Privacy Policy

1. Introduction

Upfront Marital Technologies Inc. ("Upfront") is committed to maintaining the privacy, transparency, and digital dignity of all platform users. This Privacy Policy outlines how we collect, use, protect, and share your personal data. It reflects our adherence to global privacy standards including the California Consumer Privacy Act (CCPA/CPRA), the General Data Protection Regulation (GDPR), ISO/IEC 27701, and additional U.S. privacy frameworks.

As a purpose-driven platform designed around cultural authenticity, Upfront approaches data privacy as a human right. We believe trust is built through disclosure, accountability, and ethical innovation in how we handle your data.

2. Information We Collect

We collect personal data to provide and enhance our services. This includes:

• Personal Identifiers: Name, email address, phone number, gender identity, and user preferences.
• AI-Generated Metadata: Compatibility data, behavioral metrics, and language model interactions from proprietary features like Langston and Zora.
• Device & Session Data: IP address, browser type, geolocation, session timestamps, and unique device identifiers.
• Payment Information: Financial transactions are processed securely via Stripe. We do not store your credit card numbers.
• Voluntary Communications: Feedback, support queries, and survey responses.

3. How We Use Information

The data collected allows us to:

• Operate, secure, and troubleshoot the Upfront platform and services.
• Personalize your user experience through dynamic AI-driven recommendations.
• Conduct analytics and trend monitoring to improve service quality.
• Enforce platform rules, detect fraud, and address harmful behavior.
• Comply with legal obligations, such as preventing money laundering or identity misuse.

All data processing is performed under lawful bases defined under Article 6(1) of the GDPR, including user consent, contractual necessity, and legitimate interests. CPRA §1798.100 compliance is also maintained.

4. Cookies and Tracking

We utilize cookies and similar technologies to:

• Maintain secure sessions and keep you logged in across devices.
• Support Stripe's payment and verification features.
• Understand usage patterns through first-party analytics.

Third-party cookies may also be employed (e.g., Google Analytics), and users are offered cookie opt-out banners where required by law.

5. User Rights and Choices

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

• Access: Request a copy of your personal data.
• Deletion: Request deletion of your personal information (subject to legal retention requirements).
• Correction: Amend or complete inaccurate data.
• Restriction: Limit how your data is processed.
• Portability: Obtain your data in a structured, machine-readable format.
• Opt-Out: Withdraw consent or object to profiling and third-party data sharing.

Users are entitled to exercise these rights through our dedicated privacy portal or by emailing legal@upfrontmarriage.com. We honor opt-out preferences, including GPC (Global Privacy Control) signals where technically feasible.

6. Data Retention

Upfront retains data only as long as necessary for the purposes outlined in this policy. Our default retention schedule is:

• User profiles and activity: 5 years post-account deletion.
• Payment records: 7 years, per IRS requirements.
• AI-generated interactions: 12 months for performance tuning and compliance review.

We adhere to ISO/IEC 27701 retention controls and map all data flows in accordance with GDPR Article 30 Records of Processing Activities (RoPA).

7. Sharing and Disclosure

We do not sell your personal data. We may share information under these conditions:

• With third-party processors like Stripe for secure payment transactions.
• With hosting and analytics vendors under strict data protection agreements.
• With regulators or legal entities upon lawful request.

We maintain Data Processing Agreements (DPAs) with all third-party vendors and conduct annual reviews of risk classification and sub-processor inventories.

8. Children's Privacy

Upfront does not knowingly collect data from children under the age of 13. Our platform is intended for adults seeking meaningful relationships. If we discover that we have inadvertently collected such data, we will promptly delete it. Parents may contact us to request deletion via legal@upfrontmarriage.com.

9. Data Security

Upfront uses enterprise-grade security controls, including:

• TLS/SSL encryption for data in transit
• AES-256 encryption for sensitive data at rest
• Role-based access controls and multi-factor authentication (MFA)
• Third-party penetration testing and SOC 2-aligned protocols
• Secure development lifecycle (SDLC) reviews and anomaly detection

Security standards align with ISO/IEC 27001 and include zero-trust architecture across cloud and edge environments.

10. International Data Transfers

For users outside the United States, your information may be transferred to and processed in the U.S. or other jurisdictions. We use:

• Standard Contractual Clauses (SCCs)
• Vendor data protection assessments (RoPAs)
• Regulatory alignment with GDPR Article 46 mechanisms

We aim to maintain adequacy protections where applicable.

11. AI Personalization Transparency

Your interactions with Langston and Zora may inform curated match suggestions, in-app journaling, or tailored prompts. These features support platform personalization, but Upfront Marital Technologies Inc. does not engage in fully automated decision-making that produces legal or similarly significant effects on users.

12. Consent for LinkedIn and AI Interactions

When registering via LinkedIn, you authorize us to access your profile name, photo, and headline to help verify and enrich your platform profile. By using the service, you also consent to personalization through artificial intelligence systems including Langston and Zora.

13. Voice Data and Biometric Privacy

Voice interactions on the platform are recorded and retained for 30 days to support service quality, personalization, and user continuity. Transcripts of these sessions are securely stored as part of user data and function similarly to in-app messages or journal entries. This ensures that follow-up AI coaching by Langston and Zora reflects prior context and engagement history. Upfront does not use voice recordings to train future AI models, nor are voiceprints or biometric identifiers collected. These practices are aligned with GDPR Article 5(1)(b) (purpose limitation), ISO/IEC 27701, and U.S. state-level biometric privacy laws such as BIPA (Illinois) and CPRA (California).

14. Purpose Table for Data Transparency

15. Cookie Preferences and Tracking Controls

Users may revisit or adjust their cookie preferences at any time through browser settings or in-app tools. Where required by law, a cookie consent banner is provided during onboarding to capture initial consent. We honor user preferences in accordance with GDPR, CPRA, and related privacy regulations.

16. Impact of Personalization Opt-Out

Opting out of personalization features may result in reduced match relevance, milestone accuracy, or content targeting. The platform may still function, but core benefits may be limited.

17. Third-Party Vendor Disclosure

We share data only with service providers under strict confidentiality agreements. These include:

• Stripe for payment processing
• Firebase by Google for authentication and infrastructure
• Mailchimp for user communication
• Gemini and Play.ai for AI-enhanced services and journaling

All third parties comply with applicable privacy and security standards.

Contact Information

For privacy-related questions, requests, or concerns, contact:

Upfront Marital Technologies Inc.

Email: legal@upfrontmarriage.com