Interleave Privacy Policy

Effective Date: December 17, 2024

Last Updated: December 17, 2024

Introduction

Welcome to Interleave. This Privacy Policy ("Policy") describes how Interleave ("Interleave," "we," "us," or "our") collects, uses, discloses, and otherwise processes personal information in connection with our mobile application, website, and related services (collectively, the "Services"), as well as your rights and choices regarding your personal information.

PLEASE READ THIS PRIVACY POLICY CAREFULLY. BY ACCESSING OR USING OUR SERVICES, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO BE BOUND BY THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT ACCESS OR USE OUR SERVICES.

This Privacy Policy is incorporated into and forms part of our Terms of Use. Capitalized terms not defined in this Policy have the meanings given to them in the Terms of Use.

Table of Contents

1. Scope of This Policy
2. Information We Collect
3. How We Use Your Information
4. Legal Bases for Processing (EEA, UK, and Switzerland)
5. How We Share Your Information
6. Cookies and Tracking Technologies
7. Data Retention
8. Data Security
9. International Data Transfers
10. Your Rights and Choices
11. Children's Privacy
12. Third-Party Links and Services
13. California Privacy Rights (CCPA/CPRA)
14. European Privacy Rights (GDPR)
15. Other State and Regional Privacy Rights
16. Changes to This Privacy Policy
17. Contact Us

1. Scope of This Policy

1.1 Applicability

This Privacy Policy applies to personal information collected through:

(a) The Interleave mobile application (available on iOS and Android);

(b) The Interleave website at interleave.love and any related subdomains;

(c) Communications with our customer support team;

(d) Our social media pages and interactions; and

(e) Any other services that link to this Privacy Policy.

1.2 Not Covered

This Privacy Policy does not apply to:

(a) Information collected by third parties, including third-party websites, services, or applications that may be accessible through links on our Services;

(b) Information collected offline or through other means not described in this Policy; or

(c) The practices of other companies or individuals that we do not own or control.

2. Information We Collect

We collect personal information in several ways, including when you provide it directly to us, when third parties provide it to us, and when it is collected automatically through your use of our Services.

2.1 Information You Provide Directly

2.1.1 Account and Profile Information

When you create an account, you provide us with:

• Email address
• Password (stored in hashed form)
• Display name or username
• Profile photographs
• Date of birth
• Gender and gender preferences
• Biographical information
• Relationship status and goals
• Location (city, region, country)

2.1.2 Relationship and Activity Data

As you use our Services, you provide:

• Events, moments, and memories you create
• Check-in scores and relationship health assessments
• Mood entries and emotional logs
• Ritual completions and activity participation
• Journal entries and notes
• Interview responses (for Weave matchmaking)
• Partner linking requests and consents

2.1.3 Communications

When you communicate through the Services, we collect:

• Messages sent to your linked partner
• Messages sent to the AI assistant
• Reports and feedback you submit
• Customer support communications
• Survey responses

2.1.4 Payment Information

When you subscribe to premium services, we collect:

• Billing name and address
• Payment card information (processed by our payment processors; we do not store full card numbers)
• Transaction history
• Subscription status

2.1.5 Voice and Audio Data

If you use voice features, we may collect:

• Voice recordings from interview responses
• Audio messages
• Voice commands (if applicable)

2.1.6 Photos and Media

You may provide:

• Profile photos
• Photos attached to events and check-ins
• Live photos (for Weave verification)
• Media imported from connected services (Google Photos, Instagram)

2.2 Information Collected Automatically

2.2.1 Device Information

We automatically collect information about your device, including:

• Device type, model, and manufacturer
• Operating system and version
• Unique device identifiers (e.g., device ID, advertising ID)
• Mobile network information
• Browser type and version (for web access)
• Screen resolution and display settings

2.2.2 Usage Information

We collect information about how you use the Services:

• Features accessed and actions taken
• Time, frequency, and duration of activities
• Pages and screens viewed
• Search queries within the app
• Interactions with other users (e.g., partner linking, matches)
• App crashes and error reports
• Performance data

2.2.3 Location Information

We may collect location information, including:

• Precise geolocation (with your explicit consent)
• Approximate location derived from IP address
• Location information you provide in your profile

2.2.4 Log Data

Our servers automatically record:

• IP address
• Access times and dates
• Referring URLs
• Browser and device information
• Pages viewed

2.3 Information from Third Parties

2.3.1 Social Login and Connected Accounts

If you connect third-party accounts, we may receive:

• Basic profile information from authentication providers
• Email address from authentication providers
• Photos from Google Photos (with your authorization)
• Photos and media from Instagram (with your authorization)
• Calendar availability from Google Calendar (with your authorization)

2.3.2 Payment Processors

Our payment processors (e.g., Stripe, Polar) may provide us with:

• Confirmation of successful payments
• Subscription status updates
• Billing issues or failed payments

2.3.3 Analytics Providers

We may receive aggregated or de-identified analytics data from service providers.

2.4 Sensitive Personal Information

Depending on your use of the Services and your jurisdiction, we may collect information that is considered sensitive, including:

• Precise geolocation data
• Racial or ethnic origin (if you choose to provide it)
• Sexual orientation or relationship preferences
• Health-related information (mood, emotional states)
• Biometric information (face geometry from photos, if applicable)

We process sensitive personal information only with your explicit consent or as otherwise permitted by applicable law, and we implement additional safeguards to protect such information.

3. How We Use Your Information

3.1 Providing and Maintaining the Services

We use your information to:

(a) Create and manage your account;

(b) Provide the core features of the Services, including events, check-ins, rituals, mood tracking, and partner linking;

(c) Process and manage subscriptions and payments;

(d) Enable partner linking and data sharing between linked accounts;

(e) Provide customer support and respond to your inquiries;

(f) Send transactional communications (e.g., account verification, password resets, payment confirmations).

3.2 Personalizing Your Experience

We use your information to:

(a) Provide personalized relationship insights and recommendations through our AI features;

(b) Customize content and features based on your preferences and usage patterns;

(c) Suggest rituals, activities, and date ideas tailored to your relationship;

(d) Facilitate matching and compatibility assessments in Weave matchmaking.

3.3 Improving and Developing the Services

We use your information to:

(a) Understand how users interact with our Services;

(b) Identify trends, usage patterns, and areas for improvement;

(c) Develop new features, products, and services;

(d) Conduct research and analysis (using aggregated or de-identified data);

(e) Train and improve our AI and machine learning models.

3.4 Safety, Security, and Fraud Prevention

We use your information to:

(a) Detect, prevent, and address fraud, abuse, and security issues;

(b) Verify user identity and prevent unauthorized access;

(c) Enforce our Terms of Use and other policies;

(d) Protect the rights, property, and safety of Interleave, our users, and the public;

(e) Investigate and respond to reports of harmful or prohibited conduct.

3.5 Communications and Marketing

We use your information to:

(a) Send service-related announcements and updates;

(b) Send promotional communications about new features, offers, or events (with your consent where required);

(c) Conduct surveys and request feedback;

(d) Respond to your comments, questions, and requests.

3.6 Legal and Compliance

We use your information to:

(a) Comply with applicable laws, regulations, and legal processes;

(b) Respond to lawful requests from public authorities;

(c) Establish, exercise, or defend legal claims;

(d) Protect against legal liability.

4. Legal Bases for Processing (EEA, UK, and Switzerland)

If you are located in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, we process your personal information based on the following legal grounds:

4.1 Performance of a Contract

We process your information as necessary to perform our contract with you (the Terms of Use), including to:

• Create and manage your account
• Provide the Services you request
• Process payments
• Provide customer support

4.2 Legitimate Interests

We process your information based on our legitimate interests, where those interests are not overridden by your rights and freedoms, including to:

• Improve and develop our Services
• Ensure the security and integrity of our Services
• Prevent fraud and enforce our policies
• Conduct analytics and research
• Send service-related communications

4.3 Consent

We process your information based on your consent, which you may withdraw at any time, including for:

• Processing sensitive personal information
• Sending marketing communications
• Collecting precise geolocation data
• Using cookies and similar tracking technologies (where required)
• Accessing third-party services on your behalf

4.4 Legal Obligations

We process your information as necessary to comply with our legal obligations, including:

• Tax and accounting requirements
• Responding to legal process
• Mandatory reporting obligations

5. How We Share Your Information

5.1 With Your Consent

We share your information with third parties when you have given us explicit consent to do so.

5.2 With Your Linked Partner

When you link your account with a partner, we share information according to your sharing preferences, which may include:

• Check-in scores and mood entries
• Events and calendar items
• Ritual completions
• Other content you choose to share

Your partner can only see information you have specifically chosen to share. You can modify your sharing preferences or unlink your account at any time.

5.3 With Service Providers

We share your information with third-party service providers who perform services on our behalf, including:

All service providers are contractually obligated to use your information only for the purposes of providing services to us and to maintain appropriate security measures.

5.4 With Third-Party Integrations

When you connect third-party services to your account, we may share information with those services as necessary to provide the integration:

• Google Calendar: Event details for calendar synchronization
• Google Photos: Access to import photos you select
• Instagram: Access to import photos you select

Your use of these integrations is subject to the third parties' own privacy policies.

5.5 For Legal Reasons

We may disclose your information if we believe in good faith that disclosure is necessary to:

(a) Comply with applicable laws, regulations, or legal process;

(b) Respond to requests from government or public authorities, including those outside your country of residence;

(c) Enforce our Terms of Use or other agreements;

(d) Protect the rights, privacy, safety, or property of Interleave, our users, or the public;

(e) Detect, prevent, or address fraud, security, or technical issues; or

(f) Protect against legal liability.

5.6 Business Transfers

In the event of a merger, acquisition, reorganization, bankruptcy, or other sale of all or a portion of our assets, your personal information may be transferred as part of that transaction. We will notify you of any such change in ownership or control of your personal information.

5.7 Aggregated and De-Identified Information

We may share aggregated or de-identified information that cannot reasonably be used to identify you. Such information is not subject to this Privacy Policy.

5.8 No Sale of Personal Information

WE DO NOT SELL YOUR PERSONAL INFORMATION. We have never sold personal information, and we have no plans to do so in the future.

6. Cookies and Tracking Technologies

6.1 Types of Technologies

We use the following technologies to collect information:

6.1.1 Cookies

Cookies are small text files stored on your device. We use:

• Essential Cookies: Required for the Services to function (e.g., authentication, security)
• Functional Cookies: Remember your preferences and settings
• Analytics Cookies: Help us understand how you use the Services

6.1.2 Local Storage

We use local storage to store information on your device for app functionality and performance.

6.1.3 Mobile Identifiers

On mobile devices, we may use advertising identifiers (IDFA on iOS, Advertising ID on Android) with your consent.

6.2 Your Choices

You can manage cookies through:

• Your browser settings (for web access)
• Your device settings (for mobile apps)
• Our cookie preferences (where available)

Disabling certain cookies may affect the functionality of the Services.

6.3 Do Not Track

Some browsers have a "Do Not Track" feature. We currently do not respond to Do Not Track signals, but we honor the Global Privacy Control signal where required by law.

7. Data Retention

7.1 Retention Periods

We retain your personal information for as long as necessary to:

(a) Provide the Services to you;

(b) Maintain your account;

(c) Comply with legal obligations;

(d) Resolve disputes and enforce our agreements;

(e) Pursue legitimate business purposes.

7.2 Specific Retention Periods

7.3 Deletion

When you delete your account:

(a) Your profile and content will be removed from the Services within 30 days;

(b) Some information may be retained in backup systems for up to 90 days;

(c) Certain information may be retained longer if required by law or for legitimate business purposes (e.g., fraud prevention, legal claims);

(d) Information you shared with your partner or that was copied by other users may remain with those users.

7.4 Safety Retention

If your account is terminated for violating our Terms of Use, we may retain information about you for a longer period to prevent you from creating new accounts and to protect the safety of our users.

8. Data Security

8.1 Security Measures

We implement appropriate technical and organizational measures to protect your personal information, including:

(a) Encryption: Data in transit is protected using TLS/SSL encryption. Sensitive data at rest is encrypted using industry-standard encryption;

(b) Access Controls: Access to personal information is restricted to authorized personnel on a need-to-know basis;

(c) Authentication: We use secure authentication mechanisms, including password hashing and session management;

(d) Monitoring: We monitor our systems for security incidents and unauthorized access attempts;

(e) Security Assessments: We conduct regular security assessments and penetration testing;

(f) Incident Response: We maintain incident response procedures to address security breaches.

8.2 Your Responsibilities

You are responsible for:

(a) Maintaining the confidentiality of your password and account credentials;

(b) Using strong, unique passwords;

(c) Logging out of your account when using shared devices;

(d) Reporting any suspected unauthorized access to your account immediately.

8.3 Limitations

No method of transmission over the Internet or electronic storage is 100% secure. While we strive to protect your personal information, we cannot guarantee absolute security. In the event of a security breach affecting your personal information, we will notify you as required by applicable law.

9. International Data Transfers

9.1 Data Location

Your personal information may be transferred to, stored, and processed in countries other than your country of residence, including the United States and other countries where our service providers operate.

9.2 Transfer Mechanisms

When we transfer personal information outside of the EEA, UK, or Switzerland, we implement appropriate safeguards, including:

(a) Standard Contractual Clauses (SCCs): We use SCCs approved by the European Commission for transfers to countries without an adequacy decision;

(b) Adequacy Decisions: We may transfer data to countries that the European Commission has determined provide adequate protection;

(c) Supplementary Measures: Where necessary, we implement additional technical and organizational measures to ensure an adequate level of protection.

9.3 Your Consent

By using our Services, you consent to the transfer of your personal information to countries outside your country of residence, including countries that may not provide the same level of data protection as your home country.

10. Your Rights and Choices

10.1 Account Settings

You can access and update much of your personal information through your account settings, including:

• Profile information and photos
• Sharing preferences
• Notification settings
• Connected accounts

10.2 Communication Preferences

You can manage your communication preferences:

• Push Notifications: Adjust in your device settings
• Email Communications: Use the unsubscribe link in our emails or adjust your account settings
• Marketing Communications: Opt out at any time

10.3 Data Rights

Depending on your jurisdiction, you may have the following rights:

10.4 Exercising Your Rights

To exercise your privacy rights, you may:

(a) Use the settings and controls within the Services;

(b) Contact us at privacy@interleave.love;

(c) Submit a request through our Help Center.

We will verify your identity before processing your request. We may ask you to provide additional information to help us verify your identity and locate your records.

10.5 Response Time

We will respond to your request within the timeframe required by applicable law, typically within 30 days. If we need more time, we will notify you.

10.6 Appeals

If we deny your request, you may have the right to appeal. Contact us at privacy@interleave.love to submit an appeal.

11. Children's Privacy

11.1 Age Restriction

The Services are intended for users who are at least 18 years of age. We do not knowingly collect personal information from anyone under 18.

11.2 Parental Notice

If we learn that we have collected personal information from a person under 18, we will take steps to delete that information as soon as possible. If you believe we have collected information from a person under 18, please contact us at privacy@interleave.love.

11.3 Content Restrictions

Users are prohibited from uploading photos of unaccompanied minors or any content depicting minors in a harmful or exploitative manner.

12. Third-Party Links and Services

12.1 Third-Party Websites

The Services may contain links to third-party websites, applications, or services that are not operated by us. This Privacy Policy does not apply to those third-party services.

12.2 Third-Party Practices

We are not responsible for the privacy practices of third parties. We encourage you to review the privacy policies of any third-party services before providing them with your personal information.

12.3 Social Features

If you use social features or share content through social media, your activities may be visible to other users and the public, depending on your privacy settings with those services.

13. California Privacy Rights (CCPA/CPRA)

13.1 Applicability

This section applies to California residents and supplements the rest of this Privacy Policy, as required by the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA).

13.2 Categories of Personal Information

In the preceding 12 months, we have collected the following categories of personal information:

13.3 Sources of Personal Information

We collect personal information from:

• You directly
• Automatically through your use of the Services
• Third-party services you connect
• Payment processors

13.4 Purposes for Collection

We use personal information for the purposes described in Section 3 of this Privacy Policy.

13.5 Disclosure and Sharing

We disclose personal information to the categories of recipients described in Section 5 of this Privacy Policy. We do not "sell" or "share" (as defined by the CCPA/CPRA) your personal information for cross-context behavioral advertising.

13.6 Sensitive Personal Information

We use sensitive personal information only for the purposes permitted by the CCPA/CPRA, including:

• Providing the Services you request
• Ensuring security and integrity
• Performing services on your behalf
• Activities that a consumer would reasonably expect

We do not use sensitive personal information to infer characteristics about you for purposes other than providing the Services.

13.7 Your California Rights

As a California resident, you have the right to:

(a) Know: Request information about the categories and specific pieces of personal information we have collected, the sources of collection, the purposes for collection, and the categories of third parties with whom we share your information;

(b) Delete: Request deletion of your personal information, subject to certain exceptions;

(c) Correct: Request correction of inaccurate personal information;

(d) Opt-Out of Sale/Sharing: We do not sell or share your personal information;

(e) Limit Use of Sensitive Personal Information: Request that we limit the use of your sensitive personal information to certain purposes;

(f) Non-Discrimination: Not be discriminated against for exercising your rights.

13.8 Authorized Agents

You may designate an authorized agent to submit requests on your behalf. We will require verification of both your identity and your agent's authority.

13.9 Exercising Your Rights

To exercise your California privacy rights, contact us at privacy@interleave.love or submit a request through our Help Center.

13.10 Verification

We will verify your identity by matching information you provide with information we have on file. For deletion requests, we may require additional verification.

13.11 Financial Incentives

We do not offer financial incentives for the collection, sale, or deletion of personal information.

14. European Privacy Rights (GDPR)

14.1 Applicability

This section applies to individuals in the European Economic Area (EEA), United Kingdom (UK), and Switzerland, and supplements the rest of this Privacy Policy.

14.2 Data Controller

For purposes of the General Data Protection Regulation (GDPR) and equivalent laws, Interleave is the data controller of your personal information.

14.3 Your Rights Under GDPR

You have the following rights under the GDPR:

(a) Right of Access (Article 15): You have the right to obtain confirmation of whether we process your personal data and, if so, access to that data and information about the processing;

(b) Right to Rectification (Article 16): You have the right to obtain rectification of inaccurate personal data and to have incomplete data completed;

(c) Right to Erasure (Article 17): You have the right to obtain erasure of your personal data in certain circumstances (the "right to be forgotten");

(d) Right to Restriction (Article 18): You have the right to obtain restriction of processing in certain circumstances;

(e) Right to Data Portability (Article 20): You have the right to receive your personal data in a structured, commonly used, machine-readable format and to transmit it to another controller;

(f) Right to Object (Article 21): You have the right to object to processing based on legitimate interests, including profiling, and to processing for direct marketing purposes;

(g) Rights Related to Automated Decision-Making (Article 22): You have the right not to be subject to decisions based solely on automated processing that produce legal or similarly significant effects, with certain exceptions;

(h) Right to Withdraw Consent: Where processing is based on consent, you have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before withdrawal;

(i) Right to Lodge a Complaint: You have the right to lodge a complaint with a supervisory authority in your country of residence.

14.4 Exercising Your Rights

To exercise your GDPR rights, contact us at privacy@interleave.love. We will respond within one month, which may be extended by two additional months if necessary, taking into account the complexity and number of requests.

14.5 Supervisory Authorities

If you are located in the EEA, UK, or Switzerland, you have the right to lodge a complaint with your local supervisory authority. A list of EEA supervisory authorities is available at: https://edpb.europa.eu/about-edpb/board/members_en

14.6 Data Protection Officer

You may contact our data protection team at: dpo@interleave.love

15. Other State and Regional Privacy Rights

15.1 Virginia (VCDPA)

Virginia residents have rights similar to those described in Section 13 (CCPA/CPRA), including the rights to access, correct, delete, obtain a copy of, and opt out of targeted advertising and the sale of personal data.

15.2 Colorado (CPA)

Colorado residents have rights similar to those described in Section 13, including the rights to access, correct, delete, obtain a copy of, and opt out of targeted advertising, the sale of personal data, and profiling.

15.3 Connecticut (CTDPA)

Connecticut residents have rights similar to those described in Section 13, including the rights to access, correct, delete, obtain a copy of, and opt out of targeted advertising, the sale of personal data, and profiling.

15.4 Utah (UCPA)

Utah residents have the rights to access, delete, and obtain a copy of their personal data, and to opt out of the sale of personal data and targeted advertising.

15.5 Other Jurisdictions

If you reside in a jurisdiction with privacy laws that grant you specific rights not addressed in this Policy, please contact us at privacy@interleave.love, and we will work with you to honor your rights under applicable law.

15.6 Canada (PIPEDA)

Canadian residents have the right to access their personal information, request correction of inaccurate information, and withdraw consent to the collection, use, or disclosure of their personal information.

15.7 Brazil (LGPD)

Brazilian residents have rights similar to those under GDPR, including access, correction, deletion, portability, and the right to information about sharing with third parties.

15.8 Australia (Privacy Act)

Australian residents have rights to access and correct their personal information and to complain about privacy breaches to the Office of the Australian Information Commissioner.

16. Changes to This Privacy Policy

16.1 Updates

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or other factors. When we make material changes, we will:

(a) Update the "Last Updated" date at the top of this Policy;

(b) Post the updated Policy on our website and within the Services;

(c) Notify you by email or through in-app notification (for material changes).

16.2 Review

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your personal information.

16.3 Continued Use

Your continued use of the Services after any changes to this Privacy Policy constitutes your acceptance of the updated Policy. If you do not agree to the updated Policy, you should stop using the Services and delete your account.

17. Contact Us

If you have any questions, concerns, or complaints about this Privacy Policy or our privacy practices, please contact us at:

Interleave

Privacy Team

Email Contacts:

• Privacy Inquiries: privacy@interleave.love
• Data Protection Officer: dpo@interleave.love
• General Support: support@interleave.love
• Security Issues: security@interleave.love

Data Subject Requests:

To exercise your privacy rights, please email privacy@interleave.love or submit a request through the Help section in the Interleave application.

Response Time:

We aim to respond to all privacy-related inquiries within 30 days. For complex requests, we may require additional time and will keep you informed of our progress.

Acknowledgment

BY USING THE SERVICES, YOU ACKNOWLEDGE THAT YOU HAVE READ THIS PRIVACY POLICY, UNDERSTAND IT, AND AGREE TO ITS TERMS AND CONDITIONS.

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