Privacy Policy
Version 1.4
This Privacy Policy explains how Prosperous Pairs collects, uses, discloses, stores, transfers, and protects personal information through ProsperousPairs.com, any related application, application and membership process, matchmaking and introduction services, communications, events or hosted experiences, relationship education, and related services (collectively, the “Services”).
“Prosperous Pairs,” “we,” “us,” and “our” mean the operator of ProsperousPairs.com and the personal information controller, business, or responsible organization for the processing described in this Policy unless another notice identifies a different entity.
1. Scope
This Policy applies to website visitors, applicants, members, prospective members, event or travel participants, people who communicate with us, and individuals whose information is processed for an approved safety, fraud-prevention, legal-compliance, or contact-release purpose.
Prosperous Pairs serves or may serve people in the United States, the Philippines, Singapore, and other approved countries. Because the Services support international applications and matching, personal information may be collected in one country and processed, reviewed, stored, or disclosed in another.
Country- or state-specific privacy notices may supplement this Policy. Where applicable law provides stronger or non-waivable rights, that law controls.
2. Information we collect
Depending on the Services used and the person’s jurisdiction, we may collect the following categories.
Account and contact information
- name, display name, email address, telephone number, password hash, account identifiers, authentication records, and communication preferences;
- country, city, region, state or province, postal code, residence information, and acquisition source; and
- account, application, approval, membership, suspension, ban, and eligibility status.
Application, profile, and relationship information
- date of birth, age, sex, the sex or characteristics of a partner sought, relationship goals, relationship status, family and children information, relocation outlook, occupation, education, religion or spirituality, lifestyle information, biography, and responses to relationship or compatibility questionnaires;
- preferred language, additional conversational languages, profile and visibility settings, geographic preferences, and country-flow locale; and
- photographs, profile images, audio or video submitted for verification or introductions, crop and focal settings, moderation status, and related file metadata.
Identity, age, safety, and legal-compliance information
Where an approved process applies, this may include:
- legal name, aliases or former names, date of birth, government proof of age or identity, document type, issuing jurisdiction, receipt date, registration state or ZIP code, and residence history;
- separately accepted Background & Safety Screening Authorization records;
- applicant-provided certifications, attestations, marital history, prior sponsorship information, restraining/protection-order information, criminal-history information, or other background information where legally required or voluntarily provided for an approved process;
- public safety registry search status, source references, review notes, possible-match verification, decision status, reviewer identity, and audit records;
- jurisdiction acknowledgments, government pamphlet delivery, primary-language disclosure records, specific-client contact-release consent, and international compliance-gate status; and
- reports or supporting documents voluntarily provided or lawfully required for a safety, fraud, or legal-compliance review.
We do not intentionally include protected victim-identifying information in a member-facing contact-release packet where disclosure is prohibited.
Membership, promotion, and payment information
- selected plan, billing cadence, membership status, commitment and renewal dates, cancellation or plan-change requests, and service history;
- payment-processor customer, payment-method, transaction, invoice, subscription, dispute, and webhook identifiers; masked card information such as card brand and last four digits; and payment or reconciliation status; and
- coupon or Community Access code use, promotion eligibility, calculation snapshots, redemption, grants, sponsorship decisions, benefit dates, grace periods, notice delivery, and related audit events.
Raw payment-card numbers and CVV should be handled directly by the payment processor and are not intended to be stored by Prosperous Pairs.
Communications, appointments, events, and support
- messages sent to staff, support requests, administrative communications, email delivery events, appointment or interview booking metadata, meeting links, event or travel inquiries, and records of action taken;
- reports of suspected fraud, abuse, trafficking, exploitation, safety issues, or policy violations and related review records; and
- event registration, travel-preference, eligibility, logistics, emergency-contact, and vendor information where needed for a separately offered experience.
Technical, security, cookie, and anti-abuse information
- IP address, browser and device information, timestamps, session and CSRF data, authentication events, security events, rate-limit data, error references, anti-bot tokens and results, consent timestamps, and audit logs; and
- cookies, local storage, SDK data, or similar technologies used for session management, preferences, security, forms, analytics, attribution, or other disclosed purposes.
3. Sensitive and highly sensitive information
Matchmaking and safety information can reveal highly sensitive matters, including sex or sexual-life information, sexual orientation, religious or philosophical beliefs, relationship status, government identifiers, immigration or citizenship information, precise location, alleged or established offenses, safety records, and recordings.
We process sensitive information only for specific, disclosed, and legitimate purposes and only where an applicable legal condition permits the processing. Where a law requires explicit or specific consent, that consent will be requested separately and will not be inferred merely from accepting this Privacy Policy.
Providing optional profile information is voluntary unless a field is clearly identified as necessary for eligibility, safety, legal compliance, or the Service requested.
Prosperous Pairs does not currently represent that it uses facial recognition or biometric identification. A biometric identification, liveness, voiceprint, facial-template, or similar technology will not be activated without a separate legal, privacy, security, vendor, retention, and consent review where required.
4. Sources of information
We may obtain information:
- directly from you;
- from activity within the Services, including forms, account actions, purchases, communications, and consent records;
- from other users who submit a safety, fraud, abuse, or conduct report;
- from payment, email, appointment, video-meeting, hosting, storage, security, anti-bot, analytics, or other operational providers;
- from approved government or public sources when an authorized safety or legal-compliance process applies; and
- from an approved screening or verification provider only after its legal basis, contracts, data controls, and separate authorization process have been approved.
We do not authorize unlawful scraping, pretexting, circumvention of access controls, or acquisition of unrelated private information through a screening process.
5. Why we use information
We may use personal information to:
- create, authenticate, secure, administer, and support accounts;
- receive and continue applications, verify age or identity, conduct interviews, and perform human review;
- build and moderate profiles, apply visibility choices, enable browsing or eligible messaging, and facilitate lawful matchmaking or introductions;
- administer questionnaires, relationship education, and disclosed compatibility functions;
- communicate with applicants and members, schedule appointments, deliver service messages, and respond to requests;
- process memberships, payments, renewals, cancellations, refunds, promotions, grants, Community Access benefits, and sponsorships;
- review identity consistency, prevent fraud and abuse, investigate safety reports, prevent ban evasion, and enforce the Terms;
- satisfy approved screening, public-registry, age, jurisdiction, primary-language, contact-release, IMBRA, or other international compliance requirements;
- operate, troubleshoot, secure, measure, and improve the Services;
- comply with tax, accounting, recordkeeping, court, regulator, law-enforcement, or other legal obligations; and
- establish, exercise, or defend legal claims.
We do not use payment status, country, sex, membership tier, promotion status, or another user’s interest to infer consent to release a person’s private contact information.
6. Legal grounds for processing
The legal basis depends on the jurisdiction and purpose. Where required, we rely on one or more of the following:
- Consent: for processing that requires freely given, specific, informed, and revocable agreement, including certain sensitive-data, marketing, cookie, visibility, contact-release, screening, or AI uses;
- Steps requested before a contract and performance of a contract: to process an application, create an account, provide purchased Services, administer memberships, and process billing;
- Legal obligation: to satisfy applicable safety, consumer, tax, accounting, recordkeeping, privacy, court, and international contact-release requirements;
- Legitimate interests: to operate and secure the Services, conduct proportionate human review, prevent fraud and abuse, maintain audit evidence, communicate about the Services, and protect users, where those interests are not overridden by the individual’s rights; and
- Vital interests or public safety: in limited circumstances involving a credible and urgent threat, where applicable law permits.
For EEA or UK users, a lawful basis under ordinary data-protection rules does not by itself authorize processing of special-category information or criminal-offense data. We will identify an additional lawful condition and safeguards where those rules apply.
For Philippine data subjects, sensitive personal information will be processed only under a condition permitted by the Philippine Data Privacy Act and applicable National Privacy Commission rules.
For Singapore individuals, we will follow the applicable PDPA rules on notification, consent, exceptions, purpose limitation, and related obligations.
7. Profile visibility and disclosure to other users
Private application data, approved member-directory information, and public-preview information are separate.
We display only information authorized for the relevant surface and allowed by account status, membership, visibility choices, moderation, safety controls, contact-release rules, and applicable law.
Private contact information and private application answers are not placed in a general member directory unless a specifically disclosed feature and valid authorization permit it.
A person receiving browse-only access does not thereby receive messaging, personal-contact, curated-introduction, or in-person-meeting rights.
You may change available visibility settings or request correction of profile information, subject to moderation, legal holds, fraud-ban records, and records that must lawfully be preserved.
8. International matching and IMBRA-related processing
Where IMBRA or another contact-release law applies, we may process and disclose legally required U.S.-client background materials to the relevant foreign national client before personal contact information is released or an in-person meeting is facilitated. Any reliance on an IMBRA statutory exception must be based on a documented compliance classification of the actual workflow rather than inferred from acceptance of this Policy.
Depending on the applicable requirement, the process may include:
- proof-of-age or identity records;
- an approved search of the National Sex Offender Public Website or another legally required source;
- a U.S. client’s signed certification and required background information;
- records retrieved from the required search or documentation that no record was found;
- a government pamphlet or other required information;
- proof that required material was delivered in the foreign national client’s primary language; and
- the foreign national client’s specific written consent to release personal contact information to the identified U.S. client.
We will not disclose protected victim-identifying information where law prohibits it. Contact-release consent is limited to the identified person and purpose and is not consent to a date, relationship, marriage, travel, immigration sponsorship, sexual activity, or further disclosure.
If the applicable legal process is incomplete, the relevant contact release or in-person facilitation remains blocked.
9. When we disclose information
We may disclose limited information to:
- authorized personnel, including staff, administrators, matchmakers, compliance reviewers, and approved professional reviewers according to role and need;
- other eligible users, only for profile, introduction, messaging, or contact information that the relevant person has authorized and that applicable law permits;
- operational service providers, such as hosting, storage, email, payment, appointment, video-meeting, anti-bot, security, analytics, and technical providers;
- government or public sources and approved compliance reviewers, when conducting a permitted safety, identity, or legal review;
- professional advisers, including lawyers, auditors, accountants, insurers, and consultants bound by appropriate duties;
- authorities or affected parties, when reasonably necessary to comply with law, respond to valid legal process, protect a person, investigate fraud or abuse, enforce agreements, or respond to a security incident; and
- a successor organization, in connection with a proposed or completed merger, financing, reorganization, sale, or transfer of the Services, subject to applicable confidentiality and notice requirements.
Prosperous Pairs does not sell personal information for money. Some privacy laws define “sale,” “sharing,” or “targeted advertising” more broadly than an exchange for money. If Prosperous Pairs enables advertising, cross-context behavioral advertising, or other technology that creates an opt-out right under applicable law, we will provide the required notice and opt-out mechanism.
We do not intentionally disclose private application answers, assessment reports, raw payment-card data, private staff communications, or private recordings to the general public.
10. Service providers and subprocessors
Depending on the enabled feature, providers may include:
- payment processors such as Square or another provider identified at checkout;
- Google services used for appointment booking, video meetings, anti-bot protection, or other disclosed functions;
- email delivery infrastructure;
- hosting, database, storage, backup, security, monitoring, analytics, and infrastructure providers; and
- an AI, identity, or screening provider only after the provider, configuration, data controls, contract, legal basis, notice, and any required separate consent have been approved.
Service providers are expected to process information only for the contracted or disclosed purpose and to protect it appropriately.
11. Cookies, analytics, and similar technologies
We may use:
- strictly necessary technologies for authentication, sessions, security, fraud prevention, preferences, and forms;
- functional technologies for optional site features and remembered choices;
- analytics technologies to understand site and feature performance; and
- advertising or attribution technologies only if enabled and lawfully configured.
Where applicable law requires prior consent for non-essential cookies, SDKs, local storage, or similar technologies, those technologies should remain disabled until the required consent is obtained.
Where available, you may change non-essential tracking choices through the site’s cookie or privacy settings. Browser controls can also restrict some technologies, but disabling necessary technologies may prevent parts of the Services from working.
12. AI, profiling, automated decisions, and translation
AI execution, chat-language analysis, behavioral learning, or automated relationship assessment will not be treated as authorized merely because a person accepts this Policy.
If an AI-assisted relationship, moderation, translation, or safety feature is enabled, we will disclose the relevant purpose, data categories, provider role, material limitations, and any required consent or right to object, access, correct, challenge, or request human review.
We do not represent AI output as a medical or psychiatric diagnosis, a guarantee of compatibility, or proof of identity or safety.
Prosperous Pairs will not use member information to train a general-purpose Prosperous Pairs model unless that use is separately disclosed and lawfully authorized.
13. International transfers
Information may be processed in the United States and in other countries where approved service providers or authorized reviewers operate. Those countries may have privacy laws different from the person’s home jurisdiction.
For personal information originating in the Philippines, Prosperous Pairs remains accountable for personal information transferred domestically or internationally and will use contractual, organizational, technical, or other reasonable measures intended to provide the protection required by Philippine law.
For personal data transferred outside Singapore, Prosperous Pairs will use measures intended to ensure a standard of protection comparable to the Singapore PDPA unless a lawful exception applies.
If Prosperous Pairs offers Services subject to the EEA GDPR, international transfers will rely on a lawful mechanism such as an adequacy decision, applicable Standard Contractual Clauses, or another valid transfer mechanism. Participation in the EU-U.S. Data Privacy Framework will be claimed only if the relevant recipient is actually certified and covered.
If Prosperous Pairs offers Services subject to UK data-protection law, international transfers will use an applicable UK adequacy mechanism, approved transfer agreement or addendum, or another lawful safeguard.
Where required, Prosperous Pairs will conduct transfer-risk assessments and maintain appropriate processor or data-transfer contracts.
14. Security
We use administrative, technical, and physical safeguards designed for the nature and sensitivity of the information. Depending on the system, safeguards may include role-based access, password hashing, protected connections, session and CSRF controls, anti-abuse throttling, restricted media delivery, logging, backups, vendor controls, and separation of payment-card handling from Prosperous Pairs systems.
No system can be guaranteed completely secure. Security statements in this Policy describe controls we actually implement or require and should not be read as a guarantee against every incident.
15. Personal-data breaches
If a personal-data breach occurs, we will investigate, contain, document, and assess it and will notify affected individuals, regulators, service providers, insurers, or other parties when applicable law or contract requires notification.
Because notification standards and deadlines vary by jurisdiction, Prosperous Pairs uses an incident-response process designed to escalate potentially reportable incidents promptly. For example, where Singapore’s PDPA applies and a breach is determined to be notifiable, notification to the Personal Data Protection Commission will be made as soon as practicable and no later than the statutory deadline following that determination, and affected individuals will be notified where required. Philippine, U.S. state, EEA, UK, and other breach rules will be applied according to the affected data, residents, scale, risk, and governing law.
16. Retention and deletion
We retain information only as long as reasonably necessary for the disclosed purpose, an active account or contract, safety and fraud prevention, billing and tax records, dispute resolution, audit integrity, legal compliance, or the establishment, exercise, or defense of legal claims. A shorter mandatory deletion rule always controls over a longer internal target.
Our target retention architecture is:
| Record category | Target retention rule |
|---|---|
| Abandoned applications with no safety or fraud issue | Up to 180 days after abandonment |
| Declined applications with no safety, fraud, dispute, or legal hold | Up to 12 months after final decision |
| Active account, profile, photos, and videos | While active; after closure, delete from active systems as required by applicable law and otherwise generally within 30–90 days unless a lawful retention basis applies |
| Support, appointment, and ordinary service communications | Generally up to 24 months after the communication or account closure, unless needed longer for a claim or legal obligation |
| Payment, invoice, tax, and accounting records | Generally 7 years or the period required by applicable financial or tax law |
| Contract versions, acceptances, consent records, and material legal notices | Generally 7 years after the relevant relationship or obligation ends, unless a different period is required |
| Security and authentication logs | Generally 12–24 months, subject to security need and data minimization |
| Safety, abuse, anti-evasion, or fraud records | Only the minimum information reasonably necessary for the lawful safety or fraud purpose and only for the period permitted by applicable law |
| IMBRA proof-of-age and statutory compliance records | The period required by 8 U.S.C. § 1375a or other applicable law; certain proof-of-age records must be retained for 7 years from receipt |
| Cookies and similar identifiers | According to the stated lifespan or consent setting; non-essential identifiers should not persist longer than necessary |
| Backups | Deleted data will age out under the backup rotation, generally within 90 days unless a legal hold or technical restoration requirement applies |
New York covered social-referral records
Where New York General Business Law § 394-c requires personal or private material acquired from a purchaser—including questionnaire responses, photographs, or background information—to be returned, destroyed, and deleted at the expiration of the covered contract or services, Prosperous Pairs will follow that statutory rule promptly and will not rely on the general target periods above to extend retention. Where destruction or deletion is used, Prosperous Pairs will promptly provide the certification of destruction or deletion required by the statute. Any exception will be limited to retention that the statute or another applicable law actually permits or requires, including a valid judicial order where applicable.
Contract, billing, tax, consent, security, or other records that are legally distinct from the personal/private materials subject to a mandatory deletion rule may be retained only for an applicable lawful purpose and period.
A deletion request does not require deletion of information that must lawfully be retained. We will explain an applicable limitation where required.
17. Privacy choices and requests
Subject to applicable law, you may have the right to request:
- confirmation of whether we process your personal information;
- access to personal information and information about its sources, purposes, and recipients;
- correction of inaccurate or incomplete information;
- deletion, erasure, blocking, or restriction;
- withdrawal of consent, subject to notice of consequences where required;
- objection to certain processing or direct marketing;
- a portable copy of eligible electronically processed information;
- opt-out from sale, sharing, targeted advertising, or certain profiling where applicable;
- review or correction of a consequential automated decision where applicable; and
- information about a personal-data breach or complaint process.
Send privacy requests to contact@prosperouspairs.com with the subject line “Privacy Request.” We may verify identity and authority only to the extent reasonably necessary for the request.
We will not unlawfully discriminate against a person for exercising a privacy right.
Withdrawal of consent does not affect processing already lawfully completed. It may prevent us from providing a feature that genuinely requires the information.
18. United States state privacy rights
Residents of some U.S. states may have additional privacy rights. Depending on the law and Prosperous Pairs’ coverage status, those rights may include access or confirmation, correction, deletion, portability, opt-out rights relating to covered sale, sharing, targeted advertising, or profiling, limits or consent requirements for sensitive data, rights concerning certain automated decisions, rights to use an authorized agent, and an appeal process after denial of a request.
Prosperous Pairs does not sell personal information for money. If an analytics, advertising, data-sharing, or profiling activity is treated as a “sale,” “sharing,” or “targeted advertising” activity under an applicable law, we will provide the notice, consent, or opt-out mechanism that law requires.
Where legally required, we will recognize supported opt-out preference signals such as Global Privacy Control for the activity to which the signal applies.
Because state privacy statutes use different thresholds and exemptions, Prosperous Pairs will periodically reassess revenue, processing volumes, sensitive-data practices, business relationships, and jurisdictional coverage rather than assuming that a comprehensive state privacy law does or does not apply.
Dating-service safety, contract, cancellation, fraud-ban, and screening disclosures required by individual states are addressed in the Terms of Service and on the legally required Service surfaces. Those consumer-protection notices are separate from comprehensive state privacy rights.
19. Philippines privacy rights
Philippine data subjects may have rights to be informed, object, access, rectify, erase or block, obtain data portability, file a complaint, and seek damages as provided by the Philippine Data Privacy Act and National Privacy Commission rules.
For sensitive personal information, Prosperous Pairs will rely only on a processing condition permitted by Philippine law, including specific consent where required. Prosperous Pairs remains accountable for personal information transferred to processors or third parties domestically or internationally and will use contractual or other reasonable means intended to provide a comparable level of protection as required by Philippine law.
Questions or requests may be sent to contact@prosperouspairs.com with the subject line “Philippines Privacy Request.”
Where National Privacy Commission registration requirements apply to Prosperous Pairs as a Personal Information Controller or Personal Information Processor, Prosperous Pairs will complete the required Data Protection Officer and Data Processing System registration or any required exemption declaration and will maintain required registration information.
Prosperous Pairs will identify and make available the responsible personal information controller and privacy-accountable contact details required by Philippine law before relying on this Policy for Philippine production processing.
20. Singapore privacy rights and DPO contact
Individuals covered by Singapore’s PDPA may withdraw consent with reasonable notice and may request access to personal data in our possession or control and information about its use or disclosure, subject to applicable exceptions. They may also request correction of an error or omission.
Prosperous Pairs will designate at least one Data Protection Officer and make the DPO’s business contact information publicly available as required. Personal data transferred outside Singapore will be protected using measures intended to provide a standard of protection comparable to the PDPA unless a lawful exception applies.
Until a dedicated DPO address is displayed, privacy and DPO inquiries may be directed to contact@prosperouspairs.com with the subject line “Singapore DPO / Privacy.”
21. EEA and UK rights, if applicable
If the Services are offered to individuals in the EEA or UK in circumstances that make the GDPR or UK GDPR applicable, eligible individuals may have rights of access, rectification, erasure, restriction, portability, objection, withdrawal of consent, and safeguards concerning certain automated decisions.
Where required, Prosperous Pairs will identify an EEA representative and/or UK representative and make the required contact details available.
A person may also lodge a complaint with the competent supervisory authority. Exercising a regulator complaint right does not require waiving or first completing a contractual dispute process where law provides otherwise.
22. Dating-safety and fraud notices
Some jurisdictions require online-dating safety disclosures or notifications concerning fraud bans or background-screening practices. Prosperous Pairs will provide those notices where required.
Any public statement that a user has been “screened,” “verified,” “background checked,” or is “safe” must accurately describe the actual process completed for that person and jurisdiction and must not imply a comprehensive criminal background check unless one was actually performed and lawfully supported.
23. Children and age eligibility
The Services are not intended for anyone under 21. We do not knowingly permit an under-21 person to apply for or maintain a member account.
If we learn that we collected personal information from an ineligible minor, we will restrict the account and delete or retain the information only as required by applicable law, safety needs, fraud prevention, or legal claims.
24. External links and third-party sites
The Services may link to third-party websites or services. Their independent processing is governed by their own privacy practices. Review those practices before providing information directly to a third party.
Where Google reCAPTCHA or a similar anti-bot service is used, the form or site will provide the disclosures required by the provider and applicable law.
25. Changes to this Policy
We may update this Policy as the Services, providers, or law changes. The current version and effective date will be posted on the website.
Before a material expansion of personal-information use, we will provide legally appropriate notice and request new acceptance or consent where required. Historical legal versions and acceptance evidence will be preserved as reasonably necessary for compliance and disputes.
26. Contact and complaints
Privacy requests, questions, and complaints may be sent to:
Prosperous Pairs LLC Mailing address: 140 Lake Nancy Ln #116, West Palm Beach, FL 33411, USA Privacy/DPO and general contact: contact@prosperouspairs.com Website: ProsperousPairs.com