiliates for marketing or promotional purposes. Phone numbers and consent records collected for texting are not shared with anyone for any purpose, other than the Service Providers that must technically handle them in order to deliver the messages.

Reply STOP to opt out. Reply HELP for support. Message and data rates may apply. Message frequency may vary. Carriers are not liable for delayed or undelivered messages.

Retention of Your Personal Data

We retain Personal Data only as long as necessary for the purposes set out in this Policy. Unless otherwise stated, the periods below are maximum periods ("up to"), and We delete or anonymize data sooner where it is no longer needed. Where possible We shorten retention or reduce identifiability by deleting, aggregating, or anonymizing data.

• Account information — for the duration of Your Account relationship, plus up to 24 months after account closure to resolve disputes and handle post-termination issues. Where You submit a verified deletion request, We delete or de-identify Account data within 30 days, subject to the exceptions below.

• Stream Content — live streams are retained while active; recorded clips and uploaded images are retained until You delete them or close Your Account, and are removed from Our active systems within 30 days of deletion.

• Comments and interaction data — for the life of the associated stream or event, or until You delete them.

• Precise geolocation — location used for discovery is processed transiently and is not stored in identifiable form beyond the session; the notification radius and business coordinates You configure are retained while Your Account is active.

• Push notification tokens — until You disable notifications, uninstall the Application, or the token expires.

• Business verification data (EIN, owner date of birth) — for the life of the Business Account plus up to 7 years, to meet tax, anti-fraud, and recordkeeping obligations.

• Customer support tickets and correspondence — up to 24 months from ticket closure.

• Content moderation and safety records — up to 24 months after the enforcement action, or longer where needed to prevent a banned user from returning or to respond to legal process.

• Analytics and application usage statistics — up to 14 months in identifiable form, then aggregated.

• Crash and diagnostic data — up to 90 days.

• Server logs (IP addresses, access times) — up to 12 months for security monitoring and troubleshooting.

• Privacy rights request records — up to 24 months, as required by law, to demonstrate compliance.

We may retain Personal Data beyond these periods where: We are required by law to do so (for example, financial records); the data is necessary to establish, exercise, or defend legal claims; You have asked Us to retain it; or the data exists in encrypted backups scheduled for routine deletion.

When retention periods expire, We delete Personal Data from Our active systems or convert it into anonymous statistical data that cannot be linked back to You. Residual copies may remain in encrypted backups for a limited period consistent with Our backup schedule and are not restored except where necessary for security, disaster recovery, or legal compliance. Anonymized data may be retained indefinitely.

International Transfers of Your Personal Data

We are based in the United States and Our Service Providers process data in the United States and, in some cases, in other countries. If You access the Service from outside the United States, Your Personal Data will be transferred to, stored, and processed in the United States, where data protection laws may differ from those of Your jurisdiction.

Where We transfer Personal Data out of the European Economic Area, the United Kingdom, or Switzerland, We rely on one or more of the following safeguards:

• the European Commission's Standard Contractual Clauses (Decision 2021/914) and, for the UK, the UK International Data Transfer Addendum;
• an adequacy decision covering the recipient country; or
• the recipient's certification under the EU-U.S. Data Privacy Framework and its UK Extension and Swiss-U.S. Framework, where applicable.

We also carry out transfer impact assessments and apply supplementary technical measures, including encryption in transit and at rest. You may request a copy of the relevant safeguards by contacting Us.

Security of Your Personal Data

We use commercially reasonable administrative, technical, and physical safeguards designed to protect Your Personal Data, including:

• encryption of data in transit using TLS, and encryption of stored data at rest;
• storage of passwords using salted, one-way hashing;
• storage of authentication tokens in the Device's secure keystore (Android Keystore / iOS Keychain);
• role-based access controls limiting employee access to Personal Data on a need-to-know basis;
• short-lived access tokens and token rotation; and
• logging and monitoring of access to production systems.

No method of transmission over the Internet or method of electronic storage is completely secure, and We cannot guarantee absolute security. If We become aware of a breach of security leading to the unauthorized disclosure of Your Personal Data, We will notify You and the relevant supervisory or state authorities where required by law and without undue delay.

Your Privacy Rights

Rights Available to All Users

Regardless of where You live, You may:

• access and review Your profile information in the Application;
• correct or update Your information in Your Account settings;
• delete individual streams, clips, comments, and images from within the Application;
• delete Your Account and associated data, either from within the Application under Profile → Settings → Delete Account, or by submitting a request at https://seewhatshappnin.com/delete-account without needing to install the Application;
• withdraw device permissions for location, camera, microphone, and photos at any time in Your Device settings;
• unsubscribe from marketing emails using the link in any such email; and
• disable push notifications in the Application or Your Device settings.

Rights Under the GDPR and UK GDPR

If the GDPR or UK GDPR applies to Our processing of Your Personal Data, You have the right to:

• Be informed about how We process Your Personal Data — this Policy serves that purpose.
• Access Your Personal Data and obtain a copy of it (Art. 15).
• Rectification of inaccurate or incomplete Personal Data (Art. 16).
• Erasure of Your Personal Data, the "right to be forgotten" (Art. 17).
• Restriction of processing in certain circumstances (Art. 18).
• Data portability — to receive Your Personal Data in a structured, commonly used, machine-readable format and to have it transmitted to another controller (Art. 20).
• Object to processing based on Our legitimate interests, and to object at any time to processing for direct marketing (Art. 21).
• Withdraw consent at any time where processing is based on consent (Art. 7(3)), without affecting the lawfulness of prior processing.
• Not be subject to a decision based solely on automated processing, including profiling, that produces legal or similarly significant effects (Art. 22). As noted above, We do not carry out such processing.
• Lodge a complaint with a supervisory authority (Art. 77). In the UK this is the Information Commissioner's Office (ico.org.uk); in the EEA it is the authority in Your country of residence, place of work, or place of the alleged infringement.

To exercise these rights, email privacy@seewhatshappnin.com. We will respond within one month, which We may extend by up to two further months for complex requests, in which case We will tell You within the first month and explain why.

Rights Under California Law (CCPA/CPRA)

This section applies to California residents and supplements the rest of this Policy. It describes Our practices for the preceding 12 months and constitutes Our notice at collection.

Categories of Personal Information We Collect

Sources of Personal Information

We collect Personal Information directly from You, automatically from Your Device as You use the Service, from third-party sign-in providers where You choose to use them, and from other Users (for example, when another User comments on Your stream or reports Your content).

Sensitive Personal Information

We collect precise geolocation and Account log-in credentials. We use and disclose this Sensitive Personal Information only for the purposes permitted under CCPA Regulations §7027(m) — namely to perform the Service You requested, to ensure security and integrity, and for short-term transient use — and not to infer characteristics about You. Because We limit Our use of Sensitive Personal Information to these permitted purposes, We are not required to offer, and do not offer, a separate "Limit the Use of My Sensitive Personal Information" mechanism.

Sale and Sharing

We have not sold Personal Information, and have not shared Personal Information for cross-context behavioral advertising, in the preceding 12 months. We do not sell or share the Personal Information of consumers We know to be under 16 years of age. Because We do not sell or share Personal Information, We do not provide a "Do Not Sell or Share My Personal Information" link; We nonetheless honor opt-out preference signals such as the Global Privacy Control as described above.

Your California Rights

• Right to know the categories and specific pieces of Personal Information We have collected, the sources, the purposes, and the categories of third parties to whom We disclose it.
• Right to delete Personal Information We have collected from You, subject to statutory exceptions.
• Right to correct inaccurate Personal Information.
• Right to opt out of the sale or sharing of Personal Information (not applicable, as We do neither).
• Right to limit the use and disclosure of Sensitive Personal Information (not applicable, as We use it only for permitted purposes).
• Right to non-discrimination — We will not deny You goods or services, charge You different prices, or provide a different level of quality because You exercised a privacy right.

To submit a request, email privacy@seewhatshappnin.com or use the form at https://seewhatshappnin.com/privacy-request. We will confirm receipt within 10 business days and respond within 45 calendar days, which We may extend by a further 45 days with notice to You.

Verification: to protect Your Personal Information, We verify requests by asking You to confirm the request from the email address associated with Your Account and, for requests to know specific pieces of information, by asking You to sign in to Your Account or provide additional matching data points. We use information provided for verification only for that purpose.

Authorized agents: You may designate an authorized agent to submit a request on Your behalf. We will require written permission signed by You, and We may require You to verify Your own identity directly with Us. A natural person or business entity registered with the California Secretary of State may act as an authorized agent.

Shine the Light (Cal. Civ. Code §1798.83): We do not disclose Personal Information to third parties for their own direct marketing purposes.

Rights Under Other U.S. State Privacy Laws

If You are a resident of Minnesota, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, Florida, Delaware, Iowa, Nebraska, New Hampshire, New Jersey, Tennessee, Maryland, Indiana, Kentucky, Rhode Island, or another state with a comprehensive consumer privacy law, You have the right to confirm whether We process Your Personal Data, to access it, to correct inaccuracies, to delete it, to obtain a portable copy, and to opt out of targeted advertising, the sale of Personal Data, and profiling in furtherance of decisions producing legal or similarly significant effects. We do not engage in targeted advertising, sell Personal Data, or conduct such profiling.

We process precise geolocation, which several of these laws classify as sensitive data, only with Your opt-in consent, and We do not sell it.

Minnesota residents additionally have the right to obtain a list of the specific third parties to which We have disclosed Your Personal Data, and, where profiling is used, the right to question the result of that profiling, to be informed of the reason for it, and to review the Personal Data used.

Nevada residents may submit a verified request that We not sell their covered information. We do not sell covered information.

Appeals: if We decline to act on Your request, We will tell You why. You may appeal that decision within a reasonable period by emailing privacy@seewhatshappnin.com with the subject line "Privacy Appeal". We will respond in writing within 45 days (60 days in Minnesota, where permitted) explaining the outcome and the reasons for it. If Your appeal is denied, You may contact Your state Attorney General to submit a complaint.

Children's and Minors' Privacy

The Service is not directed to children, and We do not knowingly collect Personal Information from anyone under the age of 16. You must be at least 16 years old to create an Account. We ask for Your date of birth during registration to enforce this requirement and to restrict access to event listings marked as 18+.

If You are a parent or guardian and You believe Your child has provided Us with Personal Information, please contact Us at privacy@seewhatshappnin.com. If We become aware that We have collected Personal Information from a child under 16, We will delete that information and terminate the Account as soon as reasonably possible.

Some countries and states set a higher age at which an individual can consent to the processing of their own Personal Information. Where We rely on consent as a legal basis and the applicable law sets an age above 16, We will require the consent of that User's parent or guardian before collecting and using their Personal Information.

Live streams and events marked 18+ are restricted to Users whose stated date of birth indicates they are 18 or older.

Public Content and Content Moderation

Live streams, clips, comments, business profiles, and event listings published through the Service are public. Other Users may view, record, screenshot, or redistribute this content, and We cannot control what they do with it once it leaves the Service.

We review reported content and may remove content or suspend Accounts that violate Our Terms of Service. We retain records of reports, removals, and enforcement actions as described in the Retention section, including where necessary to prevent a suspended User from creating a new Account.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition, or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different privacy policy.

Law Enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities, such as a court or a government agency.

Other Legal Requirements

The Company may disclose Your Personal Data in the good-faith belief that such action is necessary to:

• comply with a legal obligation;
• protect and defend the rights or property of the Company;
• prevent or investigate possible wrongdoing in connection with the Service;
• protect the personal safety of Users of the Service or the public; or
• protect against legal liability.

Links to Other Websites

The Service may contain links to websites not operated by Us, including links Hosts add to their business profiles. If You click a third-party link You will be directed to that third party's site. We have no control over, and assume no responsibility for, the content, privacy policies, or practices of any third-party sites or services. We strongly advise You to review the privacy policy of every site You visit.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time. We will post the new Privacy Policy on this page and update the "Last updated" date at the top. Where the changes are material, We will notify You by email and/or by a prominent notice within the Service before the change takes effect, and where the change requires it, We will obtain Your consent.

You are advised to review this Privacy Policy periodically. Changes are effective when posted on this page unless stated otherwise.

Contact Us

If You have any questions about this Privacy Policy or wish to exercise Your privacy rights, You can contact Us:

• By email: privacy@seewhatshappnin.com
• By mail: The Great Connection LLC, 711 W Lake St, Minneapolis, MN 55408, United States
• Account deletion: https://seewhatshappnin.com/delete-account