This Privacy Policy (“Privacy Policy”) provides information about the privacy practices ofCadooga LLC (“Cadooga,” “we,” “us,” or “our”), including how we collect, use, disclose, andotherwise process personal information obtained when you visit our website,cadooga.com (the “Site”) or use the Cadooga mobile application (the “App”, and with theSite, collectively, the “Services”).
Personal information means information that identifies or could reasonably be linked to an individual. The personal information we collect about you may vary depending on the nature of your interactions with us.
A. Personal Information You Provide
When you create an account, you give us personal information to set up your account such as your name, email address, date of birth, and other login details. You may also choose to become Cadooga verified by submitting a government-issued identification and a photo of yourself. In some instances, we may require you to submit a government-issued identification if we are unable to verify your identity.
In order to create an account, use certain features within the Services such as our Intend2Copyright feature, or delete/deactivate your account, we may require a face scan, which may be considered biometric data in some jurisdictions. Prior to collecting such data, we will obtain your consent for such collection. Cadooga does not collect face scans or other biometric data from individuals in the State of Illinois.
When you set up your profile, you give us certain details about yourself such as your nickname, gender, age, relationship status, location, and other details about yourself such as your interests. You can choose to share as much or as little on your profile as you want. You may choose to provide us with photos and videos to add to your profile. Additionally, you may choose to submit content (for example, messages, comments, and posts) while using the Services. The content you submit may be visible to any user of the Services.
You can share data with us through your account on other platforms (e.g., TikTok, Instagram, Snap, LinkedIn) such as if you decide to create and log into your account via these platforms or if you decide to upload data, such as photos, onto our Services from these platforms.
You may also engage in transactions while using the Services. We keep a record of the details of your transaction. When you engage in a transaction directly with us, we will process your financial information.BakerHostetler Draft – 3.18.2026Attorney-Client PrivilegedB.
B. Personal Information Collected from the App
When you download, access, or use our App, we may (depending on your device or permission settings) have access to certain information from your device, such as:
* Geolocation Information. We may use location-aware technologies to locate you, sometimes precisely (as determined by your IP address, GPS, Bluetooth, or Wi-Fi signals). We use your location information to display your location in your profile or personalize the App to provide you with more location-relevant content.
* Storage. The App may need to access the stored files on your device in order to save photos and screenshots to your device.
* Camera and photos. The App may utilize your device’s camera or access your device’s photos to allow you to take pictures and face scans.
* Device Information and Device ID. We may get information about the device you use, including the model of your device and its operating system, your IP address, device ID or other unique identifier. We use this information to understand how our App performs when you use it.
* Usage Data. When you use the App, we may get certain information such as the time and length of your App use, and other usage data.
We may use Software Development Kits (“SDKs”) to collect information when you use the App. SDKs are blocks of code that may be installed in a mobile application to understand how visitors interact with the mobile application and collect certain information about the device and network used to access the mobile application, such as the advertising identifier associated with your device.
We may disclose your information with certain non-affiliated third parties to facilitate your access and use of our App, our Services, and to provide us with certain business functions, including but not limited to sharing your information with app developers, advertising networks, data analytics providers, operating systems and platforms, social media networks, and service providers who provide us a service (e.g., customer service, auditing, hosting certain features including blockchains, debugging to identify and repair errors that impair existing intended functionality on our App, and/or protecting against malicious, deceptive, fraudulent, or illegal activity). To the extent we grant third parties access to personal information collected via the App, they are expected to follow privacy practices no less protective than our practices to the extent allowed by applicable law.
We retain personal information we collect while you use the App for no longer than is necessary to achieve the purposes for which the personal information was collected, or as may otherwise be permitted or required under applicable law.
Cadooga allows you to connect with other members, which may mean that some of your personal information may be visible to other members of the Services.
We may disclose personal information we have collected with our corporate affiliates, including Vanvir Corporation, that may use your personal information as described in thisPrivacy Policy. We may also disclose your personal information to the following recipients:strategic partners, and our vendors, including those that help us operate our business and perform services on our behalf, such as App support, sending emails, processing payments, customer service, and detecting and deterring fraud or other illegal activities.
We may disclose personal information for the following purposes: in order to facilitate the services you requested; as part of a business transaction, including in the event we sell or transfer all or a portion of our business assets (e.g., further to a merger, reorganization, liquidation, or any other business transaction), including negotiations of such transactions; as required or permitted by law, including where we determine that disclosure of specific information is necessary to comply with the request of a law enforcement or regulatory agency or other legal process; where we perceive a threat or risk to individuals or property as a result of activity on our Site; and with your consent or at your direction.
Please note that we do not disclose face scans or biometric data outside of the Vanvir System (defined below) unless such disclosure is strictly necessary to provide the requested services. For example, we disclose your biometric data (and the related data generated from your biometric data) to our facial recognition service provider and our cloud platform database in order to provide the requested services.
We do not sell personal information to third parties for monetary consideration.
We may use personal information for various purposes, including:
* To enable you to use our Services, including to create your account and maintain a profile on our Services and to allow you to connect with other Cadooga members;
* To process your financial information to maintain your Cadooga membership;
* To communicate with you, including communicating with you about the Services and responding to your queries and questions;
* To verify your identity while you are using our Services. For example, when you use our face scan feature, we will use your biometric data to confirm that you are who you say you are, to let other users know that you have been Cadooga verified, to register your creative works, and to improve our identity verification services;
* To operate advertising and marketing campaigns, including running advertisements for products we believe may interest you. Please note, we do not use sensitive data, including biometric data, for advertising or marketing purposes or to profile you as a user;
* To improve our Services and create new features on the Services;
* For security and integrity, including protecting against security threats, preventing, identifying, investigating, and responding to potential or actual fraud, illegal or malicious activities, and other risks, enforcing our policies, agreements, and terms, and otherwise protecting our rights. We may also use your face scan to prevent any fraud, for example, we may use your face scan to prevent an individual from creating multiple accounts;
* For quality, safety, and internal research, including assessing the Services performance, tracking and responding to technical issues, and developing new or enhanced service offerings; and For any other purpose, with your consent or as communicated to you at the time of collection.
When you interact with Cadooga, your personal information may be used across other products within the system of products offered by us and our affiliates (the “Vanvir System”). Your personal information may be used within the Vanvir System to allow you to seamlessly use other products within the Vanvir System; to develop new products; to operate, maintain, and improve our products and services; to verify and authenticate your identity; to provide customer support; and to enhance the features and functionality of the products and services in the Vanvir System. When we use your personal information in the Vanvir System, we will use it in accordance with the practices described in this Privacy Policy.
Certain features within the Services may link to products and/or features operated by third parties. For example, when you click on the Criminal Background Search Feature within the App, we provide a link to the selected state sex offender registry or arrest search. Any searches that you conduct are on such third party’s website and not within the Cadooga App. This Privacy Policy does not apply to the practices of third parties that we do not own or control. You should refer to that third party’s privacy policy for information on how your personal information is collected, used, and protected.
The Services may permit you to connect your Cadooga account with unaffiliated social media platforms (“Social Features”). Upon connecting your Cadooga account with these Social Features, we may access certain information such as your social media handle, list of followers, list of photos, and other account details. You may also choose to create an account with Cadooga using your username and password from other social media platforms (for example, using your Google account). Use of such a feature may allow us to collect information about you.
We will retain your personal information for no longer than is necessary to provide the Services or to achieve the purposes for which the information was collected, or as may be permitted under applicable law. To determine the appropriate retention period, we will consider the amount, nature, and sensitivity of the data; the potential risk of harm from unauthorized use or disclosure of the data; the purposes for which we process the data and whether we can achieve those purposes through other means; and the applicable legal requirements. Unless otherwise required by applicable law, at the end of the retention period we will remove personal information from our systems and records or take appropriate steps to properly anonymize it.
If we have processed your facial scan, we will retain such data for 60 months (regardless of whether your account is active or if it has been deleted), unless a longer retention is required to ensure the safety of others or comply with an applicable legal obligation.
We maintain appropriate administrative, technical, and physical safeguards designed to help protect personal information we process while providing the Services. Although we use reasonable efforts to safeguard information, transmission via the Internet is not completely secure and we cannot guarantee the security of your information collected via the Services.
Opting Out of Promotional Emails. If you no longer wish to receive marketing emails from us, please click on the unsubscribe link in the relevant email. If you opt out of marketing emails, we may still send you administrative emails, such as those related to your account and your requested services.
Deleting Your Account. If you wish to delete your account and certain associated account data with your App account, please navigate to Settings option within the App, select “Delete,” and follow the instructions to confirm you would like to delete your Account. Please note that we retain some of your personal information after you delete yourAccount, as described herein, including to keep Cadooga safe for all users by preventing fraud within the App.
Device Settings and Permissions. You can use your mobile device settings to limit certain permissions. Please note that some App features may not function properly if certain permissions are disabled or settings are changed. With respect to the App, you can stop collection of data generated by use of the App by uninstalling the App. You may be able to exercise specific privacy choices, such as enabling or disabling certain features (e.g., location-based services, push notifications), by adjusting the permissions in your mobile device and/or the App’s settings. Beware that if GPS precise location services are disabled, other means of establishing or estimating location (e.g., connecting to or proximity to Wi-Fi) may persist. You may be able to enable or disable location tracing on the App by adjusting the permissions through your mobile device settings. Note that uninstalling the App or changing the App permission will not delete your user account or any information we previously collected via the App.
Our Services are not intended for use by individuals under the age of 18, and we do not knowingly collect personal information from children under the age of 18. If we become aware that we have obtained personal information from a child under age 18 we will delete such information in accordance with applicable law.
This Privacy Policy is subject to change at our discretion. We will indicate changes to the Privacy Policy by updating the “Effective Date” at the beginning of the Privacy Policy. Your continued use of the Services after any update to this Privacy Policy will constitute your acceptance of the changes.
You may contact us regarding this Privacy Policy by emailing support@cadooga.com.
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