PRIVACY POLICY

GiftTulip.com

Effective Date: April 21, 2025

1. Introduction

Welcome to GiftTulip.com (“we,” “our,” or “us”). We are committed to protecting your personal information and your right to privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website GiftTulip.com and use our services (collectively, the “Platform”).

Please read this Privacy Policy carefully. If you disagree with its terms, please discontinue use of our Platform immediately. By accessing or using the Platform, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy.

2. Information We Collect

2.1 Information You Provide Directly

When you register for an account, use our services, or communicate with us, we may collect:

• Full name and display name / username

• Email address

• Date of birth and age verification information

• Gender identity and dating preferences

• Profile photos and other media you upload

• Biography, interests, and other profile information

• Gift preferences and related profile details

• Messages and communications sent through the Platform

• Payment and billing information (processed securely via third-party payment processors)

• Any other information you choose to provide

2.2 Information Collected Automatically

When you use our Platform, we automatically collect certain technical information, including:

• IP address and approximate geographic location

• Browser type, version, and language settings

• Device type, operating system, and unique device identifiers

• Referring URLs and pages visited on our Platform

• Date and time of access

• Clickstream data and interaction patterns

• Cookie identifiers and similar tracking technologies

• Log files and usage data

2.3 Information from Third Parties

We may receive information about you from third parties, including:

• Advertising partners and analytics providers

• Social media platforms, if you choose to connect your account

• Payment processors for transaction verification

• Identity verification services

3. Cookies and Tracking Technologies

We use cookies, web beacons, pixels, and similar technologies to operate and improve our Platform, deliver advertising, and provide analytics. These include:

• Essential Cookies: Required for the Platform to function properly, such as maintaining your login session.

• Functional Cookies: Remember your preferences and settings to enhance your experience.

• Analytics Cookies: Help us understand how visitors interact with our Platform (e.g., Google Analytics).

• Advertising Cookies: Used by us and our advertising partners to serve relevant advertisements to you on our Platform and on third-party websites and apps. These may include retargeting pixels from platforms such as Google Ads, Meta (Facebook/Instagram), TikTok, and others.

You may control cookies through your browser settings. However, disabling certain cookies may affect the functionality of our Platform. Our advertising partners may use their own cookies and tracking technologies subject to their own privacy policies. We are not responsible for the privacy practices of third-party advertising networks.

We may use remarketing or retargeting technology, meaning that if you visit our Platform, you may later see advertisements for GiftTulip.com on other websites and apps. This is done using cookies and tracking pixels placed by our advertising partners.

4. How We Use Your Information

We use the information we collect for the following purposes:

• To create, operate, and maintain your account and provide our matchmaking and dating services

• To display your profile to other users in accordance with the Platform’s browsing rules

• To facilitate communication between users, including via WhatsApp and email for premium subscribers

• To process payments and manage premium subscriptions

• To send you service-related communications, including account updates, security alerts, and support messages

• To send you promotional communications, offers, and newsletters (you may opt out at any time)

• To serve and improve targeted advertising, including interest-based advertising through third-party ad networks

• To analyze usage patterns and improve our Platform, features, and services

• To verify your identity and ensure you meet our age requirements

• To detect, prevent, and investigate fraud, abuse, security incidents, and other harmful activity

• To enforce our Terms and Conditions and other policies

• To comply with applicable laws, regulations, and legal obligations

• To respond to your inquiries and provide customer support

5. Legal Bases for Processing Your Information

Depending on where you are located, we process your personal information on the following legal grounds:

• Contract Performance: Processing necessary to provide you with the services you requested, including account creation and subscription management.

• Legitimate Interests: Processing for our legitimate business interests, such as improving our services, preventing fraud, and marketing our Platform, provided these interests do not override your rights.

• Consent: Where you have given us clear consent, such as for marketing emails or placement of certain cookies.

• Legal Obligation: Where we are required to process your data to comply with a legal obligation.

6. How We Share Your Information

We do not sell your personal information. We may share your information in the following circumstances:

6.1 With Other Users

Your profile information (such as your name, photos, interests, and gift preferences) will be visible to other users as determined by the Platform’s browsing rules. Women users may browse men’s profiles; men users may see profiles only of women who have liked them. You control what information you include in your profile.

6.2 With Service Providers

We share information with trusted third-party service providers who assist us in operating our Platform, including:

• Cloud hosting and infrastructure providers

• Payment processors (who handle payment data under their own strict security standards)

• Email and communication service providers

• Analytics providers (e.g., Google Analytics)

• Advertising networks and marketing platforms (e.g., Google Ads, Meta Ads)

• Customer support tools

• Fraud prevention and security services

These providers are contractually obligated to use your information only as necessary to provide services to us and in compliance with applicable law.

6.3 For Advertising Purposes

We work with third-party advertising partners to display ads on our Platform and to advertise our services on other platforms. These partners may use cookies, pixels, and device identifiers to collect information about your activity on our Platform and other websites to provide you with targeted advertising. This sharing is subject to our Cookie Policy and the privacy policies of those advertising partners.

6.4 Business Transfers

If we are involved in a merger, acquisition, asset sale, financing, or other business transition, your information may be transferred as part of that transaction. We will notify you of any such change in ownership or use of your personal information.

6.5 Legal Requirements and Protection

We may disclose your information where required by law, legal process, or governmental authority, or where we believe disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a lawful request.

7. Data Retention

We retain your personal information for as long as your account is active or as necessary to provide you with our services. We will also retain information as necessary to comply with our legal obligations, resolve disputes, enforce our agreements, and for legitimate business purposes such as fraud prevention.

When you delete your account, we will delete or anonymize your personal information within a reasonable period, except where we are required to retain it by law or for legitimate business reasons. Some information may persist in backups for a limited period.

8. Data Security

We implement commercially reasonable technical, organizational, and administrative security measures to protect your personal information from unauthorized access, loss, misuse, alteration, or disclosure. These measures include encryption, access controls, and secure servers.

However, no method of transmission over the internet or method of electronic storage is 100% secure. While we strive to protect your personal information, we cannot guarantee its absolute security. You are responsible for maintaining the confidentiality of your account credentials. We are not responsible for unauthorized access to your account resulting from your own actions or negligence.

9. Your Rights and Choices

Depending on your location, you may have the following rights regarding your personal information:

• Access: Request a copy of the personal information we hold about you.

• Correction: Request that we correct inaccurate or incomplete information.

• Deletion: Request that we delete your personal information, subject to certain exceptions.

• Restriction: Request that we restrict the processing of your information in certain circumstances.

• Portability: Request that we provide your information in a structured, machine-readable format.

• Objection: Object to the processing of your information for direct marketing or where we rely on legitimate interests.

• Withdraw Consent: Where processing is based on consent, withdraw that consent at any time without affecting the lawfulness of prior processing.

• Opt-Out of Marketing: Unsubscribe from marketing emails at any time by clicking the unsubscribe link in any email we send.

To exercise any of these rights, please contact us at hell@gifttulip.com. We will respond to your request within the timeframe required by applicable law. We may need to verify your identity before processing your request.

10. Children’s Privacy

Our Platform is strictly intended for adults aged 18 years and older. We do not knowingly collect, solicit, or retain personal information from anyone under the age of 18. If you are under 18, please do not use our Platform or provide any information to us.

If we become aware that we have inadvertently collected personal information from a person under 18, we will take immediate steps to delete that information. If you believe we may have collected information from a minor, please contact us immediately at hell@gifttulip.com.

11. Third-Party Links and Services

Our Platform may contain links to third-party websites, applications, and services, including WhatsApp and email clients used for premium user communications. We are not responsible for the privacy practices or content of those third parties. We encourage you to review the privacy policies of any third-party services you interact with through our Platform.

When premium users communicate via WhatsApp or email, those communications are subject to the privacy policies of WhatsApp (Meta Platforms) and the relevant email service provider. We do not monitor, store, or control those communications once they leave our Platform.

12. International Data Transfers

Our Platform operates globally, and your information may be transferred to and processed in countries other than the country in which you are located. These countries may have data protection laws that differ from those in your country.

By using our Platform, you consent to the transfer of your information to countries outside your own, including countries that may not provide the same level of data protection as your home country. We take appropriate steps to ensure that such transfers comply with applicable law and that your information remains protected.

13. Advertising Disclosure

We may display advertisements on our Platform from third-party advertising networks. We may also run paid advertising campaigns on third-party platforms to promote our services. These advertising activities involve the use of cookies, pixels, and other tracking technologies as described in Section 3.

We comply with applicable advertising laws and regulations. Our advertising partners are required to comply with applicable privacy laws in their collection and use of data for advertising purposes. If you wish to opt out of interest-based advertising, you may do so through the Digital Advertising Alliance (DAA) at www.aboutads.info, the Network Advertising Initiative (NAI) at www.networkadvertising.org, or your device’s advertising settings.

14. Changes to This Privacy Policy

We reserve the right to update or modify this Privacy Policy at any time. When we make changes, we will update the Effective Date at the top of this document and, where the changes are significant, we will provide more prominent notice (such as a notification on the Platform or via email).

Your continued use of the Platform after the effective date of any updated Privacy Policy constitutes your acceptance of the changes. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

15. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at: