LEVELS Pre-Launch
1. INTRODUCTION
Sollia LLC (“Sollia,” “we,” “us,” or “our”) operates the pre-launch landing page (the “Landing Page”) for the LEVELS dating app (the “app”) and associated waitlist and giveaway sign-up form (the “Form”). We are committed to protecting the privacy and security of your personal information. This Privacy Policy explains what personal information we collect when you visit the Landing Page or submit information through the Form, how we use and protect that information, and your legal rights with respect to it. By accessing the Landing Page or submitting information through the Form, you acknowledge that you have read, understood, and agree to the practices described herein. We collect only the minimum personal information reasonably necessary to administer the waitlist, the Giveaway, and related communications described in this Privacy Policy. This Privacy Policy applies solely to the Landing Page and Form and does not apply to third-party websites or platforms linked to or from the Landing Page, including but not limited to Google, Instagram, and Meta Platforms, Inc., each of which operates under its own privacy policy. The Form itself is built and hosted using Google Forms under Sollia’s own Google Workspace account, subject to the Cloud Data Processing Addendum between Sollia and Google. When you submit personal information through the Form, Sollia is the controller of that information, and Google processes it solely on Sollia’s behalf and instructions, as described in Section 6.1 below. This is separate from the Google Account sign-in used to access the Form: your use of your own Google Account to sign in is governed by Google’s own account terms and privacy policy, and Sollia does not control how Google manages your Google Account itself.
2. WHO WE ARE
Sollia LLC (“Sollia”) is the data controller responsible for your personal information collected through the Landing Page and Form. The LEVELS dating app is operated by Sollia LLC. Privacy Contact Email: privacy@levelsdating.com · Legal Backup Email: legal@solliahq.com · Company Social Media: @solliahq · State of Formation: Florida, United States. All privacy-related requests, questions, and concerns should be directed to privacy@levelsdating.com. If you are unable to reach us there, you may also contact legal@solliahq.com.
3. INFORMATION WE COLLECT
3.1 Information You Provide Directly
When you complete the sign-up Form on the Landing Page, we collect the following categories of personal information: • Full Name - to identify you on the waitlist and to administer the Giveaway and any prizes awarded. • Phone Number - for waitlist communications and, where separately consented to, SMS notifications about the App launch and founding member offers. • Email Address - for waitlist communications, marketing updates, and prize notifications. • Instagram Handle (optional) - solely to verify your eligibility for the Giveaway, including confirming that you follow @thelevelsapp on Instagram. • How You Found Out About Us - to help us understand the effectiveness of our marketing channels. • Referral Information (optional) - if you were referred by another person, we collect the referrer’s name and phone number solely to credit that person with a bonus Giveaway entry. • ZIP Code and Eligible Area Self-Certification - if you enter the Giveaway, we collect your ZIP code and your confirmation that you reside within the geographic area eligible for the Giveaway, solely to administer Giveaway eligibility as described in the Official Giveaway Rules & Promotion Terms. • Google Account Identifier - if you sign in to a Google Account to submit the Form, the email address associated with that Google Account is automatically recorded with your submission. This is used solely to prevent duplicate, automated, or fraudulent entries and to enforce the one-entry-per-person limit described in the Official Giveaway Rules & Promotion Terms. This identifier may be the same as, or different from, the Email Address you separately provide in the Form.
3.2 Information Collected Automatically
When you visit the Landing Page, we and the third-party platforms we use to host and operate it may automatically collect certain technical information, including your IP address and approximate geographic location, browser type and version, device type and operating system, pages viewed and time spent on the Landing Page, and referring URL. This information is collected through cookies and similar technologies, as further described in Section 9.
3.3 Information We Do Not Collect At Sign-Up
Through the Landing Page and Form specifically, we do not currently collect government-issued identification numbers, biometric data, financial account or payment details, health or medical information, real-time location data, or private communications. We do not knowingly collect personal information from individuals under the age of 18. However, if you are selected as a potential Giveaway winner, we may separately request identity verification documents - which may include a copy of government-issued identification and, where applicable, a photograph holding such identification - solely for the purposes described in Section 3.5 below. This identity verification data is not collected from entrants generally, only from selected potential winners as part of the winner-verification process described in the Official Giveaway Rules & Promotion Terms.
3.4 Forward-Looking Disclosure: Data to Be Collected in the LEVELS dating app
We include this section to provide advance transparency about personal information that will be collected when the LEVELS dating app launches. This disclosure is provided in accordance with applicable law and Apple App Store and Google Play Store requirements. All data collection within the app will be subject to explicit consent, full in-app disclosure, and a separate, comprehensive Privacy Policy that users must accept before accessing the app. Categories of data anticipated to be collected in the App include: • Identity and Age Verification Data: government-issued identification documents and images collected solely to verify user identity and confirm users are 18 years of age or older. • Biometric Identifiers: data derived from identity verification processes, used solely for authentication and account security. • Precise Geolocation Data: collected with explicit consent to support location-based matching and optional in-app safety features. • Profile Information: such as name, age, preferences, interests, photographs, and user-provided content. • Communications Data: messages and content exchanged within the app, which may be subject to automated moderation for safety purposes. • Usage and Behavioral Data: information about how users interact with the App, used to improve functionality, user experience, and match quality through proprietary systems. A comprehensive Privacy Policy addressing all of the above will be published prior to the App’s public launch. Users will be required to accept that policy before accessing the app.
3.5 Identity Verification Data for Giveaway Winners
We do not collect government-issued identification during Giveaway entry. If you are selected as the Grand Prize potential winner, we will request identity verification documents, which include a copy of government-issued identification and a photograph of you holding that identification, solely for the purposes of (a) confirming eligibility (including age and residency within the Eligible Area described in the Official Giveaway Rules & Promotion Terms) and (b) administering prize fulfillment or preventing fraud in connection with the Giveaway. Founding Member and Runner-Up potential winners are not asked for this documentation unless Sollia reasonably determines it is necessary to resolve a specific eligibility concern. This identity verification data is used only for the purposes described above and is not used for any other purpose, including marketing. These documents are collected through a Google Form and stored in Google Drive under our Google Workspace account, which is subject to the Cloud Data Processing Addendum described in Section 6.1. Access to these documents is limited to personnel who need it to verify eligibility and administer prize fulfillment. Copies of identity verification documents are retained only as long as necessary to complete winner verification and prize fulfillment, and are then securely deleted from our Google Workspace account. This is a shorter retention period than, and is separate from, the general retention period described in Section 7 for other Giveaway and prize records (such as winner names, prize tier, and confirmation of prize delivery), which do not include copies of identification documents once verification is complete.
4. HOW WE USE YOUR INFORMATION
We use the personal information collected through the Landing Page and Form for the following purposes: • Waitlist Administration: to add you to the LEVELS dating app pre-launch waitlist and maintain records of sign-ups. • Founding Member Prize Administration: to identify, verify, and notify recipients of Founding Member prizes, and to administer Founding Member benefits upon App launch. • Giveaway Administration: to verify eligibility, process and verify referral entries, conduct the random draw, notify potential winners, and fulfill prizes. • Waitlist & Giveaway Communications: to send you operational communications necessary to administer your waitlist sign-up and Giveaway entry, including sign-up confirmation, App launch updates, founding member offers, and (if applicable) Giveaway results and winner notifications. Providing a valid email address and receiving these communications is necessary to join the waitlist and participate in the Giveaway. • Marketing Communications: to send you additional promotional updates about the App and related offers via email and, where separately consented to, SMS. You may opt out of promotional updates at any time without affecting your waitlist membership or Giveaway eligibility. • Analytics and Improvement: to understand how users find and interact with the Landing Page and to improve our marketing and product development efforts. • Legal Compliance: to comply with applicable laws, regulations, and legal obligations, and to enforce our Terms and Conditions. • Safety and Fraud Prevention: to detect, investigate, and prevent fraudulent sign-ups, automated entries, and misuse of the Form or Giveaway.
5. LEGAL BASIS FOR PROCESSING (EEA / UK / GDPR)
If you are located in the European Economic Area, United Kingdom, or a jurisdiction with equivalent data protection laws, we process your personal information on the following legal bases: (a) Consent - where you have given us your explicit consent, such as by completing the Form and agreeing to receive marketing communications; (b) Legitimate Interests - where processing is necessary for our legitimate business interests, including administering the waitlist and Giveaway, improving our marketing efforts, and preventing fraud, provided those interests are not overridden by your rights; and (c) Legal Obligation - where processing is necessary to comply with a legal obligation to which we are subject. You may withdraw your consent at any time without affecting the lawfulness of processing carried out before withdrawal. To withdraw consent, contact us at privacy@levelsdating.com.
6. HOW WE SHARE YOUR INFORMATION
We do not sell, rent, or trade your personal information to any third party for their own marketing or commercial purposes. We may share your information only in the following limited circumstances:
6.1 Service Providers
We work with third-party service providers who assist us in operating the Landing Page, hosting and processing the Form, and storing collected data. These providers process your information only on our behalf, for the specific purposes described in this Privacy Policy, and are contractually required to protect your information. Relevant providers include the platform used to host the Landing Page and the platform used to host and process the sign-up Form and to store sign-up data. We do not authorize these providers to use your personal information for their own purposes. Specifically, the sign-up Form and Giveaway prize-claim materials are collected and stored using Google Forms and Google Drive under our Google Workspace account. We have accepted Google’s Cloud Data Processing Addendum (CDPA) for our Google Workspace account, under which Google acts as a data processor with respect to the personal information submitted through the Form and processes it only on our behalf and instructions, subject to contractual confidentiality and security obligations.
6.2 Legal Requirements
We may disclose your information if required by applicable law, regulation, legal process, or governmental request, or if we reasonably believe in good faith that disclosure is necessary to protect the rights, property, or safety of the Company, our users, or the public.
6.3 Business Transfers
In the event of a merger, acquisition, reorganization, or sale of assets involving Sollia, your personal information may be transferred to the acquiring or successor entity. We will notify you of any such transfer and any choices you may have with respect to your information.
6.4 With Your Consent
We may share your information with third parties in any other circumstances where you have provided us with your explicit prior written consent.
6.5 Aggregated or De-Identified Data
We may share aggregated or de-identified information that cannot reasonably be used to identify any individual, without restriction and without notice to you.
6.6 Prize Providers
If you are selected as a Giveaway winner, we may share limited contact information (such as your first name and the contact information needed to arrange prize delivery) with the third-party business or promotional partner supplying your prize or prize component (“Prize Provider”), solely for the purpose of fulfilling that prize. Prize Providers are independent third parties, are not administrators or operators of the Giveaway, and are not authorized to use your information for their own marketing purposes without your separate, explicit consent. For more information about Prize Providers, see the Official Giveaway Rules & Promotion Terms.
7. DATA RETENTION
• Waitlist data: retained until the App has officially launched and the waitlist is closed, or until you request deletion, whichever comes first. • Giveaway and prize data (including Founding Member winner records): retained for a minimum of three (3) years following the close of the Giveaway and the awarding of all prizes, for record-keeping, legal compliance, and tax reporting purposes. This retention period applies to Giveaway and prize administration records generally (such as winner identity, prize tier, and confirmation of delivery). It does not apply to copies of government-issued identification documents collected for winner verification, which are retained only as described in Section 3.5 above and deleted once verification and fulfillment are complete. • Marketing communications data: retained until you opt out or request deletion. • Fraud prevention and legal compliance records: retained for up to seven (7) years as required by applicable law or legitimate business necessity. After the applicable retention period, we will securely delete or anonymize your personal information. To request early deletion of your information, contact us at privacy@levelsdating.com, subject to any legal obligations requiring us to retain certain data.
8. YOUR PRIVACY RIGHTS
8.1 Rights for All Users
• Right to Access: request a copy of the personal information we hold about you. • Right to Correction: request that we correct any inaccurate or incomplete personal information. • Right to Deletion: request that we delete your personal information, subject to any legal obligations requiring its retention. • Right to Opt Out of Promotional Marketing Communications: opt out of promotional or marketing-style updates at any time by contacting us at privacy@levelsdating.com or following the unsubscribe link in any email we send. This right does not extend to administrative or transactional communications necessary to operate the waitlist or administer the Giveaway (such as sign-up confirmations or winner notifications), which are sent as a condition of participation. This limitation applies only to muting that specific communication channel while remaining enrolled; it does not limit your separate Right to Deletion above. If you no longer wish to receive any communications from us at all, you may withdraw from the waitlist and/or the Giveaway at any time by requesting deletion of your information as described above, which will end your participation and stop all communications, subject to the retention exceptions described in Section 7.
8.2 Additional Rights for EEA / UK Users (GDPR / UK GDPR)
• Right to Restriction of Processing: request that we restrict processing of your personal information in certain circumstances. • Right to Data Portability: request that we provide your personal information in a structured, commonly used, machine-readable format. • Right to Object: object to our processing of your personal information on the basis of legitimate interests. • Right to Lodge a Complaint: you have the right to lodge a complaint with your local data protection supervisory authority.
8.3 Additional Rights for California Residents (CCPA / CPRA)
California residents have the right to: know what personal information we collect, use, disclose, and share; delete personal information subject to certain exceptions; correct inaccurate personal information; opt out of the sale or sharing of personal information for cross-context behavioral advertising (we do not sell or share personal information for such purposes); limit use of sensitive personal information; and be free from discrimination for exercising these rights.
8.4 California Shine the Light (Cal. Civ. Code § 1798.83)
We do not disclose personal information to third parties for their own direct marketing purposes.
8.5 Additional Rights for Florida Residents (Florida Digital Bill of Rights)
Florida residents have the right to access, correct, delete, and obtain a copy of their personal data, and to opt out of the processing of personal data for purposes of targeted advertising or profiling.
To exercise any of the rights described in this Section 8, contact us at privacy@levelsdating.com. We will respond within the timeframe required by applicable law and may need to verify your identity before processing your request.
9. COOKIES AND TRACKING TECHNOLOGIES
The Landing Page may use cookies and similar tracking technologies. Essential cookies are necessary for the Landing Page to function. Analytics cookies help us understand how visitors interact with the Landing Page. Marketing cookies may be used to measure the effectiveness of our promotional campaigns. Most web browsers allow you to control or disable cookies through their settings; however, disabling cookies may affect the functionality of the Landing Page. The Landing Page does not currently respond to browser Do Not Track (“DNT”) signals. We will update this Privacy Policy if we implement a DNT response mechanism.
10. SMS COMMUNICATIONS
By providing your phone number through the Form and separately checking the optional SMS consent checkbox, you expressly consent to receive text messages from Sollia regarding the LEVELS dating app waitlist, App launch updates, founding member offers, and related promotions. YOUR CONSENT TO RECEIVE SMS MESSAGES IS COMPLETELY OPTIONAL AND IS NOT A CONDITION OF ENTRY INTO THE GIVEAWAY, RECEIPT OF ANY PRIZE, MEMBERSHIP ON THE WAITLIST, OR ANY PURCHASE. • Message frequency will vary. Message and data rates may apply depending on your carrier and plan. • To opt out at any time, reply STOP to any message we send, or contact us at legal@solliahq.com. • To request assistance, reply HELP to any message, or contact us at legal@solliahq.com. We do not share your phone number with any third party for their own marketing purposes.
11. INTERNATIONAL DATA TRANSFERS
Sollia is based in the United States. If you access the Landing Page or submit information from outside the United States, your personal information will be transferred to and processed in the United States, where data protection laws may differ from those in your country of residence. For users in the EEA or United Kingdom, we ensure that transfers of personal information outside the EEA/UK are subject to appropriate safeguards, including Standard Contractual Clauses where required. By submitting your information through the Form, you consent to the transfer and processing of your personal information in the United States as described in this Privacy Policy.
12. DATA SECURITY
We implement reasonable and appropriate technical and organizational measures to protect your personal information against unauthorized access, loss, misuse, alteration, or destruction. These measures include access controls, secure data storage, and contractual requirements imposed on our third-party service providers. No method of transmission over the internet or electronic storage is completely secure. While we strive to protect your personal information, we cannot guarantee its absolute security. In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will notify affected individuals and relevant supervisory authorities as required by applicable law. Where required under the GDPR, we will endeavor to provide notification within seventy-two (72) hours of becoming aware of the breach.
13. CHILDREN’S PRIVACY
The Landing Page, Form, and the LEVELS dating app are intended solely for individuals who are 18 years of age or older. We do not knowingly collect, use, or disclose personal information from individuals under the age of 18. If we become aware that personal information has been collected from a person under 18, we will take prompt steps to delete it. If you are a parent or guardian and believe your child under 18 has submitted information through the Form, contact us immediately at privacy@levelsdating.com.
14. INTELLECTUAL PROPERTY NOTICE
The LEVELS brand, the “LEVELS” marketing name as used in connection with the Company’s services, as well as associated logos, algorithm names, and all related branding, design elements, and certain proprietary concepts and frameworks associated with the Company’s services are the property of Sollia and are protected by applicable copyright, trademark, trade secret, and other intellectual property laws. No provision of this Privacy Policy constitutes a license, assignment, or transfer of any intellectual property right of Sollia.
15. THIRD-PARTY LINKS AND PLATFORMS
The Landing Page may contain links to or integrations with third-party websites and platforms, including Instagram and the sign-up form platform. These platforms operate independently and are governed by their own privacy policies, which we encourage you to review. We are not responsible for the privacy practices or data handling of any third-party platform.
16. CHANGES TO THIS PRIVACY POLICY
We reserve the right to update or modify this Privacy Policy at any time. Material changes will be reflected in an updated Effective Date posted at the top of this document. We encourage you to review this Privacy Policy periodically. Where required by applicable law, we will seek your consent before implementing material changes.
17. CONTACT US
For questions about this Privacy Policy or your personal information:
Privacy and data requests: privacy@levelsdating.com
Legal correspondence: legal@solliahq.com
Company social media: @solliahq
App social media: @thelevelsapp
Mailing address: Available upon verified written request
EEA/UK users may also contact their local data protection supervisory authority.
This Privacy Policy was prepared for Sollia and the LEVELS dating app pre-launch. This document does not constitute legal advice.