Privacy Policy

Introduction

This Privacy Policy explains how Mulli Technologies Inc. (“Mulli,” “we,” “us,” or “our”) collects, uses, discloses, and protects your information when you use our mobile application, website, and related services (the “Service”).

We are committed to handling your personal information in accordance with Canadian privacy law, including the Personal Information Protection and Electronic Documents Act (PIPEDA), British Columbia’s Personal Information Protection Act (PIPA), and, where applicable, Quebec’s Act respecting the protection of personal information in the private sector, as amended by Law 25.

By using the Service, you agree to this Privacy Policy. This Policy forms part of, and should be read together with, our Terms of Service.

1Information We Collect

We collect only the personal information reasonably necessary to provide, improve, secure, and operate the Service. We collect the following categories of personal information:

• Account and registration data — your name, email address, phone number, date of birth (used to confirm you are 18 or older), and gender. We use your mobile phone number to send you a one-time verification code by text message when you create your account or sign in, and to send account and security notifications.
• Profile information — photos, bio, golf experience and preferences, and the dating, relationship, and social preferences you choose to share, which may include information that reveals your sexual orientation.
• Location information — precise and/or approximate geolocation, as described in “Location Data.”
• Messages and content — messages, posts, comments, ratings, and other content you create, upload, or share.
• Identity-verification data — where you use verification tools, images or information submitted for verification.
• Payment information — purchases are processed by the applicable app store; we receive transaction confirmations rather than full payment-card details.
• Device and technical data — device type, operating system, identifiers, IP address, app version, and log data.
• Usage and analytics data — how you interact with the Service, collected through analytics tools, cookies, pixels, and similar technologies (including the Meta Pixel).
• Information from others — reports or information that other users or third parties provide about you.
• Inferred information — matches, recommendations, and preferences we infer from your activity.

2Sensitive Information

Some information we collect is sensitive — including precise geolocation, information that may reveal sexual orientation or relationship preferences, and identity-verification data.

We collect and use sensitive information only with your express consent and only as reasonably necessary to provide the Service. You may withdraw your consent at any time, though doing so may limit or disable certain features.

Mulli does not collect, store, or use biometric identifiers (such as facial-geometry data) unless expressly disclosed to you and consented to. Where identity-verification tools involve a selfie or similar image, we use it only to confirm identity as described at the time of collection and do not create or retain biometric templates except with your express consent.

3How We Use Your Information

We use your information to:

• Create and manage your account and confirm your eligibility (18+)
• Provide, operate, maintain, and improve the Service
• Match you with other users and personalize content and recommendations
• Enable messaging, community, and Clubhouse features
• Process purchases and manage subscriptions
• Detect, prevent, and respond to fraud, abuse, safety risks, and violations of our Terms
• Communicate with you, including service, security, and transactional notices
• Send marketing communications where permitted, with the ability to opt out
• Comply with legal obligations and enforce our agreements

We use your information only for the purposes identified at the time of collection or for compatible purposes, and we will obtain consent for new purposes where required by law.

Marketing communications are sent only with the consent required by applicable law, including Canada’s Anti-Spam Legislation (CASL), and may be withdrawn at any time.

4Legal Basis and Consent

Our collection, use, and disclosure of personal information is based on your consent, except where the law otherwise permits or requires.

We obtain express consent for sensitive information and rely on implied consent for information reasonably necessary to provide a feature you request. You may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice; withdrawing consent may mean we can no longer provide certain features.

Where we engage service providers to process information on our behalf, the consent you provide to us extends to that processing.

5Location Data

We collect precise and/or approximate location data to provide features such as nearby golfer matching, local community content, and event discovery.

You can enable or disable location permissions through your device settings at any time. Disabling location may limit location-based features. We do not continuously track your location for safety or emergency purposes — see our Terms of Service.

6Messaging and Content

Messages, posts, and content shared within the Service may be processed and stored to enable functionality, moderation, safety, and legal compliance.

We do not routinely read private messages. However, automated systems and authorized personnel may review messages when investigating reports, enforcing our policies, detecting abuse or fraud, protecting safety, or complying with legal obligations.

While we use safeguards, we do not guarantee the confidentiality of user communications. Content you share with other users or in community areas may be seen, stored, or re-shared by them.

7SMS and Text Messaging

What we send. When you register or sign in with a mobile number, we send a one-time verification code by text message to confirm your identity. This is a transactional message and is required to create and access your account. We may also send account, security, and service notifications by text. Where you have given express consent, we may send promotional or marketing text messages; you may withdraw that consent at any time without affecting your ability to use the Service.

Consent. You provide your mobile number and consent to receive these messages at the point you enter your number in the Mulli app. We do not send text messages to numbers we have not collected directly from you.

Frequency and cost. Message frequency varies. Verification codes are sent only when you request one. Message and data rates may apply.

Opting out. Reply STOP to any message to stop receiving non-essential text messages, or HELP for assistance. You may also contact us at hello@mulligolfapp.com. Note that if you opt out of all text messages you may be unable to sign in using your phone number; you can continue to use Google or Apple sign-in.

We never share your mobile information. Mulli does not share or sell your mobile phone number, or your consent to receive text messages, to any third party, affiliate, or lead generator for marketing or promotional purposes. Your mobile number is disclosed only to the messaging service provider that transmits messages to you on our behalf, and only for that purpose.

Delivery. Mobile carriers are not liable for delayed or undelivered messages.

8Automated Decision-Making and Profiling

We use automated systems, algorithms, and artificial intelligence to generate matches, recommend content, personalize your experience, and detect fraud and safety risks. These processes may involve profiling based on your profile, preferences, and activity.

Where automated processing is used to make a decision that significantly affects you, you may, to the extent required by applicable law (including Quebec’s Law 25), request information about that decision and submit observations to a member of our team for review.

9Cookies, Pixels, and Tracking

We and our partners use cookies, pixels, software development kits (SDKs), and similar technologies — including the Meta Pixel — to operate the Service, remember preferences, measure performance, and understand advertising effectiveness.

You can control many of these technologies through your device or browser settings and, where available, through in-app privacy controls. Some advertising and measurement partners may receive limited data to evaluate and improve campaigns. No mobile phone number, and no text-message consent or opt-in data, is ever disclosed to any advertising, measurement, or marketing partner. We do not sell your personal information and do not share personal information with third parties in exchange for compensation of any kind.

10How We Share Information

We do not sell your personal information, and we do not share personal information with third parties in exchange for compensation of any kind. Mobile phone numbers and text-message consent obtained through the Service are never shared with or sold to third parties, affiliates, or lead generators for marketing or promotional purposes; they are disclosed only to the messaging provider that delivers messages you have asked to receive. We share other information only as described below:

• Service providers and processors who work on our behalf (such as hosting, analytics, and payment processing), under confidentiality and data-protection obligations
• Other users — the profile information and content you choose to make visible
• App stores and platforms (such as Apple and Google) as needed to deliver the Service
• Law enforcement, regulators, or others when required by law or legal process, or to protect the safety, rights, or property of any person
• In a business transaction such as a merger, acquisition, financing, or sale of assets, subject to this Policy

We may also share de-identified or aggregated information that cannot reasonably be used to identify you.

11Third-Party Services and Processors

We rely on third-party providers to operate the Service, including cloud hosting and database infrastructure, Twilio for text-message delivery, Cloudinary for image hosting, Google Firebase for push notifications, payment processing through the Apple App Store and Google Play, and analytics, advertising, and measurement tools such as the Meta Pixel.

These providers process information under our instructions and in accordance with their own privacy policies. We encourage you to review the privacy practices of any third-party service you interact with.

12International Data Transfers

Your information may be stored or processed in countries outside Canada — including the United States — where our service providers operate.

Information stored in another country is subject to the laws of that country, and may be accessed by courts, law enforcement, and regulatory authorities in those foreign jurisdictions in accordance with local laws. Before transferring personal information outside your province or Canada, we take steps intended to ensure a comparable level of protection, consistent with PIPEDA, PIPA, and Quebec’s Law 25.

13Data Retention

We retain personal information only as long as necessary to fulfill the purposes for which it was collected, to provide the Service, and to comply with legal, accounting, security, fraud-prevention, and dispute-resolution obligations.

When information is no longer required, we securely delete or de-identify it. Following account deletion, residual copies may persist in backups for a limited period before being overwritten, and content you shared with others or in community areas may remain visible. See our Terms of Service for account-deletion details.

14Security

We use technical and organizational safeguards designed to protect personal information, including encryption of data in transit and at rest, access controls, and monitoring.

You are responsible for maintaining the confidentiality of your account credentials and should not share them with anyone. Notify us promptly if you believe your account has been compromised.

No method of transmission or storage is completely secure, and we cannot guarantee absolute security. If we become aware of a breach that poses a real risk of significant harm, we will respond as described in “Data Breach Notification.”

15Your Privacy Rights

Subject to applicable law, you have the right to:

• Access the personal information we hold about you
• Correct inaccurate or incomplete information
• Withdraw consent to certain collection, use, or disclosure
• Request deletion of your account and associated personal information
• Request a copy of your information in a portable, commonly used technological format (data portability)
• Object to, or request review of, certain decisions made through automated processing
• Opt out of marketing communications

We will respond to verified requests within the timeframe required by law (generally within 30 days under PIPEDA).

16Exercising Your Rights and Complaints

To exercise any of these rights, contact us at hello@mulligolfapp.com or our Privacy Officer (below). We may need to verify your identity before responding.

If you are not satisfied with our response, you may file a complaint with:

• The Office of the Privacy Commissioner of Canada (OPC)
• The Office of the Information and Privacy Commissioner for British Columbia (OIPC BC)
• The Commission d’accès à l’information du Québec (CAI), for Quebec residents

17Privacy Officer

We have designated a Privacy Officer responsible for our compliance with this Policy and applicable privacy laws.

You can contact our Privacy Officer at:

Privacy Officer
Mulli Technologies Inc.
hello@mulligolfapp.com

18Data Breach Notification

In the event of a confidentiality incident or breach of security safeguards involving personal information that poses a real risk of significant harm, we will notify affected individuals and the relevant authorities — including the Office of the Privacy Commissioner of Canada and, for Quebec residents, the Commission d’accès à l’information — as required by law, and we will maintain a record of such incidents.

19Children

The Service is intended only for individuals 18 years of age or older. We do not knowingly collect personal information from anyone under 18.

If we learn that we have collected information from a minor, we will delete it promptly. If you believe a minor has provided us with information, please contact us.

20Changes to This Policy

We may update this Privacy Policy from time to time. For material changes, we will provide notice through the Service or by other appropriate means and, where required by law, obtain your consent.

The “Last updated” date reflects the most recent revision. Your continued use of the Service after changes take effect constitutes acceptance, except where consent is required.

21Contact

Mulli Technologies Inc.

hello@mulligolfapp.com