California Consumers

See our California Policy.

Welcome to Cuff’s Privacy Policy. We hope this information comes across as transparent and straightforward to all readers.

We'll discuss the information we collect, how we use it, and our commitment to securing it.

This Privacy Policy applies beginning May 23rd, 2020. This is the first version of our privacy policy.

Effective: May 23rd, 2020.

This Privacy Policy applies to websites, apps, and other virtual assistants that are operated by Cuff.

LevelUp is an AI headshot generator app that creates professional pictures from your photos.

Q: What face data does your app collect? A: LevelUp collects images of your face, including details of your eyes, nose, hair, mouth, skin, and other facial features necessary to train an AI model.

Q: How do we use the collected face data? A: With this AI model, we create professional headshot photos that resemble your face and are hyper-realistic.

Q: Will the data be shared with any third parties? Where will this information be stored? A: Your facial data is not shared with any third parties and is securely stored on our servers using AWS and Google Cloud services for storage.

Q: How long will the face data be retained? A: Your facial data is discarded as soon as the AI model is finished with creating your headshot photos.

Cuff is a holding entity designed to serve apps ranging from social discovery to utility functionality.

If you live outside the European Union, the entity responsible for your information is Cuff.

We'll need some personal information from you, like your age and location. The only mandatory field to know from you is your age. You are free to choose a display name that is not your real name. Interests, personality traits, and other characteristics that describe you are optionally provided to help better find your matches. For our LevelUp app, we collect your photo information to create AI models of your face. We do not share these images with anyone and they are securely deleted from our servers when finished.

We may use personally identifiable information in the form of cookies to identify who you are.

Otherwise, all information will be asked for directly from you.

We'll apply your information to find matches based on age, location, and characteristics you use to describe yourself. We will not store face data on our servers.

For providing services to you:

• Creating your account.
• Provide support for you account.
• Complete your purchases.

Connecting you with others.

• Using the data you provided, Cuff analyzes who your best matches would be and automatically handles the pairing process.

Ensure consistency across all mobile devices.

• Cuff currently uses sign-in with Apple to ensure a consistent experience across all iOS devices.

Providing services to you

• Register you and offer up your availability for matchmaking on Cuff.
• Administer your account on these new features and apps

Developing and improving our services

• Conduct research and analysis of users’ behavior to improve our services and content (for instance, we may decide to change the look and feel or even substantially modify a given feature based on users’ behavior)
• Develop new features and services (for example, we may decide to build a new interests-based feature further to requests received from users).

To combat unauthorized conduct.

• We'll investigate all instances of flagrant conduct.

Ensure complicance on a legal basis

• Comply with legal requirements per the jurisdiction Cuff operates in.

To process your information as described above, we rely on the following legal bases:

• Provide our service to you: Most of the time, the reason we process your information is to perform the contract that you have with us. For instance, as you go about using our service to build meaningful connections, we use your information to maintain your account and your profile, to make it viewable to other users and recommend other users to you.
• Legitimate interests: We may use your information where we have legitimate interests to do so. For instance, we analyze users’ behavior on our services to continuously improve our offerings, we suggest offers we think might interest you, and we process information for administrative, fraud detection and other legal purposes.
• Consent: From time to time, we may ask for your consent to use your information for certain specific reasons. You may withdraw your consent at any time by contacting us at the address provided at the end of this Privacy Policy.

Since our goal is to help you make meaningful connections, the main sharing of users’ information is, of course, with other users. We also share some users’ information with service providers and partners who assist us in operating the services in some cases, legal authorities. Read on for more details about how your information is shared with others.

With other users

You share information with other users whom you are matched with. The information shared is voluntarily provided by you.

You can partially adjust what is shared in your settings.

With our service providers and partners

We use third parties to help us operate and monitor our product for assurance.

When required by law

We may disclose your information if found necessary to comply with a legal process, such as a court order, subpoena or search warrant, government or law enforcement investigation or other legal requirements

With your consent or at your request

We may ask for your consent to share your information with third parties. In any such case, we will make it clear why we want to share the information.

Sharing of information may involve international data transfers, for instance to the United States of America and other jurisdictions. An example of this would be video packets sent to other users so that you may video chat with them.

We want you to be in control of your information, so we have provided you with the following tools:

• Access your account settings.

On the topic of the consistency of your information, recall:

• Reviewing your information. Applicable privacy laws provide you with the right to review the personal information Cuff maintains.
• Updating information: If you believe that the information we hold about you is inaccurate or you don't want us to retain it, please contact us at ali@cuff.live

• Unstalling: Removes all forms of data collection Cuff may process.
• In particular countries, such as the European Union, you may lodge a complaint with the appropriate data protection authority if you have concerns about your personal information.

If you are a California resident, you can request a notice disclosing the categories of personal information about you that we have shared with third parties for their direct marketing purposes during the preceding calendar year. To request this notice, please submit your request to ali@cuff.live.

We work hard to protect you from unauthorized access to or alteration, disclosure or removal of your personal information.

We regularly monitor our systems for possible vulnerabilities and attacks and regularly review our information collection, storage and processing practices to update our physical, technical and organizational security measures.

We may suspend your use of all or part of the services without notice if we suspect or detect any breach of security. If you believe that your account or information is no longer secure, please notify us at ali@cuff.live.

Our services are restricted to users who are 18 years of age or older. We do not permit users under the age of 18 on our platform and we do not knowingly collect personal information from anyone under the age of 18. Please report all instances of underage use to Cuff.

We keep your personal information only as long as we need it for legitimate business purposes and as permitted by applicable law.

We delete or anonymize your information upon deletion of your account, except when:

1. we must keep it to comply with applicable law.
2. there is an outstanding issue or claim making it necessary to contain your information.

If you have questions about this Privacy Policy, reach out to ali@cuff.live

We'll notify you prior to any material changes in this privacy policy.