Nohmit Incorporated d/b/a Invitrr · Effective June 1, 2026
Nohmit Incorporated d/b/a Invitrr
Effective Date: June 1, 2026 | Version: 2026-06-01
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NOTICE TO ALL USERS: THIS PRIVACY POLICY CONSTITUTES A BINDING LEGAL AGREEMENT BETWEEN YOU AND NOHMIT INCORPORATED. BY ACCESSING OR USING THE SERVICES IN ANY MANNER, INCLUDING BUT NOT LIMITED TO CREATING AN ACCOUNT, BROWSING ANY PORTION OF THE APPLICATION OR WEBSITE, OR SUBMITTING ANY INFORMATION TO US, YOU ACKNOWLEDGE THAT YOU HAVE READ THIS PRIVACY POLICY IN ITS ENTIRETY, THAT YOU UNDERSTAND IT, AND THAT YOU AGREE TO BE BOUND BY ITS TERMS. IF YOU DO NOT AGREE WITH ANY PORTION OF THIS PRIVACY POLICY, YOUR SOLE REMEDY IS TO DISCONTINUE ALL ACCESS TO AND USE OF THE SERVICES AND TO REQUEST DELETION OF YOUR ACCOUNT AND PERSONAL INFORMATION IN THE MANNER DESCRIBED HEREIN.
SECTION 1 — INTRODUCTION, IDENTITY OF THE CONTROLLER, AND SCOPE OF THIS POLICY
Nohmit Incorporated ("Invitrr," "we," "us," "our," or the "Company") is a corporation incorporated under the laws of the Province of Ontario, Canada, with its principal place of business in Ottawa, Ontario. Invitrr operates the Invitrr mobile application, the primary consumer website accessible at invitrr.com, and any other current or future websites, mobile applications, application programming interfaces, software, features, tools, content, services, or platforms operated by or on behalf of Nohmit Incorporated that link to or reference this Privacy Policy (all of the foregoing, collectively and individually, the "Services").
This Privacy Policy ("Policy") describes in detail the manner in which Nohmit Incorporated collects, receives, generates, stores, processes, uses, discloses, transfers, retains, archives, and deletes personal information and other data in connection with your access to and use of the Services. This Policy also describes your rights with respect to your personal information and the mechanisms through which you may exercise those rights. References in this Policy to "personal information" or "personal data" mean any information relating to an identified or identifiable natural person, as that term is defined under applicable privacy legislation, including but not limited to Canada's federal Personal Information Protection and Electronic Documents Act, S.C. 2000, c. 5 ("PIPEDA"); An Act Respecting the Protection of Personal Information in the Private Sector (R.S.Q., c. P-39.1), as amended by An Act to Modernize Legislative Provisions as Regards the Protection of Personal Information (2021, chapter 25, "Law 25" or "Quebec Privacy Act"); Regulation (EU) 2016/679 of the European Parliament and of the Council ("GDPR"); the United Kingdom General Data Protection Regulation as retained in UK law by the European Union (Withdrawal) Act 2018 and as amended by the Data Protection, Privacy and Electronic Communications (Amendments etc.) (EU Exit) Regulations 2019 ("UK GDPR"); the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020 (Cal. Civ. Code §§ 1798.100 et seq., "CCPA/CPRA"); and any other applicable privacy, data protection, or consumer protection statutes, regulations, or binding guidance in force in any jurisdiction in which the Services are accessed or used.
For purposes of applicable Canadian and Quebec privacy legislation, Nohmit Incorporated is the "organization" responsible for personal information under its control. For purposes of the GDPR and UK GDPR, to the extent those instruments apply, Nohmit Incorporated acts as the "data controller" with respect to personal information processed in connection with the Services. Nohmit Incorporated has designated a Privacy Officer responsible for overseeing compliance with applicable privacy legislation and for receiving and responding to privacy-related inquiries and complaints. Our Privacy Officer may be contacted at any time by email at [email protected], with the subject line "Privacy Officer — [Nature of Inquiry]." We endeavour to acknowledge receipt of all privacy inquiries within five (5) business days and to respond substantively within thirty (30) calendar days, extendable to sixty (60) calendar days where permitted by applicable law and where the complexity of the request so requires, provided that we will notify you of any such extension within the initial thirty-day period.
For individuals located in the European Economic Area or the United Kingdom, this Policy serves as the privacy notice required by Articles 13 and 14 of the GDPR and UK GDPR, respectively. Nohmit Incorporated is committed to designating a representative within the EEA and/or UK as required by Article 27 of the GDPR and UK GDPR once the volume and nature of our processing activities in those jurisdictions necessitates such designation under applicable guidance. Until such a representative is designated, inquiries from EEA and UK individuals may be directed to [email protected].
This Policy applies to all individuals who access or use the Services in any capacity, including without limitation registered users who have created an Invitrr account, individuals who browse the public-facing website without creating an account, individuals who submit their contact information through our pre-launch waitlist, hosts who create social events through the Services, attendees who request to join events, community volunteers who participate in the Bailout safety program, individuals whose personal information is transmitted to us as emergency contacts by registered users, and any other individual whose personal information we process in connection with the Services. Certain provisions of this Policy apply only to specific categories of individuals as indicated, and we have endeavoured to make those distinctions clear within the text.
SECTION 2 — ELIGIBILITY AND AGE RESTRICTIONS
The Services are exclusively directed to, and are intended for use only by, individuals who are eighteen (18) years of age or older. Invitrr does not knowingly collect, solicit, use, or disclose personal information from individuals under the age of eighteen (18). We do not knowingly collect personal information from children under the age of thirteen (13) as defined under the Children's Online Privacy Protection Act ("COPPA"), and we do not knowingly process personal data of children under sixteen (16) as defined under Article 8 of the GDPR. At the time of account creation, we require users to confirm that they are at least eighteen (18) years of age, and we record that confirmation in our database alongside the timestamp, IP address, and user agent string associated with the confirmation event. By creating an account and using the Services, you represent and warrant that you are at least eighteen (18) years of age and that you have the legal capacity to enter into a binding agreement under the laws of your jurisdiction of residence. If we discover at any time or have reasonable cause to believe that a user is under the age of eighteen (18), we reserve the right to immediately suspend or permanently terminate that user's account, deny all further access to the Services, and delete or cease processing any personal information associated with that account to the extent technically and legally feasible. If you have reason to believe that an individual under the age of eighteen (18) has created an account or otherwise submitted personal information to us through the Services, please contact us immediately at [email protected].
SECTION 3 — CATEGORIES OF PERSONAL INFORMATION WE COLLECT AND THE SOURCES FROM WHICH WE COLLECT IT
We collect personal information from multiple sources and through multiple mechanisms. The following subsections describe in detail each category of personal information we collect, the specific data elements within each category, the source of that information, and the purpose for which it is initially collected. Additional information about how we use this information is provided in Section 4. Additional information about how long we retain this information is provided in Section 8.
3.1 Information You Provide Directly. The most significant source of personal information we collect is information that you voluntarily provide to us directly through your use of the Services. When you create an Invitrr account, you provide us with your email address, which we store as your primary account identifier and which we use to authenticate your identity, to deliver one-time password verification codes, and to send you account-critical transactional communications including but not limited to security alerts, account verification notices, subscription notifications, moderation notices, and safety-related communications. You may also optionally provide your mobile telephone number in E.164 international format, which we use as an alternative authentication mechanism and for delivery of SMS-based one-time password codes and, where applicable, SMS safety alerts through our Bailout safety feature. If you create your account using a password, we store a cryptographic hash of your password using industry-standard hashing algorithms; the plaintext of your password is never stored in our database and is not accessible to any Invitrr employee or system in its original form. If you authenticate using Sign In with Apple, we store the Apple-issued subject identifier associated with your Apple identity, which is an opaque, app-specific string that does not contain or reveal your Apple ID email address; if you authenticate using Google OAuth, we store the Google-issued subject identifier ("sub claim") associated with your Google account. Both of these social authentication identifiers are stored exclusively for authentication purposes, are never returned in API responses accessible to other users, and are never used for any purpose other than authenticating your identity when you log in.
When you complete the Invitrr onboarding questionnaire, you provide us with a substantial body of profile and personality information that forms the foundation of your public profile and that is used to seed and inform our proprietary recommendation and matching systems. This information includes your first and last name, which is displayed on your profile; your date of birth, which we use to verify that you meet the age requirement and which is used to display or conceal your age on your profile in accordance with your privacy settings; your gender identity, which is a free-text field that you may complete voluntarily and which is displayed on your profile and may optionally be used in discovery filtering; your chosen username or handle, which is a unique public identifier on the platform; a freeform biography of up to five hundred (500) characters; a short vibe descriptor; a description of your hosting style if you intend to host events; your preferred role on the platform (host, guest, or both); your selection of event type preferences from a predefined list of categories; your selection of vibe and interest tags from predefined taxonomies; your responses to personality and social-style questions presented during onboarding, including your event size preference, your social energy level as indicated on a scale captured as a floating-point value between zero and one, your preferred time of day for social activities, your willingness to travel a certain distance for events, your self-described frequency of going out, your stated priorities at social events, your planning style, your preferences regarding host characteristics, and your response to personality-framing questions presented in the onboarding flow. You also provide your city and country of residence. The specific algorithms, models, weighting systems, computational processes, and proprietary methodologies through which any of the foregoing information is combined, processed, weighted, scored, vectorized, or otherwise applied to generate recommendations, match scores, feed rankings, or any other output of our systems constitute proprietary trade secrets of Nohmit Incorporated and are not disclosed in this Policy or in any other public-facing document. We describe the categories of inputs we use, and the general purposes for which we use them, but we do not and are not required to disclose the proprietary means by which those inputs are processed.
You also provide us with your profile photographs, which you upload through the application and which are stored in Cloudflare R2 object storage with access governed by signed URLs served through media.invitrr.com. All photographs uploaded to the Services are automatically submitted to our automated content moderation pipeline prior to being made publicly visible, as described in greater detail in Section 3.4. You may also optionally provide event listings including an event title, description, venue display name, neighborhood and city information, timing information, event metadata, capacity, visual assets, and tags. When you send messages to other users through the Services, the text and image content of those messages is stored in our database and, in the case of text content, is submitted to our automated content moderation pipeline. When you submit a request to attend an event, we store the content of any personal note you include with your request. When you add emergency contacts to your account, you provide us with each contact's full name, telephone number in E.164 format, relationship label, preferred notification method, and priority ranking. When you activate a Bailout safety session, you provide us with your chosen request type and an optional contextual description. When you submit an event rating following attendance at an event, we store your numerical ratings across multiple dimensions and any optional text comment you include. When you submit an identity verification selfie, we store the image file and associated challenge data as described in Section 3.5.
3.2 Information Generated Automatically Through Your Use of the Services. In addition to information you provide directly, we automatically generate and collect certain information through your interaction with the Services. When you interact with events, profiles, or other content within the application, we record a time-series log of your in-app interaction signals ("behavioral events"). Each behavioral event record captures the type of interaction (drawn from a predefined internal taxonomy of signal types that includes but is not limited to events corresponding to feed views, event card views, time spent viewing a card, swipe-accept interactions, swipe-reject interactions, search queries entered, profile views, event request submissions, conversation initiations, messages sent, conversation abandonment, and other engagement signals, totaling forty-six (46) discrete event types as of the effective date of this Policy, subject to expansion as the Services evolve); the identifier of the content object you interacted with; a JSON payload containing contextual metadata specific to the event type (such as the number of seconds spent viewing a card, the text of a search query, or the scroll depth of a feed view); the session identifier grouping this event with other events in the same user session; and the timestamp of the interaction. This behavioral event log is retained for a rolling ninety (90) day window for active users, after which records older than ninety days are incorporated into the aggregated behavioral model described below and the raw event records are permanently deleted. Following account deletion, all behavioral event records are permanently deleted within thirty (30) days as part of the data erasure cascade.
We derive from the behavioral event log, and maintain on a per-user basis, a behavioral preference model ("behavioral vector") that consists of preference weights across multiple event type dimensions, vibe dimensions, distance preferences, and temporal preferences; engagement scores, activity scores, urgency scores, and role scores derived from your interaction history; and a set of numerical signals that are used to personalize your event feed, determine the ranking of events presented to you, and inform other aspects of the recommendation experience. The behavioral vector is updated continuously as new behavioral events are logged. The specific algorithms, computational methods, mathematical formulas, model architectures, feature engineering processes, normalization techniques, weighting mechanisms, and other technical processes used to derive, update, store, and apply the behavioral vector — including but not limited to any machine learning models, statistical models, heuristic systems, or hybrid systems involved in those processes — constitute proprietary and confidential trade secrets of Nohmit Incorporated. We expressly decline to disclose any aspect of these processes beyond the input categories described in this Policy, and nothing in applicable privacy law requires us to disclose trade secret information. Our disclosure obligations under GDPR Article 13, PIPEDA Schedule 1, Law 25, and other applicable instruments are satisfied by our disclosure of the categories of personal data processed and the purposes of processing, which we provide herein.
We also collect certain device and technical information automatically when you install and use the application. This includes a stable device identifier generated by and stored in your iOS Keychain, which persists across application reinstalls and which we use for session management, device continuity tracking, and new-device security alert generation; the human-readable model name of your device, such as "iPhone"; the version number of the Invitrr application installed on your device; your Apple Push Notification service (APNs) device token, which we use exclusively to route push notifications to your device and which is never shared with any third party for advertising or targeting purposes; your device platform identifier; and the timestamp at which your device token was last registered or updated. In connection with authenticated sessions, we collect and store for each active session a cryptographic hash of the refresh token issued to that session (the raw token value is never stored on our servers), the device identifier and model associated with the session, the application version associated with the session, the IP address from which the session was established (stored in partially masked form in session management records accessible to you, and in full in server access logs retained for thirty (30) days), the session expiry timestamp, and a record of the last time the session was used. You may view your active sessions and revoke any individual session or all other sessions through the Security section of the application Settings screen.
We collect your IP address in several contexts, including in our web server access logs (retained for thirty (30) days), in our records of account creation events, in our records of policy acceptance events (retained for seven (7) years as legal evidence of consent), in our rate limiting and IP reputation systems (retained transiently in cache), and in connection with reports of suspicious activity. IP addresses are used for security purposes including rate limiting, fraud detection, and IP reputation filtering; for geographic context in certain limited circumstances; and as part of our legal records of consent. IP addresses collected as part of policy consent records are retained as legal evidence of the circumstances under which you accepted our Terms of Service and Privacy Policy.
3.3 Information We Receive From Third Parties. We receive certain personal information about you from third parties in limited circumstances. When you authenticate using Sign In with Apple, Apple transmits to us the Apple-issued subject identifier associated with your Apple identity and, on the first login only, your name and email address to the extent you choose to share them with us through the Apple authentication flow; on subsequent logins, Apple transmits only the subject identifier. When you authenticate using Google OAuth, Google transmits to us your Google-issued subject identifier, your email address, and your name as registered in your Google account. Apple's transmission of your personal information to us is governed by Apple's Privacy Policy; Google's transmission is governed by Google's Privacy Policy. When Apple notifies us of subscription events through App Store Server Notifications — including renewals, expirations, cancellations, billing retry events, and refund events — Apple transmits to us your original transaction identifier, the product identifier of your subscription, and associated event metadata. We also receive acknowledgment responses from your emergency contacts when they interact with your safety tracking page or respond to SMS alerts during an active Bailout safety session; specifically, we receive the phone number of the contact who responded and the type of acknowledgment they provided.
3.4 Content Moderation Data. All text content you submit through the Services — including messages, biographies, event descriptions, event titles, request notes, and rating comments — is submitted to the OpenAI Moderation API, a third-party automated content moderation service, for the purpose of detecting potentially harmful, abusive, or policy-violating content. The OpenAI Moderation API returns a toxicity score and category classifications for each piece of submitted content, which we store in association with the content record for moderation record-keeping purposes. Text content is submitted to the OpenAI Moderation API in hashed or encoded form where technically feasible to minimize data exposure. All image content you upload through the Services — including profile photographs, event cover photographs, and message image attachments — is submitted to the Amazon Web Services Rekognition computer vision service ("AWS Rekognition") for the purpose of detecting explicit, violent, or otherwise prohibited visual content. AWS Rekognition returns a set of label classifications and confidence scores, which we store in association with the content record. Neither OpenAI nor AWS is authorized to retain, use, or share content submitted to their respective moderation APIs for any purpose other than returning moderation results to us, and we have data processing agreements in place with each provider to this effect.
3.5 Identity Verification Data. If you choose to undergo our optional identity verification process, we collect and store your identity verification status, the timestamp of your selfie submission, and a reference to the selfie photograph stored in Cloudflare R2 object storage. The identity verification process involves your completion of a liveness challenge, which is a dynamic sequence of face orientation or expression prompts designed to confirm that you are a live person present at the time of verification rather than a static photograph or pre-recorded video. The challenge parameters, the individual frame uploads, and the completed liveness submission are processed by our internal liveness verification system. Selfie images and liveness frames are accessible exclusively to trained Trust and Safety personnel at Nohmit Incorporated who conduct verification reviews. We do not use your verification selfie to build a biometric database, we do not share it with third-party identity verification services, and we do not use it for any purpose other than confirming that the person depicted in the selfie is consistent with the profile photographs you have provided. Verification selfies are retained for a maximum of twelve (12) months following the completion or rejection of a verification review, after which they are permanently deleted, except where retention is required or permitted by applicable law in connection with a legal proceeding, regulatory investigation, or law enforcement request.
3.6 Safety and Bailout Session Data. When you activate a Bailout safety session, we create a session record that includes the unique identifier of the session; your user identifier; the type of safety request you selected; any optional contextual description you provided; the lifecycle status of the session (matching, active, escalated, resolved, cancelled, or expired); the timestamp at which the session was activated; the identifier of any community volunteer matched to your session; a single-use safety access token derived from a cryptographically secure random UUID, which is used to generate the unique URL transmitted to your emergency contacts and which expires four (4) hours after activation; the escalation level of the session, reflecting how many rounds of escalation SMS messages have been sent; a record of check-in events and missed check-ins; a record of any distress signals detected by our system (such as cessation of location updates or GPS dropout); the timestamp and method of session resolution; and internal risk scoring fields used exclusively for safety system decision-making and never returned in API responses accessible to users.
During an active Bailout session, your device transmits GPS location updates to our servers at approximately sixty (60) second intervals. Each location update record includes your latitude and longitude coordinates, the horizontal accuracy of the coordinates in metres, your direction of travel in degrees, your speed in metres per second, your device battery percentage, the type of participant transmitting the update (session owner or volunteer), and the timestamp of the update. These location updates are displayed in real time on the safety tracking page accessible to your emergency contacts via the unique safety URL, and are also made available in real time to any community volunteer matched to your session. Location updates are retained for ninety (90) days following session resolution, after which they are permanently and irrecoverably deleted. During a Bailout session, messages exchanged between you and an assigned community volunteer through the in-session chat interface are relayed exclusively through a WebSocket connection maintained by our servers and are never written to our persistent database; these messages are ephemeral by design and are purged from server memory when the session resolves, expires, or is cancelled.
3.7 Subscription, Payment, and Balance Data. We maintain subscription records including your Apple App Store original transaction identifier, the product identifier of your current subscription plan, your subscription status, your subscription expiry date, your auto-renewal preference, the App Store environment in which your subscription was issued, and the timestamp of our most recent verification of your subscription status with Apple. We also maintain a record of your consumable add-on credit balances, including the number of Super Request credits, extra request pack credits, Event Spotlight credits, Profile Boost credits, Extended Event credits, and Rewind credits associated with your account, which serves as the server-side authoritative source of truth for these balances. We do not collect, store, process, or have any access to your credit card number, bank account number, payment card expiration date, CVV/security code, billing address, or any other financial instrument details; all payment processing is performed exclusively by Apple through the App Store, and Apple's privacy policy and payment terms govern that processing.
3.8 Pre-Launch Waitlist Data. If you submitted your name, email address, city, intended role, and IP address through our pre-launch waitlist at invitrr.com prior to the public launch of the Services, we retain that information for the purpose of sending you your waitlist invitation and for the purpose of geographic launch sequencing. Waitlist data is not automatically merged with any Invitrr account you subsequently create; we rely on matching email addresses to associate waitlist records with accounts for purposes of delivering promised waitlist benefits, and we treat waitlist records and account records as separate processing contexts subject to separate consent bases.
3.9 Policy Agreement Records. We maintain an immutable append-only record of each event on which you accepted the Invitrr Terms of Service, Privacy Policy, or any other policy requiring your affirmative consent, including the version identifier of the policy accepted, the precise timestamp of acceptance, a boolean flag indicating your affirmative acceptance, a boolean flag recording your confirmation that you are at least eighteen (18) years of age, the IP address from which acceptance was submitted, and the User-Agent string of the device and application through which acceptance was submitted. These records constitute legal evidence of your informed consent and are retained for the duration of your account and for a minimum period of seven (7) years following permanent account deletion, to enable us to demonstrate compliance with applicable consent-recording obligations and to defend against any claims arising from the consent transaction.
SECTION 4 — PURPOSES FOR WHICH WE PROCESS YOUR PERSONAL INFORMATION AND THE LEGAL BASES FOR THAT PROCESSING
We process your personal information for specific, legitimate purposes, each of which is described in this Section. For individuals in the European Economic Area or the United Kingdom, we identify alongside each purpose the legal basis under the GDPR and UK GDPR on which we rely for that processing. For individuals in Quebec, we also identify the purpose and the legal basis under Law 25. For all other Canadian users, processing is conducted in accordance with PIPEDA's consent-based and legitimate-business-need frameworks.
We process your account and authentication information for the purpose of creating and maintaining your account, verifying your identity when you log in, delivering security alerts, and providing account management features, on the legal basis of performance of a contract (Article 6(1)(b) GDPR), being the contract formed between you and Invitrr upon your acceptance of the Terms of Service. We process your profile information for the purpose of displaying your profile to other users, enabling event discovery, and enabling hosts to review your profile when considering your request to attend their events, on the legal basis of performance of a contract. We process your onboarding questionnaire responses, behavioral event data, and derived behavioral vector for the purpose of operating, personalizing, and improving our proprietary recommendation and matching systems, and for the purpose of ranking your event feed, on the legal basis of our legitimate interests in providing you with a personalized and relevant service experience (Article 6(1)(f) GDPR); we have determined that this processing is necessary for the provision of the core value proposition of the Services and that our legitimate interests in conducting it are not overridden by your interests or fundamental rights, particularly given the nature of the processing (personalization of a social discovery feed) and the transparency we provide through this Policy, and our Legitimate Interests Assessment for this processing is available upon request. We process your device and technical information for the purposes of delivering push notifications, managing your sessions, detecting suspicious or fraudulent activity, and maintaining the security and integrity of the Services, on the legal basis of our legitimate interests in operating a secure and reliable platform and, to the extent the processing is technically necessary to provide features you have requested (such as push notifications), on the basis of performance of a contract. We process your emergency contact information for the purpose of operating the Bailout safety feature and transmitting safety alerts to your designated contacts when you activate a session, on the legal basis of performance of a contract and, in circumstances where the activation of a Bailout session may indicate an imminent risk to your life or physical safety, on the additional legal basis of protection of vital interests (Article 6(1)(d) GDPR). We process your Bailout session data and real-time location updates during active Bailout sessions on the legal basis of your explicit consent given at the time of activating the session (Article 6(1)(a) and, to the extent location constitutes sensitive data in the applicable jurisdiction, Article 9(2)(a) GDPR), on the legal basis of protection of vital interests, and on the legal basis of performance of a contract. We process content moderation data for the purpose of detecting and removing policy-violating content, protecting our users from harmful content, and enforcing our Community Guidelines, on the legal basis of our legitimate interests in maintaining a safe and lawful platform and, to the extent we are legally required to remove certain categories of content, on the legal basis of compliance with a legal obligation (Article 6(1)(c) GDPR). We process subscription and payment data for the purpose of managing your subscription, gating premium features, and maintaining required financial records, on the legal basis of performance of a contract and compliance with a legal obligation. We process policy agreement records for the purpose of documenting your consent and demonstrating compliance with our consent obligations, on the legal basis of compliance with a legal obligation and our legitimate interests in legal defense. We process risk scoring data, moderation history, audit logs, suspension records, and appeal records for the purpose of enforcing our Terms of Service and Community Guidelines, maintaining platform safety, and defending against legal claims, on the legal basis of our legitimate interests in these activities and, where applicable, compliance with a legal obligation. We may process any category of personal information described in this Policy for the purpose of establishing, exercising, or defending legal claims, on the legal basis of Article 9(2)(f) GDPR where special category data is involved, and Article 6(1)(f) for all other data.
To the extent that any information you voluntarily provide — including gender identity or personal information disclosed in connection with Bailout safety events — constitutes special category data under Article 9 GDPR, we rely on your explicit consent (Article 9(2)(a)), the necessity of processing to protect your vital interests (Article 9(2)(c)) in the context of the Bailout feature, and the necessity of processing for reasons of substantial public interest (Article 9(2)(g)) where applicable. We collect gender identity only because users choose to provide it voluntarily in their profile, and we process it only for the purposes of profile display and, where you have enabled it, discovery filtering. We do not collect or infer any other special category data and we do not use any personal information you provide as a proxy for inferring racial or ethnic origin, political opinions, religious or philosophical beliefs, or other special category attributes.
SECTION 5 — HOW WE SHARE YOUR PERSONAL INFORMATION
We do not sell your personal information to third parties for monetary consideration. We do not share your personal information for cross-context behavioral advertising purposes. We do not disclose your personal information to data brokers, advertising networks, or social media companies for targeting purposes. We share your personal information only in the limited circumstances described in this Section, and in each case only to the extent necessary to accomplish the stated purpose.
We share your public profile information — which includes your first name, handle, profile photographs, biography, vibe descriptor, interest and vibe tags, event preference tags, general location at city or neighbourhood precision, membership tenure, events-attended and events-hosted counts, average host rating, and InvitrScore — with other authenticated users of the Services for the purpose of enabling social discovery, facilitating event requests, and enabling hosts to review profiles before accepting or declining requests. Your precise home-area latitude and longitude coordinates, your date of birth (unless you have enabled age display), your email address, your telephone number, your device information, your behavioral vector, your risk score, and all other information described in this Policy as "internal only" or as excluded from API responses are never shared with other users through the Services under any circumstances. The exact address and precise coordinates of an event you host are shared only with confirmed attendees — that is, users whose request to attend your event you have accepted — and are not disclosed to any other user, including users whose requests are pending or have been declined.
We share your personal information with the following categories of third-party service providers, each of whom processes your data as a data processor (or "service provider" under the CCPA) under contract with Nohmit Incorporated and subject to data processing agreements that prohibit the service provider from using your personal information for any purpose other than performing services for us: Apple Inc., to whom we transmit your APNs device token and notification payload for purposes of delivering push notifications to your device; Twilio Inc., to whom we transmit telephone numbers and message content for purposes of delivering SMS one-time password codes, security alerts, and Bailout safety alert messages to you and to your emergency contacts; Resend Inc., to whom we transmit your email address and email content for purposes of delivering transactional email communications; Cloudflare, Inc., whose R2 object storage service we use to store profile photographs, event photographs, verification selfies, and other binary assets, and whose network infrastructure serves those assets through signed URLs; Amazon Web Services, Inc., to whose Rekognition computer vision service we transmit uploaded images for automated content moderation scanning; OpenAI, LLC, to whose Moderation API we transmit text content for automated harmful-content detection; and database and caching infrastructure providers, which host and process personal data described in this Policy under data processing agreements with us. Each of the foregoing service providers is contractually prohibited from using your personal information for their own purposes, from selling it, from disclosing it to unauthorized parties, and from processing it in ways not authorized by us. We conduct due diligence on our service providers' privacy and security practices before engaging them and maintain data processing agreements with each.
We share your first name, activation timestamp, real-time GPS location, and the unique safety tracking URL with your designated emergency contacts when you activate a Bailout safety session. By adding emergency contacts to your account and activating a Bailout session, you consent to this disclosure. We share your first name, request type, and real-time GPS location with a matched community volunteer during an active Bailout session. Community volunteers are other registered Invitrr users who have voluntarily opted into the volunteer program and agreed to the volunteer terms; they are not employees or agents of Invitrr.
We may disclose personal information to government authorities, regulatory bodies, law enforcement agencies, or courts of competent jurisdiction when we are required to do so by applicable law, court order, subpoena, search warrant, regulatory demand, or other lawful legal process. We review all such requests for legal validity before complying and, where we are not legally prohibited from doing so, we will make reasonable efforts to notify you of any request for your personal information before complying, to the extent technically and legally feasible. We maintain internal records of all government data requests we receive and our responses to them. We may also disclose personal information in the good-faith belief that such disclosure is reasonably necessary to prevent or address an imminent risk of serious harm to life or physical safety; to prevent, investigate, or respond to fraud, security threats, illegal activity, or abuse of the Services; to enforce our Terms of Service, Community Guidelines, or other agreements; or to protect the rights, property, and safety of Invitrr, our users, or third parties.
In connection with a merger, acquisition, consolidation, reorganization, financing, change of control, bankruptcy, or sale of all or substantially all of our assets, personal information may be transferred to the successor entity or acquirer as part of the transaction. We will notify you of any such transaction and of any resulting change in the identity of the data controller or the applicable privacy policy through a prominent notice in the application or on our website, and through a notification sent to your registered email address, no later than thirty (30) days prior to the effective date of any material change resulting from such transaction to the extent reasonably practicable.
SECTION 6 — INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION
Nohmit Incorporated is incorporated in and primarily operates from Ontario, Canada. Our technical infrastructure involves service providers located in multiple countries, including but not limited to the United States of America. As a result, personal information you provide may be transferred to, stored in, and processed in countries other than the country in which you reside, including countries whose data protection laws may offer a different level of protection than the laws of your home jurisdiction.
Canada's federal privacy legislation, PIPEDA, has been recognized by the European Commission as providing adequate protection for personal data transferred from the European Economic Area under Commission Decision 2002/2/EC. This adequacy decision applies to transfers of personal data from the EEA to organizations in Canada subject to PIPEDA. Nohmit Incorporated is subject to PIPEDA and processes personal data in a manner consistent with its requirements. For transfers of personal data to service providers located in the United States — including Twilio, OpenAI, AWS, Neon, and Upstash — we rely on appropriate safeguards including Standard Contractual Clauses approved by the European Commission (Commission Implementing Decision (EU) 2021/914), where applicable, and data processing agreements that impose privacy obligations on our service providers that are substantially equivalent to those required under PIPEDA and, where applicable, the GDPR. For users in Quebec, we conduct privacy impact assessments as required by Law 25 before communicating personal information outside of Quebec to third parties, and we ensure through contractual mechanisms that such information receives protection equivalent to that provided under Quebec law. Upon request, we will provide additional information about the specific safeguards in place for any particular international data transfer.
SECTION 7 — COOKIES, TRACKING TECHNOLOGIES, AND ANALYTICS
The Invitrr iOS application does not use cookies. The Invitrr website at invitrr.com may use technically necessary session cookies for the purpose of maintaining session state during your visit; these cookies expire at the end of your browsing session and are not used for tracking, advertising, or profiling purposes. We do not use third-party advertising cookies, tracking pixels, social media cookies, or any other third-party tracking technologies on our website or in our application. We do not participate in cross-site tracking, real-time bidding, programmatic advertising, interest-based advertising, or any other form of data sharing with advertising networks or data brokers. We do not integrate with Facebook Pixel, Google Analytics, or any third-party analytics SDK within our application. All behavioral analytics and recommendation data described in Section 3.2 of this Policy are collected and processed exclusively within Invitrr's own infrastructure and are never shared with third-party analytics providers.
SECTION 8 — DATA RETENTION
We retain personal information for as long as is necessary to fulfill the purposes for which it was collected, to comply with our legal obligations, to resolve disputes, and to enforce our agreements, as described in this Section. Our determination of appropriate retention periods takes into account the sensitivity of the personal information, the risk of harm that could result from unauthorized use or disclosure, the technical and operational feasibility of deletion, the purposes for which the data was collected, whether those purposes could reasonably be achieved by other means, and our legal obligations.
Personal information associated with an active user account is retained for the duration of the account. Upon account deletion — whether initiated by you through the in-app deletion process or by Invitrr as a result of a Terms of Service violation — your account is immediately deactivated, which immediately removes your profile from all discovery feeds and public display and revokes all active access tokens. Following deactivation, your personal information is permanently anonymised within twenty-four (24) hours. This includes your name, email address, phone number, profile photos, date of birth, and location data. Non-personal activity data may be retained in anonymised form to improve our services, consistent with applicable privacy law under which anonymised data does not constitute personal information. Certain categories of information are retained beyond the thirty-day erasure cascade for legal compliance purposes, including audit log records documenting account creation, policy acceptance, and significant administrative actions (retained for seven years); records of account suspensions and bans and associated moderation decisions (retained for seven years); report records submitted by or about you (retained for seven years); policy consent records (retained for seven years); subscription and transaction records (retained for the period required by applicable tax and financial record-keeping law, generally seven years); and identity verification records excluding the selfie image itself (retained for seven years). Your registration email address is retained in an exclusion list for the duration of any active ban to enable enforcement of ban decisions.
Behavioral event records are subject to a rolling ninety (90) day retention window, after which records older than ninety days are incorporated into the aggregate behavioral vector and the raw event records are permanently deleted, regardless of whether your account remains active. Location update records generated during Bailout safety sessions are retained for ninety (90) days following session resolution or expiry, after which they are permanently and irrecoverably deleted. Identity verification selfie images are retained for a maximum of twelve (12) months following the completion of the verification review, after which they are permanently deleted. Liveness challenge records, including frame upload references, are retained for a maximum of ten (10) minutes from challenge creation, after which they are permanently expired and deleted.
SECTION 9 — SECURITY OF YOUR PERSONAL INFORMATION
We implement and maintain technical, administrative, and organizational security measures designed to protect your personal information against unauthorized access, acquisition, use, disclosure, alteration, destruction, or other processing in violation of applicable law or our obligations to you. These measures include, without limitation: industry-standard JSON Web Token authentication with short-lived access tokens and rotating refresh tokens; industry-standard password hashing algorithms; Transport Layer Security (TLS) encryption for all data in transit between your device and our servers, with HTTP Strict Transport Security (HSTS) headers specifying a maximum age of 31,536,000 seconds with includeSubDomains and preload directives; certificate pinning enforced in the iOS application to prevent interception of traffic by unauthorized certificate authorities; a server-side API response filter that categorically strips sensitive internal fields — including password hashes, device tokens, social authentication identifiers, risk scores, risk factors, and other internal-only fields — from all API responses, regardless of any query parameters or request modifications; rate limiting enforced at both global and per-endpoint levels with stricter limits for sensitive operations; an IP reputation system that blocks known malicious IP addresses; input validation and sanitization applied to all request bodies using schema validation and HTML stripping; and append-only audit logging of all significant administrative and system actions for accountability and forensic purposes. Access to personal data within our organization is restricted on a need-to-know basis, and all administrative access to user data requires multi-factor authentication and generates an audit log entry. We conduct periodic reviews of our security controls and engage in ongoing security testing.
Notwithstanding the foregoing, no security system is impenetrable, and we cannot guarantee that your personal information will be secure in all circumstances. The security of your account also depends in part on your own practices, including your maintenance of the confidentiality of your account credentials, your use of a strong and unique password, your prompt notification to us of any unauthorized use of your account, and your maintenance of the physical security of the devices on which you use the Services. In the event of a security incident involving unauthorized access to or acquisition of your personal information that creates a real risk of significant harm to you, we will notify the applicable regulatory authority and, where required by law, affected individuals, in accordance with applicable breach notification requirements and within the timeframes specified by applicable law, including without limitation within seventy-two (72) hours of becoming aware of a qualifying breach for reporting to the Commission d'accès à l'information under Quebec Law 25, and without undue delay for reporting to the applicable supervisory authority under the GDPR.
SECTION 10 — YOUR RIGHTS AND HOW TO EXERCISE THEM
Subject to applicable law and certain exceptions, you have the following rights with respect to your personal information, exercisable by submitting a request to [email protected] with sufficient information for us to verify your identity, including your registered email address and, for sensitive requests, a completed identity verification challenge. We will respond to all rights requests within thirty (30) calendar days of receipt, with an extension of up to sixty (60) additional days where permitted and necessary given the complexity and number of requests, provided that we notify you of any such extension within the initial thirty-day period.
Right of Access. You have the right to request confirmation of whether we process personal information about you, and if so, to receive a copy of that personal information along with supplementary information about the processing. We provide a machine-readable data export in JSON format through the Settings > Privacy > Export My Data function in the application, which generates a comprehensive export of your personal information within thirty (30) days of the request being initiated. This export includes your profile data, preference data, behavioral data, conversation history, event history, request history, safety history, and other personal information associated with your account. The export does not include the following categories of information, which are exempt from access requests under applicable law or which constitute proprietary trade secrets: internal risk scores, risk factors, and risk classification; A/B experiment assignments; the specific weighting, scoring, or ranking values in your behavioral vector; moderation results pertaining to other users' content; internal audit log entries pertaining to the actions of other users; and any information that would reveal the personal information of other individuals or the confidential business processes of Nohmit Incorporated.
Right of Rectification. You have the right to correct inaccurate personal information and, where appropriate, to have incomplete personal information completed. You may update and correct most of your personal information directly through the profile editing features of the application, including your name, biography, vibe descriptor, interests, event preferences, city, and photographs. For information that cannot be corrected through in-app features, you may submit a correction request to [email protected] with a description of the information to be corrected and the correct information.
Right to Erasure. You have the right to request the deletion of your personal information in the circumstances provided by applicable law, including where the information is no longer necessary for the purposes for which it was collected, where you withdraw consent on which processing is based and there is no other legal ground for processing, where you object to processing based on legitimate interests and there are no overriding legitimate grounds, or where the processing is unlawful. You may initiate account deletion through the Settings > Account > Delete Account function in the application, which requires re-authentication and OTP verification before proceeding. Following your confirmed deletion request, we will process your erasure within thirty (30) days in the manner described in Section 8. The right to erasure is subject to exceptions where retention is required by applicable law or is necessary for the establishment, exercise, or defense of legal claims.
Right to Restriction of Processing. You have the right to request that we restrict the processing of your personal information in certain circumstances, including where you contest the accuracy of the information, where processing is unlawful and you prefer restriction to erasure, where we no longer need the information but you require it for legal claims, or where you have objected to processing pending verification of our legitimate grounds.
Right to Data Portability. You have the right to receive personal information that you have provided to us, in a structured, commonly used, and machine-readable format (JSON), and to transmit that information to another controller without hindrance from us, in circumstances where the processing is based on consent or contract and is carried out by automated means. This right is satisfied by our data export feature described under Right of Access above.
Right to Object. Where we process your personal information on the legal basis of legitimate interests, you have the right to object to such processing at any time by contacting [email protected]. We will cease processing your personal information on that basis unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms, or unless the processing is for the establishment, exercise, or defense of legal claims. You also have the right to object at any time to the processing of your personal information for direct marketing purposes, which we do not conduct without your prior opt-in consent.
Right to Withdraw Consent. Where we rely on your consent as a legal basis for processing — including your consent to real-time location sharing during Bailout sessions — you may withdraw that consent at any time without affecting the lawfulness of processing based on consent before its withdrawal. Withdrawal of consent for location sharing during a Bailout session may be effected by cancelling the session. Withdrawal of consent for optional profile fields may be effected by removing that information from your profile through the in-app editing features.
Right to Lodge a Complaint. You have the right to lodge a complaint with the applicable supervisory authority if you believe we have processed your personal information in violation of applicable privacy law. In Canada, the federal authority is the Office of the Privacy Commissioner of Canada (priv.gc.ca; 1-800-282-1376). For Quebec residents, the applicable authority is the Commission d'accès à l'information du Québec (cai.quebec.ca; 1-888-528-7741). For EEA residents, the applicable authority is the data protection authority of your member state. For UK residents, the applicable authority is the Information Commissioner's Office (ico.org.uk; 0303 123 1113). We encourage you to contact us first at [email protected] so that we may attempt to resolve your concern directly.
Automated Decision-Making. We use automated processing to personalize your event feed and to score and rank events for presentation to you. This automated processing does not produce decisions that have legal effects on you or that similarly significantly affect you; it produces a personalized event feed that is purely informational and leaves all consequential decisions — such as whether to request to attend an event, or whether a host accepts your request — to human judgment. You are not subject to any decision based solely on automated processing that produces legal or similarly significant effects, and no such processing occurs in connection with the Services.
SECTION 11 — JURISDICTION-SPECIFIC DISCLOSURES AND RIGHTS
11.1 Quebec, Canada — Law 25. In addition to the rights described in Section 10, residents of Quebec have the following rights and are entitled to the following additional disclosures. You have the right to request the de-indexing of any hyperlink associated with your name that provides access to personal information that could injure your reputation or violates your dignity, or that is used contrary to law or a court order. You have the right to request that personal information provided through the Services be communicated to you or to a person or body authorized by law or regulation in a structured, commonly used technological format. Our Services are designed to collect only the personal information that is necessary for the purposes identified in this Policy (principle of data minimization). We maintain a comprehensive inventory of personal information under our control, updated in connection with each revision to this Policy. We conduct privacy impact assessments before implementing new information systems or technologies that process personal information, and before communicating personal information outside of Quebec. Our Privacy Officer is responsible for overseeing our compliance with Law 25 and for receiving complaints. This Privacy Policy is available in French at invitrr.com/privacy/fr, and where required by law, the French version governs for Quebec residents in the event of any conflict between language versions.
11.2 European Economic Area and United Kingdom — GDPR / UK GDPR. In addition to the rights described in Section 10, residents of the EEA and UK have the following additional rights. You have the right to obtain information about the safeguards we have put in place for international transfers of your personal data, which you may request by contacting [email protected]. You have the right to lodge a complaint with your national supervisory authority as described in Section 10. We are committed to maintaining records of processing activities as required by Article 30 GDPR. To the extent required by Article 27 GDPR, we are in the process of identifying and engaging an EU/UK representative. Our lawful bases for each processing activity are identified in Section 4.
11.3 California, United States — CCPA/CPRA. California residents are entitled to the following additional disclosures. We do not sell or share personal information as those terms are defined under the CCPA/CPRA. We do not use sensitive personal information for any purpose other than those permitted under Cal. Civ. Code § 1798.121. The categories of personal information we collect are described in Section 3. The business purposes for which we collect personal information are described in Section 4. The categories of third parties with whom we share personal information are described in Section 5. We do not discriminate against you for exercising your CCPA/CPRA rights. To submit a CCPA/CPRA request, contact [email protected]; we will verify your identity before processing the request. You may designate an authorized agent to submit requests on your behalf by providing written authorization to [email protected].
SECTION 12 — CHILDREN'S PRIVACY
The Services are not directed to or intended for use by individuals under the age of eighteen (18). We do not knowingly collect personal information from individuals under eighteen (18). We do not knowingly collect personal information from children under thirteen (13) as defined under COPPA, and we do not knowingly process personal data of children under sixteen (16) as defined under Article 8 GDPR. We maintain age verification records as described in Sections 2 and 3. If we become aware that we have inadvertently collected personal information from an individual under eighteen (18), we will take immediate steps to suspend the account, notify the user by email, and permanently delete the associated personal information. If you have reason to believe that someone under eighteen (18) has created an account or submitted personal information to us, please notify us at [email protected] immediately.
SECTION 13 — LINKS TO THIRD-PARTY SERVICES
The Services may contain links to or integrations with third-party websites, applications, or services that are not owned, operated, or controlled by Nohmit Incorporated. This Privacy Policy does not apply to any third-party service. We have no control over and assume no responsibility for the privacy practices, terms, or content of any third-party service. We encourage you to review the privacy policies of any third-party services you access or use in connection with the Services.
SECTION 14 — CHANGES TO THIS PRIVACY POLICY
Nohmit Incorporated reserves the right to modify this Privacy Policy at any time. We will post the updated Policy at invitrr.com/privacy and update the "Last Updated" date at the top of this Policy. Where required by applicable law, we will provide you with advance notice of material changes to this Policy — by prominent notice in the application, by email to your registered address, or by both — and where the change involves a new or different legal basis or purpose for processing your personal information that requires your consent under applicable law, we will seek your renewed consent before proceeding. Your continued use of the Services after the effective date of any modification constitutes your acknowledgment of and agreement to the modified Policy. If you do not agree with any modification, your sole remedy is to cease using the Services and request deletion of your account.
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