Cup of tea Privacy Policy

Cup of tea is operated by Giantreferrals.com LLC.

Cup of tea provides an online marketplace and communications platform designed to allow individuals, businesses, hosts, creators, organizations, and other Experience Providers to discover, advertise, offer, purchase, arrange, and participate in Experiences.

For purposes of this Privacy Policy, the Cup of tea website, mobile applications, services, communications systems, marketplace, profiles, Experience listings, messaging features, and related services are collectively referred to as the “Platform” or “Services.”

Unless otherwise stated, Giantreferrals.com LLC is responsible for determining how personal information collected directly through Cup of tea is processed.

This Privacy Policy applies to personal information collected through:

• Cup of tea;
• Cup of tea mobile applications, if offered;
• Cup of tea user and business accounts;
• user profiles;
• Experience Provider profiles;
• Experience listings;
• bookings and purchases;
• payment and payout processes;
• reviews and ratings;
• member-to-member communications;
• member chat and user-number messaging;
• text message and notification services;
• customer service communications;
• complaints and dispute processes;
• promotional communications;
• surveys;
• safety and fraud-prevention systems; and
• other products or services that link to this Privacy Policy.

This Privacy Policy does not govern the independent privacy practices of third-party businesses, Experience Providers, payment processors, websites, applications, or other services that Cup of tea does not control.

Cup of tea is intended only for individuals who are 18 years of age or older.

You may not create a Cup of tea account or use the Platform if you are under 18.

We do not knowingly collect personal information from children under 18 through accounts intended for Platform participation.

If we learn that an individual under 18 has created an account or provided personal information in violation of our rules, we may suspend or terminate the account and take reasonable steps to delete the information, subject to legal, safety, fraud-prevention, and record-retention requirements.

A parent or legal guardian who believes a minor has provided personal information to Cup of tea may submit a privacy request through the contact methods provided on Cup of tea.

The information we collect depends upon how you use Cup of tea.

A. Account and Identification Information

When you register or maintain an account, we may collect information such as:

• name;
• username or user number;
• email address;
• telephone number;
• date of birth or age;
• password or authentication credentials;
• account status;
• verification information;
• profile information;
• preferences; and
• other information necessary to create and administer your account.

We may also collect information reasonably necessary to verify that you meet the Platform’s eligibility requirements.

B. Profile Information

Depending upon the features you use, your profile may contain information such as:

• first name or display name;
• age;
• general location;
• photographs;
• biography or personal description;
• interests;
• activities;
• preferences;
• matching or Experience criteria;
• Experiences you are interested in attending or providing;
• reviews or ratings; and
• other information you choose to make available through your profile.

Certain profile information is intended to be visible to other Cup of tea users.

You should not place information in a public profile that you do not want other people to see.

C. Profile Photographs and Media

Cup of tea may require certain members to upload profile photographs, including:

• a recognizable photograph showing the member’s face; and
• a current full-body photograph.

Photographs must comply with Cup of tea’s Terms of Service and Community Guidelines, including restrictions concerning nudity, sexually explicit material, impersonation, misleading photographs, and prohibited content.

We may process photographs and related metadata to:

• display your profile;
• administer the Platform;
• enforce Platform rules;
• detect fraud or impersonation;
• investigate complaints;
• protect members; and
• maintain the integrity and safety of Cup of tea.

Cup of tea does not claim ownership of your photographs merely because you upload them. Rights concerning user content are governed by the Cup of tea Terms of Service.

D. Experience Information

When you create, advertise, purchase, book, host, provide, review, or participate in an Experience, we may collect information concerning:

• the Experience;
• location;
• date and time;
• price;
• availability;
• participants;
• Provider;
• booking status;
• purchase history;
• cancellations;
• refunds;
• communications;
• reviews;
• complaints;
• photographs or media;
• transaction records; and
• other information related to the Experience.

E. Business and Experience Provider Information

If you operate as a business, host, creator, organization, or other Experience Provider, we may collect:

• business or organization name;
• contact information;
• business address;
• responsible-person information;
• Experience listings;
• photographs;
• business credentials;
• licenses or permits when relevant;
• tax information when legally required;
• payout information;
• transaction information;
• customer-service records;
• complaint history;
• verification information; and
• other information reasonably necessary to administer your participation in the marketplace.

F. Payment and Transaction Information

When you make or receive payments through Cup of tea, we or our payment-processing partners may collect information necessary to process the transaction.

This may include:

• payment method;
• billing information;
• transaction amount;
• purchase information;
• refunds;
• chargebacks;
• payment status;
• payout information; and
• transaction identifiers.

Cup of tea may use third-party payment processors.

Complete payment-card numbers and banking credentials may be collected and processed directly by those payment processors rather than stored by Cup of tea.

Information provided directly to a payment processor is also governed by that provider’s privacy practices.

G. Messages and Communications

Cup of tea may provide member chat, user-number messaging, Experience communications, notifications, or similar communication features.

We may collect and retain:

• messages sent through the Platform;
• sender and recipient identifiers;
• message timestamps;
• delivery information;
• reports concerning messages;
• communications with customer support; and
• communications concerning complaints, safety issues, transactions, or disputes.

Cup of tea may access or review communications when reasonably necessary to:

• provide the messaging service;
• investigate reported conduct;
• prevent fraud;
• protect users;
• enforce our Terms of Service;
• investigate suspected illegal activity;
• resolve disputes;
• comply with law; or
• protect Cup of tea, Giantreferrals.com LLC, our users, or third parties.

Users should not assume that communications made through Cup of tea are confidential from Cup of tea.

H. Reviews, Complaints and Safety Information

When you submit or become the subject of a review, complaint, report, or dispute, we may collect:

• the identities of the parties involved;
• descriptions of the incident;
• communications;
• photographs;
• documents;
• transaction information;
• witness information;
• safety information;
• fraud indicators;
• investigation notes;
• decisions;
• account restrictions; and
• other information relevant to the matter.

Cup of tea may maintain records concerning complaints and violations for safety, fraud prevention, dispute resolution, and enforcement purposes.

As provided in the Cup of tea Terms of Service, repeated unresolved complaints, including three unresolved complaints where applicable under Platform rules, may result in suspension or termination. Serious misconduct may result in immediate action regardless of the number of prior complaints.

I. Device, Internet and Technical Information

When you access Cup of tea, we may automatically collect information such as:

• Internet Protocol address;
• browser type;
• device type;
• operating system;
• device identifiers;
• language;
• referring pages;
• pages viewed;
• links clicked;
• login activity;
• session information;
• crash information;
• approximate geographic location derived from an IP address;
• cookie identifiers; and
• other technical and usage information.

J. Location Information

Cup of tea may use location information to help users discover Experiences, businesses, or members within a particular geographic area.

Depending upon the feature and your device permissions, this may include:

• city;
• ZIP Code;
• approximate location; or
• precise device location if a feature requires it and applicable permission has been obtained.

Where required by law, we will request permission before collecting precise geolocation information.

You may be able to disable device-location permissions through your device settings, although doing so may prevent certain Cup of tea features from functioning properly.

K. Cookies and Similar Technologies

Cup of tea and our service providers may use:

• cookies;
• pixels;
• software development kits;
• local storage;
• tags;
• analytics tools; and
• similar technologies.

These technologies may be used to:

• keep users logged in;
• remember preferences;
• secure accounts;
• detect fraud;
• understand Platform usage;
• measure performance;
• improve Services;
• personalize content;
• measure advertising; and
• provide advertising where permitted.

Additional information may be provided through a Cup of tea Cookie Notice or privacy-preference interface.

L. Information From Third Parties

We may receive information about you from:

• Experience Providers;
• other Cup of tea users;
• payment processors;
• identity or fraud-prevention services;
• communications providers;
• analytics providers;
• advertising or marketing providers;
• publicly available sources;
• social-media or other services you choose to connect;
• business partners; and
• law-enforcement or governmental authorities where legally appropriate.

Certain information processed by Cup of tea may be considered “sensitive personal information,” “sensitive data,” or a similar category under applicable privacy laws.

Depending upon the Services used, this could include information relating to:

• precise geolocation;
• government-issued identification;
• account authentication;
• payment information;
• identity verification;
• age verification;
• accessibility requirements; or
• information voluntarily disclosed by a user that receives special protection under applicable law.

We process sensitive personal information only for purposes reasonably necessary and proportionate to providing the Services, maintaining security, processing transactions, satisfying legal obligations, protecting users, or for another disclosed purpose permitted by applicable law.

Where consent is legally required, we will obtain consent.

Please exercise caution before voluntarily placing sensitive information in your public profile, Experience listing, review, or other content visible to other users.

We may use personal information to:

A. Provide the Platform

Including to:

• create and administer accounts;
• authenticate users;
• display profiles;
• display Experience listings;
• facilitate Experience discovery;
• process bookings and purchases;
• facilitate payments and payouts;
• administer refunds;
• facilitate member communications;
• provide notifications;
• publish reviews and ratings; and
• provide other requested Services.

B. Personalize Cup of tea

We may use information to:

• recommend Experiences;
• organize search results;
• display relevant content;
• understand user preferences; and
• improve the relevance of the Platform.

C. Facilitate Connections

Because Cup of tea is designed to connect people with Experiences, businesses, hosts, creators, organizations, and other participants, we use profile, preference, location, and activity information to facilitate those connections.

D. Operate the Marketplace

We may process information to:

• manage Experience listings;
• administer Provider accounts;
• calculate fees;
• process transactions;
• administer subscriptions and listing charges;
• administer Platform commissions;
• handle refunds;
• prevent circumvention of Platform fees; and
• maintain transaction records.

E. Protect Users and the Platform

We may process information to:

• detect fraud;
• identify fake accounts;
• detect impersonation;
• investigate harassment;
• investigate threats;
• investigate exploitation;
• investigate discrimination;
• detect illegal activity;
• investigate payment fraud;
• detect unauthorized scraping or data harvesting;
• enforce Platform rules;
• investigate complaints;
• suspend accounts;
• ban users;
• prevent banned users from creating new accounts; and
• protect the safety and security of users and the Platform.

F. Customer Service

We may use information to:

• respond to inquiries;
• troubleshoot problems;
• investigate complaints;
• resolve disputes;
• process refunds;
• address payment issues; and
• provide technical support.

G. Improve Cup of tea

We may analyze information to:

• understand Platform usage;
• identify popular Experiences;
• develop new features;
• improve existing features;
• improve search and recommendations;
• evaluate Platform performance;
• test functionality; and
• conduct research and analytics.

Where practical and appropriate, we may use aggregated or de-identified information for these purposes.

H. Communications

We may use your contact information to send:

• account notifications;
• security alerts;
• booking confirmations;
• purchase confirmations;
• Experience updates;
• cancellation notices;
• refund information;
• messages from other users;
• customer-service communications;
• policy notices; and
• other transactional or service-related communications.

I. Marketing

Subject to applicable law and your choices, we may use information to provide information concerning:

• Cup of tea;
• Experiences;
• Platform features;
• promotions;
• offers;
• businesses or Experience Providers; and
• other content we believe may interest users.

Where required, marketing communications will include an appropriate method to unsubscribe or opt out.

J. Legal and Regulatory Purposes

We may process information to:

• comply with laws;
• respond to subpoenas and court orders;
• respond to valid governmental requests;
• satisfy tax and accounting requirements;
• maintain legally required records;
• establish or defend legal claims;
• protect our legal rights; and
• enforce the Cup of tea Terms of Service and other agreements.

We may disclose personal information in the circumstances described below.

A. With Other Cup of tea Users

Cup of tea is a social and marketplace platform. Information you place in your public profile or public Experience listing is intended to be seen by other users.

Depending upon Platform features and your settings, other users may see information such as:

• your display name;
• photographs;
• age;
• approximate location;
• biography;
• interests;
• Experience preferences;
• Experience listings;
• ratings;
• reviews; and
• other information you choose to make public.

Other users may copy, screenshot, record, download, or redistribute information they can view.

Cup of tea cannot control information after another person has lawfully viewed or obtained it.

You should therefore carefully consider what information you make public.

B. With Experience Providers and Participants

When you purchase, book, provide, or participate in an Experience, we may disclose information reasonably necessary to facilitate the Experience.

This may include:

• name or user identifier;
• contact information where appropriate;
• booking information;
• Experience details;
• payment status;
• communications;
• accessibility information voluntarily supplied for the Experience; and
• other information necessary to provide the Experience.

Experience Providers may independently process information they receive in connection with an Experience.

C. With Service Providers

We may disclose personal information to vendors that provide services such as:

• website hosting;
• cloud storage;
• payment processing;
• fraud prevention;
• identity verification;
• communications;
• SMS delivery;
• email delivery;
• analytics;
• customer service;
• security;
• data storage;
• advertising;
• marketing;
• professional services; and
• technical infrastructure.

We require service providers to process information in accordance with applicable contractual and legal obligations.

D. Payment Processors

Payment information may be provided directly to payment processors for purposes including:

• purchases;
• subscriptions;
• Experience payments;
• listing fees;
• Platform fees;
• payouts;
• refunds;
• chargebacks; and
• fraud prevention.

E. Legal Authorities and Legal Proceedings

We may disclose information when we reasonably believe disclosure is necessary or appropriate to:

• comply with applicable law;
• respond to legal process;
• respond to a subpoena, warrant, or court order;
• cooperate with lawful governmental investigations;
• prevent or investigate crime;
• protect a person’s safety;
• investigate fraud;
• enforce our agreements; or
• establish, exercise, or defend legal claims.

F. Safety and Enforcement

We may disclose relevant information when reasonably necessary to investigate or prevent:

• fraud;
• threats;
• harassment;
• violence;
• exploitation;
• unlawful discrimination;
• illegal conduct;
• payment fraud;
• cybersecurity incidents; or
• other conduct that may endanger Cup of tea, its users, or third parties.

G. Corporate Transactions

If Giantreferrals.com LLC or Cup of tea is involved in a:

• merger;
• acquisition;
• financing;
• reorganization;
• bankruptcy;
• sale of assets;
• change of control; or
• similar corporate transaction,

personal information may be disclosed or transferred as part of that transaction, subject to applicable law.

H. At Your Direction or With Your Consent

We may disclose information to another person or organization when you direct us to do so or provide legally valid consent.

Some Cup of tea content may be public.

Public profiles, Experience listings, reviews, photographs, Provider information, and other publicly available content may potentially:

• appear in search-engine results;
• be linked from other websites;
• be shared through social media;
• be copied by other users;
• be archived by third parties; or
• remain available elsewhere after you remove it from Cup of tea.

Cup of tea cannot guarantee deletion of copies independently created or maintained by third parties.

Do not publish information through a public portion of Cup of tea unless you are comfortable with others viewing it.

Messages transmitted through Cup of tea may be processed and stored by Cup of tea and its service providers.

We may use automated tools and, where appropriate, authorized personnel to identify or investigate:

• spam;
• scams;
• fraud;
• threats;
• harassment;
• prohibited commercial activity;
• exploitation;
• illegal activity;
• circumvention of Platform fees; and
• violations of Cup of tea policies.

We do not represent that communications through the Platform are end-to-end encrypted unless Cup of tea expressly identifies a particular feature as end-to-end encrypted.

Do not use Cup of tea messaging to transmit Social Security numbers, financial-account passwords, payment-card numbers, medical records, or other information that is unnecessary for the Experience.

If you provide a mobile telephone number, Cup of tea may send transactional messages relating to:

• account security;
• login verification;
• messages;
• bookings;
• purchases;
• Experience changes;
• cancellations;
• refunds;
• complaints;
• safety matters; and
• other Platform activity.

Marketing text messages will be sent only where permitted by law and, when legally required, after obtaining appropriate consent.

Consent to receive marketing text messages is not a condition of purchasing any goods or services.

Message and data rates may apply.

Users receiving marketing SMS messages may generally reply STOP to unsubscribe and HELP for assistance, subject to the instructions contained in the applicable message.

Stopping marketing messages will not necessarily stop transactional, security, or account-related communications permitted by law.

Cup of tea may use analytics and advertising technologies to understand how people use the Platform and, where permitted, to provide or measure advertising.

Depending upon the technologies implemented, information used for these purposes may include:

• cookie identifiers;
• device identifiers;
• IP address;
• browser information;
• Platform activity;
• pages viewed;
• advertisements viewed;
• general location; and
• interactions with Experiences or content.

Where applicable law provides a right to opt out of targeted advertising, cross-context behavioral advertising, the sale or sharing of personal information, or similar processing, Cup of tea will provide an appropriate privacy-control mechanism.

Cup of tea does not sell personal information for money in the ordinary meaning of the word “sell.”

However, certain state privacy laws define “sale,” “sharing,” or “targeted advertising” broadly enough that some advertising or analytics disclosures involving cookies or device identifiers may be treated as a sale or sharing even when no money is exchanged for the individual’s information.

Where required by law, Cup of tea will provide users with the ability to opt out of such activity through a “Your Privacy Choices,” “Do Not Sell or Share My Personal Information,” or substantially similar privacy control.

Cup of tea will honor legally recognized browser-based opt-out preference signals, such as Global Privacy Control, where required by applicable law and technically applicable.

Depending upon where you live, you may have the right to:

• know whether we process your personal information;
• request access to personal information;
• obtain a copy of personal information;
• correct inaccurate information;
• delete personal information;
• request portability of certain information;
• opt out of certain targeted advertising;
• opt out of certain sales or sharing of personal information;
• limit certain uses of sensitive personal information;
• withdraw consent where processing is based upon consent;
• appeal certain privacy-request decisions; and
• receive equal service without unlawful discrimination for exercising privacy rights.

These rights are subject to applicable law and certain exceptions.

For example, we may retain information when reasonably necessary to:

• complete a transaction;
• provide requested Services;
• protect users;
• detect fraud;
• maintain security;
• prevent banned users from returning;
• comply with legal obligations;
• exercise or defend legal claims; or
• preserve evidence relating to disputes or misconduct.

You may submit a privacy request through the privacy-request or contact functionality provided on Cup of tea.

When submitting a request, we may need to verify your identity.

Verification may require information reasonably necessary to confirm that the person making the request is the person to whom the information relates.

We will use verification information only for appropriate verification, security, fraud-prevention, and legal-compliance purposes.

Where permitted by law, an authorized agent may submit certain requests on your behalf. We may require evidence of the agent’s authority and may require you to verify your identity directly.

We will respond within the period required by applicable law.

If we deny a request, in whole or in part, we will provide an explanation when required by law.

Residents of jurisdictions providing a right to appeal may submit an appeal through the privacy contact mechanism available on Cup of tea.

This section applies to California residents to the extent required by the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA/CPRA”).

Depending upon your interactions with Cup of tea, we may collect the following categories of personal information:

• identifiers;
• customer-record information;
• characteristics protected under applicable law when voluntarily provided or otherwise lawfully processed;
• commercial information;
• Internet or electronic network activity;
• geolocation information;
• audio, electronic, visual, or similar information;
• professional or employment-related information concerning certain Providers;
• inferences derived from other information; and
• sensitive personal information where applicable.

We collect these categories for the business and commercial purposes described in this Privacy Policy.

We may disclose these categories to the categories of recipients described in this Privacy Policy, including service providers, Experience Providers, users, payment processors, professional advisers, advertising or analytics partners where applicable, governmental authorities, and parties involved in corporate transactions.

California residents may have the right to:

• know what personal information we collect;
• request access;
• request correction;
• request deletion;
• obtain information concerning categories of disclosures;
• opt out of sale or sharing where applicable;
• limit certain uses or disclosures of sensitive personal information where applicable; and
• exercise these rights without unlawful discrimination.

Cup of tea does not sell personal information for monetary compensation.

If Cup of tea engages in activities considered “sharing” for cross-context behavioral advertising under California law, California residents may opt out through the privacy controls provided on the Platform.

We will process Global Privacy Control signals where legally required.

Residents of states that provide comprehensive consumer privacy rights may have additional rights concerning:

• access;
• correction;
• deletion;
• portability;
• targeted advertising;
• sale of personal information;
• profiling;
• sensitive data;
• consent withdrawal; and
• appeals.

This may include rights available under applicable privacy laws in states such as Connecticut, Texas, and other jurisdictions as their laws become applicable to Cup of tea.

Cup of tea will honor applicable rights based upon the law governing the requesting consumer.

Nothing in this Privacy Policy is intended to restrict rights granted by applicable law.

Cup of tea does not intend to collect or use biometric identifiers for identification purposes unless we specifically disclose that feature and obtain any consent required by applicable law.

Ordinary photographs uploaded to a profile are not intentionally used by Cup of tea to create biometric identifiers unless Cup of tea separately informs users that a biometric-processing feature is being implemented.

If biometric technology is introduced in the future, Cup of tea will provide any additional notice and consent required by applicable law before implementing the applicable processing.

Cup of tea uses reasonable administrative, technical, and organizational safeguards designed to protect personal information against:

• unauthorized access;
• unauthorized disclosure;
• alteration;
• destruction;
• loss;
• misuse; and
• fraudulent access.

Security measures may include, where appropriate:

• authentication controls;
• access restrictions;
• encryption;
• monitoring;
• fraud detection;
• secure hosting;
• vendor controls;
• logging; and
• incident-response procedures.

However, no Internet service, website, mobile application, database, or electronic transmission can be guaranteed to be completely secure.

Users are responsible for maintaining the confidentiality of their passwords and account credentials.

If you believe your Cup of tea account has been compromised, contact Cup of tea immediately through the support or security contact functionality available on Cup of tea.

We retain personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, including to provide the Services and satisfy safety, fraud-prevention, accounting, tax, dispute-resolution, and legal obligations.

Retention periods depend upon the type of information and why it was collected.

After an account is closed, certain information may continue to be retained when reasonably necessary to:

• investigate misconduct;
• protect users;
• prevent fraud;
• prevent banned users from creating new accounts;
• process or defend chargebacks;
• resolve outstanding transactions;
• comply with tax or accounting requirements;
• respond to subpoenas or legal holds;
• establish, exercise, or defend legal claims;
• document acceptance of contracts and policies; or
• satisfy other legal obligations.

Information associated with serious safety violations, fraud, or account bans may be retained for a longer period when reasonably necessary to prevent recurrence and protect the Platform and its users.

When personal information is no longer reasonably necessary, we may delete, anonymize, or de-identify it, subject to applicable law and technical limitations.

Backups may retain information for a limited additional period until overwritten through normal backup cycles.

Users may request account deletion through available account settings or Cup of tea’s privacy-request process.

Deleting the Cup of tea application from a device, if an application is offered, does not necessarily delete your account.

Following an account-deletion request:

• your profile may cease to be publicly available;
• active listings may be removed;
• access to Platform features may end; and
• personal information will be deleted or de-identified according to our retention practices and applicable law.

Some information may remain where retention is legally permitted or required, including information concerning transactions, fraud, safety incidents, disputes, account bans, legal claims, and regulatory obligations.

We may create aggregated, anonymized, or de-identified information that cannot reasonably be used to identify an individual.

We may use this information for:

• analytics;
• research;
• business planning;
• Platform improvement;
• fraud prevention;
• marketplace analysis;
• reporting; and
• development of new features.

Where required by law, we will maintain de-identified information in de-identified form and will not attempt to re-identify it except as permitted to verify the effectiveness of de-identification measures or otherwise allowed by law.

Cup of tea may contain links to websites, businesses, Experience Providers, social networks, maps, payment services, or other third-party services.

Cup of tea does not control the privacy practices of independent third parties.

If you leave Cup of tea or provide information directly to a third party, that party’s privacy policy may govern its collection and use of your information.

Users should review the privacy policies of third-party services before providing personal information.

Businesses and Experience Providers receiving personal information through Cup of tea must use that information only for lawful purposes consistent with the applicable Experience, Cup of tea’s Terms of Service, and applicable law.

Experience Providers may not use Cup of tea personal information to:

• harass users;
• discriminate unlawfully;
• send unlawful marketing;
• commit fraud;
• impersonate another person;
• scrape or compile unauthorized databases;
• sell unauthorized user lists;
• circumvent Platform rules; or
• engage in unlawful activity.

An Experience Provider may independently be responsible for its own privacy obligations concerning information it collects directly from participants.

Cup of tea is operated in the United States.

Personal information may be processed or stored in states or countries different from the jurisdiction in which you reside, including locations where our service providers operate.

When required by applicable law, we will use appropriate safeguards for transfers of personal information.

By using the Platform, you understand that information may be processed in the United States and other jurisdictions consistent with applicable law.

Users may receive transactional emails relating to:

• account activity;
• Experiences;
• purchases;
• bookings;
• cancellations;
• refunds;
• security;
• messages;
• complaints;
• policy updates; and
• customer support.

Where required, promotional emails will contain an unsubscribe mechanism.

Unsubscribing from promotional communications does not prevent us from sending non-promotional communications necessary to administer your account, transactions, security, or relationship with Cup of tea.

Cup of tea has a legitimate interest in maintaining records necessary to protect users and prevent people removed for serious misconduct from immediately creating new accounts.

Accordingly, following suspension or termination, we may retain limited information reasonably necessary to:

• identify previously banned accounts;
• prevent fraud;
• investigate serious complaints;
• respond to law enforcement;
• protect users;
• enforce the Terms of Service; and
• defend legal claims.

Such information may include identifiers, account history, complaint records, fraud indicators, device or technical information, and records concerning the reason for enforcement.

Retention will be limited to what we reasonably determine is necessary and permitted by applicable law.

Where applicable law requires identification of a legal basis for processing, we may rely upon:

Contract

Processing necessary to provide the Services you request or perform our agreement with you.

Legitimate Interests

Processing reasonably necessary for legitimate business interests such as:

• Platform security;
• fraud prevention;
• user safety;
• customer support;
• service improvement;
• analytics;
• enforcement of agreements; and
• protection of legal rights.

Consent

Where required, we may process information based upon your consent.

You may withdraw consent as permitted by applicable law, although withdrawal does not affect processing that was lawful before withdrawal.

Legal Obligations

We may process information when necessary to comply with applicable laws, regulations, court orders, governmental requirements, tax obligations, or other legal duties.

Cup of tea may use automated systems to assist with:

• search;
• Experience recommendations;
• spam detection;
• fraud detection;
• security;
• content moderation;
• account protection;
• suspicious activity detection; and
• Platform improvement.

Automated systems may consider factors such as account activity, preferences, location, Experience history, Platform interactions, reports, or technical information.

Where applicable law provides rights concerning certain automated decisions producing legal or similarly significant effects, Cup of tea will provide those rights as required.

Some browsers transmit “Do Not Track” signals.

Because no single industry standard governs all Do Not Track signals, Cup of tea may not respond to traditional Do Not Track signals except where required by law.

Where applicable law requires recognition of a legally valid universal opt-out mechanism, including Global Privacy Control (GPC), Cup of tea will process the signal as required by applicable law.

Depending upon the Platform features available to you, privacy choices may include:

• editing profile information;
• changing communication preferences;
• controlling device-location permissions;
• managing cookies;
• opting out of marketing emails;
• opting out of marketing text messages;
• controlling certain advertising technologies;
• submitting access requests;
• requesting correction;
• requesting deletion;
• opting out of applicable sale or sharing;
• limiting certain sensitive-information processing; and
• deleting your account.

Cup of tea may provide a “Your Privacy Choices” link or similar privacy-management interface through the Platform.

Cup of tea provides tools designed to help people connect and participate in Experiences, but users are responsible for exercising reasonable judgment when sharing information.

We strongly recommend that users avoid publicly posting:

• Social Security numbers;
• driver’s-license numbers;
• passport numbers;
• financial-account numbers;
• payment-card numbers;
• passwords;
• home-security information;
• medical records; or
• other highly sensitive information not necessary to use Cup of tea.

Users should exercise particular caution when communicating with people they have not previously met.

You may not upload, publish, disclose, or distribute another person’s private personal information through Cup of tea unless you have a lawful basis and any permission required to do so.

This includes private:

• addresses;
• telephone numbers;
• financial information;
• identification documents;
• private photographs;
• private communications; and
• other sensitive personal information.

Users must comply with applicable privacy and publicity laws when posting photographs or information concerning other people.

If Cup of tea discovers a security incident involving personal information, we will investigate and respond in accordance with applicable law.

Where legally required, we will notify affected individuals, regulators, law enforcement, or other appropriate parties.

Notification may be provided electronically where permitted by law.

Certain Experience Providers or businesses may independently determine how they process information they receive outside Cup of tea.

For example, if you provide information directly to a business after purchasing an Experience, that business may have independent legal obligations regarding that information.

Cup of tea is not responsible for an independent business’s use of personal information outside Cup of tea except to the extent responsibility cannot lawfully be excluded.

Users should review an Experience Provider’s privacy practices when appropriate.

We may update this Privacy Policy periodically to reflect:

• changes to Cup of tea;
• new features;
• new technologies;
• changes in business practices;
• changes in legal requirements; or
• changes in privacy practices.

When we make material changes, we may provide notice through:

• Cup of tea;
• your account;
• email;
• Platform notifications; or
• another legally permitted method.

The date at the beginning of this Privacy Policy identifies when the Policy was most recently updated.

Where applicable law requires consent to a material change, we will request consent before applying the change as required.

This Privacy Policy forms part of the policies governing use of Cup of tea.

The Cup of tea Terms of Service govern contractual matters concerning use of the Platform.

This Privacy Policy governs Cup of tea’s collection, use, disclosure, retention, and protection of personal information.

If a provision of this Privacy Policy conflicts with a mandatory privacy right provided by applicable law, the applicable law controls.

Cup of tea privacy matters are administered by:

Giantreferrals.com LLC Cup of tea

Users may contact Cup of tea regarding privacy questions, privacy-rights requests, account deletion, data-access requests, or privacy complaints through the Privacy Request or Contact Us functionality provided on Cup of tea.

Privacy requests should include sufficient information to allow Cup of tea to identify the account and understand the request.

Do not send passwords, complete payment-card numbers, Social Security numbers, or other unnecessary sensitive information when submitting a privacy request.

By creating a Cup of tea account or using the Platform, you acknowledge that you have been provided this Privacy Policy and have had an opportunity to review it.

Where applicable law requires affirmative consent for a particular form of processing, Cup of tea will obtain that consent separately.

Your continued use of Cup of tea after a Privacy Policy update constitutes acknowledgment of the updated Privacy Policy to the extent permitted by applicable law, but does not substitute for consent where applicable law specifically requires affirmative consent.

Cup of tea’s business depends upon people being willing to interact, communicate, purchase Experiences, provide Experiences, and meet other participants through the Platform.

Maintaining appropriate privacy, security, transparency, and user control is therefore an important part of operating Cup of tea.

We intend to collect and use personal information only for legitimate Platform, marketplace, safety, business, and legal purposes consistent with this Privacy Policy and applicable law.