COMEAROUND

PRIVACY POLICY

Effective Date: July 28, 2026

Operated by VERIX LABS

Ontario, Canada — Serving Users in Canada and the United States

www.comearound.app

This Privacy Policy explains how VERIX LABS (“we,” “us,” or “our”) collects, uses, discloses, and protects information in connection with the ComeAround website (www.comearound.app), mobile application, and related services (collectively, the “Service”). This Policy should be read together with our Terms of Use.

BY CREATING AN ACCOUNT OR OTHERWISE USING THE SERVICE, YOU ACKNOWLEDGE THAT YOU HAVE READ AND UNDERSTOOD THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH THIS POLICY, PLEASE DO NOT USE THE SERVICE.

Section 7 explains how live location and “Available Now” data is handled. Section 9 explains our approach to biometric information. Section 17 explains your privacy rights, including specific rights for Canadian and U.S. residents.

1. SCOPE OF THIS POLICY

1.1 This Policy applies to information collected through the Service, including when you create an Account, build a profile, use messaging or matching features, enable location-based features, make a purchase, or otherwise interact with ComeAround.

1.2 This Policy does not apply to third-party websites, applications, or services that may be linked from the Service, or to information you choose to share directly with other Users, which is governed by those Users’ own practices.

2. INFORMATION YOU PROVIDE TO US

2.1 Account and Profile Information. When you register and build your profile, you may provide your name, date of birth, gender and gender preferences, email address, phone number, city or general location, photographs, a bio or description, interests, and dating or hangout preferences.

2.2 Verification Information. If you complete identity or photo verification, you may provide a government-issued ID and a real-time photograph or video (such as a selfie) for comparison against your profile photos, as described in Section 8.

2.3 Messages and Content. We collect the content of messages, photos, and other material you send through the Service, and any content you post to your profile or within a Group Meetup listing.

2.4 Payment Information. If you purchase Premium Services, your payment will be processed by the Apple App Store, Google Play Store, or a third-party payment processor we engage for that purpose. We do not directly collect or store your full payment card number; the applicable platform or processor handles that information under its own privacy policy.

2.5 Communications. If you contact us for support or otherwise communicate with us, we collect the information you provide in that communication.

3. INFORMATION WE COLLECT AUTOMATICALLY

3.1 Device and Usage Information. We automatically collect certain information about the device and browser you use to access the Service, including device identifiers, operating system, app version, IP address, and general usage information such as features used and interactions within the App.

3.2 Location Information. With your permission, we collect approximate or precise location information from your device, including for nearby-User matching, live location, and “Available Now” features. See Section 7 for details.

3.3 Cookies and Similar Technologies. Our website may use cookies and similar technologies to keep you logged in, remember preferences, and understand how the website is used. See Section 9 for details. We do not currently use advertising cookies, advertising identifiers, or third-party ad-tracking technologies.

4. INFORMATION FROM THIRD PARTIES

4.1 Sign-In Services. If you register or sign in using Apple, Google, or another third-party account, that provider may share certain profile information with us (such as your name and email address), as permitted by your settings with that provider.

4.2 Verification Providers. If we use a third-party identity or photo verification provider, we may receive confirmation of your verification status, and limited related information, from that provider.

4.3 Other Users. Other Users may provide information about you, such as through a report, block, or Group Meetup interaction.

5. HOW WE USE YOUR INFORMATION

5.1 We use the information we collect to:

• Create and maintain your Account and profile;
• Operate core features, including matching, messaging, and Group Meetups;
• Provide location-based features, including nearby matching, live location, and “Available Now”;
• Verify your identity and age, and detect fake or duplicate Accounts;
• Process payments and manage subscriptions;
• Maintain the safety, security, and integrity of the Service, including investigating reports and preventing fraud or abuse;
• Provide customer support and respond to your requests;
• Send Service-related communications, and, where you have consented, marketing communications;
• Improve and develop the Service; and
• Comply with applicable law, and establish, exercise, or defend legal claims.

6. HOW WE SHARE YOUR INFORMATION

6.1 With Other Users. Your profile information, including your photos, bio, and general location, is visible to other Users as part of the core functionality of the Service. If you enable live location or “Available Now,” your approximate real-time location and availability may be visible to nearby Users while that feature is active, as described in Section 7.

6.2 With Service Providers. We share information with service providers who perform services on our behalf, including our backend infrastructure and database provider (Supabase), identity and photo verification providers, payment processors, cloud hosting providers, and customer support tools. These providers are authorized to use your information only as necessary to provide services to us.

6.3 For Legal and Safety Reasons. We may access, preserve, and disclose information where we believe in good faith it is necessary to comply with a legal obligation, protect the rights, property, or safety of VERIX LABS, our Users, or the public, investigate fraud or security issues, or respond to a valid legal request from law enforcement or other authorities.

6.4 Business Transfers. If VERIX LABS is involved in a merger, acquisition, financing, reorganization, or sale of assets, information may be transferred as part of that transaction, subject to this Policy or a successor policy.

6.5 Aggregated or De-Identified Data. We may share aggregated or de-identified information that cannot reasonably be used to identify you, for research, analytics, or business purposes.

6.6 With Your Consent. We may share information for other purposes with your consent.

WE DO NOT SELL YOUR PERSONAL INFORMATION FOR MONEY, AND WE DO NOT CURRENTLY SHARE YOUR PERSONAL INFORMATION WITH THIRD-PARTY ADVERTISERS.

7. LOCATION INFORMATION, LIVE LOCATION, AND “AVAILABLE NOW”

7.1 We use location information to power nearby-User discovery. You can grant or deny location permission through your device settings; denying it may limit certain features.

7.2 Live Location. When a live-location feature is active (for example, while browsing nearby Users or during an active Group Meetup), your approximate real-time location may be visible to other Users for the duration that the feature is active. You may disable live location sharing at any time in the App settings, except where continued sharing is necessary to complete an in-progress session.

7.3 “Available Now.” Activating “Available Now” shares your approximate location and availability with nearby Users for a limited period that you control. This feature is voluntary and can be turned off at any time.

7.4 Location data is processed through our backend and database provider (Supabase) and is retained only as long as necessary to provide these features and for the retention periods described in Section 12, after which it is deleted or de-identified.

8. DEVICE PERMISSIONS

8.1 Depending on the features you use, the App may request permission to access: (a) your device’s location (for nearby matching, live location, and “Available Now”); (b) your camera and photo library (to upload profile photos and complete photo verification); and (c) push notification permissions (to send you Match, message, and safety alerts).

8.2 You control these permissions through your device settings and may deny or revoke them at any time. Denying a permission may limit or disable the related feature, as described elsewhere in this Policy.

9. IDENTITY AND PHOTO VERIFICATION; BIOMETRIC INFORMATION

9.1 If you complete identity or photo verification, the government ID image and verification photo or video you provide are used solely to confirm your identity and age and to help confirm that your profile accurately represents you.

9.2 We do not currently use automated facial recognition or biometric matching technology to process verification photos. If we adopt a verification method that involves biometric identifiers, such as facial geometry matching, we will update this Policy before doing so, and will provide any notice, consent, and retention disclosures required by applicable law, including Illinois’ Biometric Information Privacy Act (BIPA) and comparable laws in other states.

9.3 This information is treated as sensitive and is processed only for verification purposes. We do not display your government ID to other Users, and verification images are retained only as long as necessary to complete and support the verification process, after which they are deleted, unless a longer period is required by law or to investigate suspected fraud.

10. AI AND AUTOMATED PROCESSING

10.1 ComeAround does not currently use artificial intelligence or machine learning to generate matches, rank profiles, moderate content, or create conversation prompts. Any matching or discovery features currently rely on basic filters and criteria you provide (such as location, age range, and preferences), not automated profiling.

10.2 If we introduce AI-assisted or automated-decision features in the future, we will update this Policy and, where required by applicable law, provide additional notice and any applicable rights, such as the ability to request human review of a significant automated decision.

11. COOKIES AND TRACKING TECHNOLOGIES

11.1 Our website may use cookies and similar technologies to enable core functionality, keep you signed in, and understand aggregate usage of the website. We do not currently use these technologies for third-party advertising.

11.2 You can control cookies through your browser settings; disabling cookies may affect the functionality of our website. The mobile App does not use browser cookies; any device identifiers used are described in Section 3.1 and Section 8.

12. THIRD-PARTY INTEGRATIONS

12.1 The Service currently integrates with the following categories of third-party providers, each of which processes information only as necessary to provide services to us:

• Backend infrastructure and database hosting (Supabase);
• Apple and Google account sign-in services, if you choose to register or log in that way;
• Identity and photo verification providers, once selected, as described in Section 9;
• Payment processors for Premium Services, once selected, as described in Section 2.4;
• App distribution platforms (the Apple App Store and Google Play Store), which have their own privacy policies governing information they collect.

12.2 We will update this Policy to name specific providers as they are finalized. We do not currently integrate with any advertising, marketing, or social-media data-sharing platforms.

13. INTERNATIONAL DATA TRANSFERS

13.1 VERIX LABS is based in Ontario, Canada, and serves Users in both Canada and the United States. Your information may be collected, stored, and processed in Canada, the United States, or other countries where our service providers operate, which may have data protection laws different from those in your jurisdiction.

13.2 Where required by applicable law, we take steps intended to provide an appropriate level of protection for information transferred internationally, such as through contractual safeguards with our service providers.

14. CHILDREN’S PRIVACY

14.1 The Service is not directed to, and must not be used by, anyone under 18 years of age. We do not knowingly collect personal information from anyone under 18.

14.2 If we learn that we have collected personal information from a person under 18, we will take steps to delete that information and terminate the associated Account. If you believe a person under 18 has provided us with personal information, please contact us at support@comearound.app.

15. DATA RETENTION

15.1 We retain personal information for as long as necessary to provide the Service, comply with our legal obligations, resolve disputes, enforce our agreements, and support safety and fraud-prevention efforts.

15.2 Retention periods vary by data type: profile and Account information is retained while your Account is active; verification images are retained only as described in Section 9.3; messages are retained while your Account is active and for a limited period after deletion to support safety investigations; and location history is retained only briefly to support live-location and “Available Now” features before deletion or de-identification.

16. ACCOUNT DELETION

16.1 You may delete your Account at any time from within the App (Settings > Delete Account) or by emailing support@comearound.app.

16.2 Upon deletion, your profile is immediately removed from view by other Users, and we will delete or de-identify your personal information within a reasonable period, except where we are required or permitted to retain certain information for longer, such as records needed to investigate a safety report, comply with tax or accounting obligations, or resolve a legal dispute, as described in Section 15.

16.3 Messages you sent to other Users may remain visible to the recipient after you delete your Account, as they form part of the recipient’s own message history.

17. YOUR PRIVACY RIGHTS

17.1 Canadian Users

17.1 If you are located in Canada, applicable privacy law, including the Personal Information Protection and Electronic Documents Act (PIPEDA), gives you the right to access the personal information we hold about you, request correction of inaccurate information, and withdraw consent to certain uses, subject to legal and contractual restrictions. If you have concerns about how we handle your information, you may also contact the Office of the Privacy Commissioner of Canada.

17.2 U.S. Residents

17.2 If you are a resident of a U.S. state with a comprehensive privacy law — including California, Virginia, Colorado, Connecticut, Utah, Texas, and other states with similar laws — you may have the right to: (a) know and access the personal information we hold about you; (b) request deletion of your personal information; (c) request correction of inaccurate personal information; (d) opt out of the sale or sharing of personal information (we do not currently sell or share personal information as defined under these laws); (e) limit the use of sensitive personal information; and (f) not be discriminated against for exercising these rights.

17.3 EU/UK Users

17.3 The Service is currently offered only to Users located in Canada and the United States and is not directed to residents of the European Union or United Kingdom. Accordingly, the EU General Data Protection Regulation (GDPR) and UK GDPR do not currently apply to our processing. If we expand the Service to EU or UK Users, we will update this Policy to reflect the additional rights and obligations that would apply.

17.4 Exercising Your Rights

17.4 You may exercise these rights by contacting us at support@comearound.app. We may need to verify your identity before completing your request, and we will respond within the timeframe required by applicable law. You may also update or delete much of your profile information directly within the App.

18. MARKETING COMMUNICATIONS AND NOTIFICATIONS

18.1 We may send you Service-related communications (such as safety alerts, verification confirmations, and billing notices) that are necessary to the operation of your Account.

18.2 With your consent, where required by applicable law such as Canada’s Anti-Spam Legislation (CASL), we may also send marketing communications. You may opt out of marketing communications at any time using the unsubscribe link in the message, through your App notification settings, or by contacting support@comearound.app.

19. DATA SECURITY

19.1 We use reasonable technical and organizational safeguards designed to protect your information from unauthorized access, use, alteration, or disclosure. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

19.2 You play an important role in protecting your own information by keeping your Account credentials confidential and notifying us promptly of any suspected unauthorized access, as described in our Terms of Use.

20. THIRD-PARTY LINKS AND SERVICES

20.1 The Service may contain links to third-party websites or services that are not owned or controlled by VERIX LABS. This Policy does not apply to those third parties, and we encourage you to review their privacy policies before providing them with information.

21. CHANGES TO THIS POLICY

21.1 We may update this Policy from time to time. If we make material changes, we will update the “Effective Date” on the cover page and, where required by applicable law, provide additional notice, such as an in-app notice or an email.

21.2 Your continued use of the Service after changes take effect constitutes your acceptance of the revised Policy.

22. CONTACT US

If you have questions, concerns, or requests regarding this Privacy Policy or your personal information, please contact us at:

VERIX LABS

Email: support@comearound.app

Website: www.comearound.app