Effective Date: March 18, 2024

Introduction

Greetings and welcome to Silvers Hub, an online social networking platform tailored for individuals aged 50 and above. Within this Privacy Policy, we, CushyStyle Digital Media Inc., along with our affiliates (referred to as ‘Silvers Hub,’ ‘we,’ ‘us,’ or ‘our’), delineate how we gather, utilize, and share data about you during your utilization of our Platform. Throughout this document, terms such as ‘member,’ ‘you,’ and ‘your’ encompass any individual engaging with our ‘Platform’ or participating in associated events.

This Privacy Policy governs the handling of data pertaining to members and other individuals gathered during your interactions with our ‘Platform,’ encompassing all websites, applications, and services we provide, as well as any communication with us. Please note that this Privacy Policy does not extend to data you may disclose to third parties, including fellow members and other individuals with whom you choose to share personal information.

By accessing or utilizing Silvers Hub, you hereby consent to abide by the provisions outlined in this Privacy Policy.

1. How We Collect Your Information
   At Silvers Hub, we gather information about you when you:

• Establish an account;
• Utilize the Platform;
• Visit our website;
• Interact with us.
• Participate in an event;

Additionally, we collect data, such as usage statistics, through the utilization of cookies, server logs, and similar technologies. If you opt for certain features, we may also acquire information from alternate sources, like social media services, invitations, and imported contacts.

      1.1 Data You Provide to Us
We accumulate information directly from you, including:

• The data when you create an account, select interests or groups, complete a form, or engage in communication with us.
• The categories of data we may gather encompass identifiers like your name, username, password, email address, postal address, and phone number.
• Payment and commercial data, demographic details, and any other personal information you opt to disclose, such as photos, interest preferences, gender, date of birth, group affiliations, and professional background.

While providing certain details like gender and date of birth is voluntary, your selection of groups is mandatory for account administration and group membership indication. It is essential to abide by our Community Guidelines, refraining from posting personal or sensitive data about others without their explicit consent, to maintain the integrity of our platform.

      1.2 Automatically Collected Information Upon Platform Use
Upon utilizing our Platform, we automatically gather internet and electronic network activity data, including:

• Account Information: Details about your Platform usage, browser type, access duration, IP address, and preceding page visited.
• Location Information: Data pertaining to your device location, collected based on your consent, either directly or indirectly through IP address approximation.
• Device Information: Information concerning your device model, operating system, unique identifiers, and mobile network data.
• Data Collected via Cookies and Similar Technologies: Utilizing cookies to enhance Platform functionality, track usage, and evaluate communication efficacy. For a comprehensive understanding of the cookies utilized, please refer to our Cookie Policy.
• Additional Information: With your consent, we may gather additional data from your device, like photos or calendar information.

1.3 Data Acquired from External Sources
We may obtain information about you from third-party sources, including:

• Social Media Services: Accessing limited account data if you register or log in via third-party social media platforms.
• Member Content: Receiving information when you or others upload content to the Platform.
• Corporate Affiliates: Obtaining data from our current or future corporate entities.
• Other Third-Party Sources: Gathering information from publicly available sources and commercial providers to enhance recommendation accuracy.

It is important to note that we may analyze and derive insights from the data we collect.

2. How We Use Your Information
   We may use your personal information for the following purposes:

      2.1 Platform Operations
We utilize the information mentioned above for various business endeavors related to the operation of our Platform, including:

• Platform Management: Providing, maintaining, and enhancing our Platform, which encompasses processing transactions, devising new products and services (such as incorporating you into trials or pilot programs for new or revised Platform features like messaging or search functionality, or utilizing your usage data to develop new or improved messaging or search features), and overseeing the performance of our Platform.
• Administrative Functions: Conducting accounting and administrative duties, as well as enforcing or managing legal claims.
• Profile Display: Displaying information about you, such as your list of interests, which will be visible on your profile.
• Personalization: Tailoring the Platform to your preferences, such as suggesting content that we believe aligns with your interests.
• Social Media Integration: Allowing you to share your Platform activity via third-party social media services if you link your account to such services (which can be disabled at any time), and leveraging this integration to offer better recommendations.
• Analytics: Monitoring and analyzing trends, usage patterns, and activities associated with our Platform.
• Security and Compliance: Detecting, investigating, and preventing fraudulent activities, abuse, and other illicit behavior; safeguarding the rights, property, or safety of Meetup and others; enforcing compliance with our policies; and adhering to applicable laws and government requests.

      2.2 Communication Protocols
We utilize your information for various communication-related business purposes, including:

• Member Notifications: Notifying you about communications from other members, based on your communication preferences set in your account.
• Customer Service: Responding to your inquiries, comments, and requests, and delivering customer support
• Technical Notices: Sending you technical updates, security alerts, support, and administrative messages.
• Marketing and Information Sharing: Communicating with you, in line with your account preferences, regarding products, services, and events offered by us and others; providing news and information we believe may interest you; conducting online surveys; notifying you about nearby events on our Platform; and other communication activities outlined in Section 2.3.

      2.3 Utilization of Information
We engage in various other business endeavors using your information, including:

• Content and Advertising: Offering content, features, or sponsorships tailored to member profiles or interests, and delivering targeted advertising on and off the Platform.
• Promotions: Facilitating contests and promotions.
• Marketing Communications: Sending you marketing messages, in compliance with applicable laws.
• Data Combination: Integrating your information with other data collected for the purposes outlined in this Privacy Policy.
• Other Stated Purposes: Fulfilling any other purposes communicated to you at the time of information collection.

      2.4 Legal Grounds for Processing
If you reside in a jurisdiction that mandates a specific legal basis for processing personal data, the legal basis for collecting and using the aforementioned information will vary based on the type of data and the particular context of collection.

• Contractual Obligations: We process your information to deliver our services in line with our Terms of Service, such as facilitating group participation or displaying your profile to other members.
• Legitimate Interests: In certain instances, we process your information based on our legitimate interests, provided they do not override your rights. Examples include direct marketing, fraud prevention, network security, response to communications, operation of group networks by network administrators, and Platform enhancement.
• Sensitive Information: If you provide sensitive data, such as joining specific groups indicating health, religious, political, or sexual identity information, our legal basis for processing such data depends on your explicit consent or your decision to make it public, contingent upon group and profile settings.
• Legal Compliance: We may also process your information to fulfill legal obligations or protect vital interests, including compliance with applicable laws, regulations, legal processes, or audits.
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3. Information Sharing and Disclosure
   We may share your personal information with third parties in the following circumstances:

• With your consent or at your direction.
• With service providers who assist us in operating Silvers Hub and providing services to you.
• With affiliates, partners, or other trusted entities for business purposes, such as marketing and promotions.
• In response to legal requests, court orders, or government regulations.
• To protect our rights, property, or safety, or the rights, property, or safety of others.

      3.1 Sharing Through Our Platform
We display certain information based on your profile and preferences. While some details are always public, like usernames, others, such as interests, can be hidden. Group memberships are visible within the group, with settings determining their public visibility. Review settings before joining. Public data is accessible both on and off the Platform.

      3.2 Collaboration with Service Providers
To facilitate various operational and developmental aspects of the Platform, we may engage service providers for specific business purposes such as payment processing, email delivery, conducting surveys or contests, data hosting, certain technical and customer support functions. These service providers, including data analytics providers, may access, process, and store information about you on our behalf, ensuring compliance with confidentiality agreements.

      3.3 Partnerships for Analytics and Advertising
We may share the information collected about you with third parties or authorize them to utilize technologies such as cookies and device identifiers to gather data on your usage of the Platform, across other websites and online services. This data is utilized for analytical purposes and to deliver advertisements tailored for Silvers Hub.

Depending on your jurisdiction, you might have the right to opt-out of the sharing of your personal information for targeted advertising purposes. Silvers Hub provides you with the opportunity to opt-out of such sharing.

      3.4 Affiliate Sharing and Business Transactions
In scenarios like mergers, acquisitions, financing, or asset transfers, your information may be shared, sold, or transferred as part of the process. We may also disclose your information to current or future corporate parents, subsidiaries, or affiliates.

      3.5 Social Sharing and Integrated Tools
Our Platform provides social sharing features and integrated tools allowing you to share your activities on Silvers Hub with third-party services. You control the visibility of shared information based on your chosen settings. Third-party services’ use of this information is governed by their privacy policies, and we do not oversee their data usage.

      3.6 Compliance and Protection

• In alignment with applicable laws and regulations, we may access, retain, and reveal your information, including message content, to government bodies and other parties if mandated by legal processes or audits.
• Disclosure may occur if your actions contravene our Terms of Service or policies, or to safeguard Silver Hub’s rights, assets, or safety, and prevent fraud or misconduct.

      3.7 Other Circumstances

• We may anonymize or aggregate your information for unrestricted sharing, rendering it unidentifiable. This type of information falls outside the scope of this Privacy Policy.
• We may share your information with your consent, or as legally required. For instance, event sponsors may receive your information when you RSVP to an event, and other group members and event organizers can access your information when you participate in an event.

4. Your Choices
   You have the following choices regarding your personal information:

• Account Settings: You may update your account information and preferences at any time by accessing your account settings.
• Communication Preferences: You may opt out of receiving promotional emails or notifications from Silvers Hub by following the unsubscribe instructions provided in the email or adjusting your notification settings.
• Location Information: You may control or disable location services through your device settings or Silvers Hub settings.
• Cookies: We and others may use cookies, web beacons, device identifiers, and similar technologies to track your Platform and online activity. Depending on your location, you may opt out of targeted advertising and manage cookie preferences via Cookie Settings.
• Marketing Messages: You can manage messages from Silvers Hub and members by using the unsubscribe link or adjusting settings. We’ll provide these options when you sign up and sign in messages. Opting out doesn’t affect non-promotional messages or others’ policies.
• Image Labeling: You can label photos of yourself and others. Labeled photos display the person’s name and appear on their group profile. We notify you of tags or comments and offer an “untag” option. You’re responsible for obtaining non-members’ photo consent.

5. 5. Data Security
      We take reasonable measures to protect the security of your personal information and prevent unauthorized access, disclosure, alteration, or destruction. However, no method of transmission over the internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

5. 5. Children’s Privacy Policy
      Silvers Hub is committed to protecting the privacy of individuals, especially seniors aged 50 and above, who use our social media platform. Our platform is intended for individuals aged 50 and above. We do not knowingly collect personal information from children under the age of 13. If we become aware that we have inadvertently collected personal information from a child under 13, we will promptly take steps to delete such information from our records. Parents or legal guardians who believe that their child under 13 may have provided personal information to us can contact us at service@silvershub.com to request the deletion of this information. We encourage parents and guardians to supervise their children’s online activities to ensure a safe and secure browsing experience.

5. Changes to Privacy Policy
   Silvers Hub reserves the right to update or modify this Privacy Policy at any time without prior notice. Any changes to the Privacy Policy will be effective immediately upon posting on our website. We encourage users to review this Privacy Policy periodically to stay informed about how we are protecting the information we collect. Your continued use of our platform after the posting of any modifications to the Privacy Policy will constitute your acknowledgment of the changes and your consent to abide and be bound by the updated Privacy Policy. If you do not agree with any of the changes to the Privacy Policy, you must discontinue your use of Silvers Hub’s platform.
6. Contact Us
   If you have any questions, concerns, or feedback regarding this Privacy Policy or our practices, please contact us at support@silvershub.com. We will make every effort to address your inquiries and resolve any issues promptly and effectively.