Privacy Policy

Glow Tech, Inc. is the company that operates Talk to Glow (also branded as "Glow") and Eka. In this Privacy Policy, "Glow Tech," "we," "us," and "our" mean Glow Tech, Inc.; Talk to Glow and Eka are product names. This Privacy Policy explains how we collect, use, disclose, and otherwise process information when you use Talk to Glow, Eka, or any other Glow Tech product or service that links to or references this Policy (collectively, the "Services"). It applies to Eka whether or not you also use Talk to Glow.

Talk to Glow helps people form one-to-one and other selective connections, including friendships, activity partners, professional networking, and (for users 18 and older) romantic introductions. Eka may match adults into groups of up to six participants total and help coordinate real-world gatherings and activities, such as meeting at a restaurant or going on a hike. The Services may enable one-to-one or group communications between users who are introduced or placed together, including through Apple Messages/iMessage.

If you have questions, see How to Contact Us below.

1. Scope

This Privacy Policy applies to the Services that link to or reference this Privacy Policy. It does not apply to:

• Third-party websites, apps, or services that we do not control (even if linked from our Services).

• Third-party AI Agents (such as Claude, ChatGPT, or other personal AI assistants) that you authorize to act on your behalf — those agents are governed by the privacy policies of their respective providers.

• Information practices of app stores, mobile operating systems, device manufacturers, messaging platforms (including Apple), telecommunications carriers, or other platform providers.

• Any third-party services you choose to connect to the Services, which are governed by those third parties' privacy policies.

Additional privacy disclosures may be provided at or before the point of collection for specific features or integrations. If there is a conflict between those disclosures and this Privacy Policy, the feature-specific disclosure will control.

2. Key Definitions

"Personal Data" (or "personal information") means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked (directly or indirectly) with an individual.

"Sensitive Personal Data" (or "sensitive personal information") may include information such as precise geolocation, certain government identifiers, and information about a person's sex life, sexual orientation, religious beliefs, or other categories recognized under applicable law.

"Embeddings" are numerical or vector representations derived from text, voice, and/or other inputs that can help the system recognize patterns and preferences. Embeddings are typically not human-readable in the way ordinary text transcripts are.

"Inferences" are conclusions we may generate from your information (for example, compatibility signals, preference categories, or interest clusters) to provide matching and personalization.

"AI Agent" means a third-party AI assistant (such as Claude, ChatGPT, or other personal AI agents) that you authorize to interact with the Services on your behalf through one of our agent interfaces (REST API, MCP, A2A, or similar). An AI Agent acts as your delegate — it can take actions you could take yourself, subject to the limits described in Section 5A.

"Teen User" means a user between the ages of 13 and 17 (inclusive). Teen users are placed in a separate matching community and have additional safeguards described in Section 13. Eka is not available to Teen Users.

"Eka" means Glow Tech's adult-only group matching and real-world experience coordination Service. An "Eka Experience" is a gathering or activity that Eka suggests or helps coordinate.

3. How the Services Work

The Services are consumer-facing matching, introduction, messaging, and coordination services. To make introductions and coordinate Eka Experiences, we may process information you provide (such as profile details, availability, and activity preferences) and information learned during your interactions with the Services (such as preferences you express). We may then use that information to:

• Suggest one-to-one introductions or place adults into small Eka groups,

• Recommend and help coordinate a date, time, venue, meeting point, route, reservation, or other experience logistics, and

• Enable communication between users who are introduced or placed in a group.

We design the Services to be private-by-design, including avoiding "public profiles" by default and focusing on selective sharing between people who are introduced or who accept placement in the same group, subject to your settings and choices.

4. Information We Collect

We collect information in three main ways: (A) information you provide, (B) information we generate or infer, and (C) information collected automatically.

A. Information you provide directly

Depending on how you use the Services and what you choose to share, we may collect:

Account & Profile Information

• Name (or chosen name), username/handle

• Email address and/or phone number. Depending on the feature, we may send an email or messaging verification code or link to confirm that you control the contact information provided. For Eka, we may use your phone number or another identifier associated with your Apple Messages/iMessage account to communicate with you.

• Year of birth (and full date of birth only when needed to confirm whether you are above the age of 13 or, for Eka and other adult-only features, above the age of 18)

• Gender identity, pronouns, and related identity fields (if you choose to provide them)

• Location (e.g., city/region) and, if enabled, more precise location data or a meeting point you choose

• Photos and other profile media (if you upload them)

• Preferences and dealbreakers you provide for matching (e.g., relationship goals, interests, lifestyle preferences). Note: dating-context preferences (such as physical attributes, relationship history, and similar fields) are not collected from teen users.

• For Eka, your availability, scheduling preferences, activity interests, preferred travel distance, transportation preferences, broad food preferences, comfort or skill level for an activity, and other non-health experience preferences

Food and Activity Preferences

Eka may ask you to select broad, non-medical food or activity preferences to help form a group or suggest an experience. For example, we may ask whether you prefer vegetarian or vegan options or an easy rather than moderate hike. We use those selections as general preferences and do not use them to identify or infer your health status. Eka does not ask you to provide allergies, intolerances, diagnoses, medications, disabilities, medical dietary requirements, or other health information, and you should not include that information in your response. Contact the venue or activity provider directly about those matters. Because Eka may use a free-form messaging channel, we may incidentally receive health information that a user sends without being asked. We do not intentionally add that information to a matching profile or use or share it for venue selection or accommodations, and we may delete, redact, or restrict it where reasonably feasible, except as needed for safety, legal compliance, or dispute resolution.

Service Interaction Content (Text and/or Voice)

• Messages you send to Talk to Glow or Eka (including onboarding and ongoing conversations), whether through our own interfaces or a supported channel such as Apple Messages/iMessage

• Voice inputs (audio) if you use voice features. Voice recordings may be considered biometric data under certain U.S. state laws (for example, the Illinois Biometric Information Privacy Act and similar Texas and Washington laws). We use voice recordings only to provide voice-based interaction features. We do not generate or retain voiceprints, do not use voice for biometric identification of individuals, and do not sell voice data. Where required by law, we obtain consent before processing biometric information.

• Any content you provide through prompts, forms, or feedback flows

• Content sent to the Services by an AI Agent acting on your behalf

• Attachments, reactions, and other content you send in a conversation that includes Talk to Glow or Eka, to the extent the messaging channel makes that content available to us

User-to-User and Group Messaging Content

• Messages you send to other users through the Services after you are introduced or placed in a group (including message content, attachments, reactions, timestamps, participant identifiers, and delivery metadata to the extent available to us)

• Depending on how an Eka group conversation is configured, we may receive and process messages sent in a conversation that includes Eka or an account controlled by Glow Tech. We generally do not collect messages exchanged directly between participants outside a conversation that includes us, unless a participant reports or shares those messages with us.

Eka Group and Experience Information

• Invitations, acceptances, declines, group membership, removals, and waitlist status

• Availability, proposed and confirmed dates and times, venues, meeting points, routes, reservation details, group size, cancellations, and other logistics

• Attendance, check-in, no-show, reliability, and post-experience feedback information, where offered or provided

• Information you provide to coordinate with a venue or activity provider, such as a reservation name, broad food preference, or other non-health logistical request

Feedback and Safety-Related Information

• Feedback you provide about introductions, matches, dates, groups, participants, venues, or Eka Experiences

• Reports you submit (e.g., spam, harassment, safety issues)

• Information you provide during customer support interactions

Payments, Reservations, and Subscriptions
If you purchase a subscription or paid feature, or if a future Eka flow facilitates a reservation, ticket, deposit, or other purchase, we may collect limited transaction and reservation details (e.g., purchase or reservation type, date, amount, status, cancellation, and refund status). Payment card information is typically handled by a PCI-compliant payment processor or the relevant third party rather than stored directly by us, depending on the checkout method and platform.

Contacts / Invitations (Optional)
If you choose to invite friends or sync contacts (if offered), we may process contact information you provide for that purpose. We will describe the details in the relevant feature flow at the time of use.

AI Agent Information
When you authorize an AI Agent to act on your behalf, we collect:

• The agent's name, description, and stated capabilities

• The platform type (e.g., MCP, A2A, REST API)

• A hashed copy of the API key issued to the agent (we cannot retrieve the original after issuance)

• Timestamps of registration, authorization, and most recent activity

• A record of the email-based authorization flow, including the 4-digit verification code we sent you and whether you approved or declined the request

• The OAuth client identifier, where the agent authenticates via OAuth instead of an API key

B. Information we generate, infer, or derive

As you use the Services, we may create or derive additional information to operate and improve the Services:

Embeddings and AI-Derived Representations

• Embeddings derived from your interactions and inputs (including text and/or voice, depending on your settings)

• High-level categories, labels, or bins (e.g., "prefers quiet first dates")

Inferences, Matching, and Experience Signals

• Compatibility signals, match rankings, group composition recommendations, and introductions

• Activity, venue, schedule, route, and logistics recommendations

• Preference representations based on your feedback and interactions

• Reliability, attendance, safety, and personalization signals used to tailor the experience and protect users

Interaction History and Feature Usage

• Which introductions you viewed, accepted, or passed on

• Whether you opened an introduction or group thread

• Which Eka invitations you accepted, declined, canceled, or attended and whether you left or were removed from a group

• Basic engagement metrics (e.g., session duration, feature usage frequency)

• Activity logs for each authorized AI Agent (which actions the agent took on your behalf, when)

C. Information collected automatically

When you use the Services, we may automatically collect:

Device and Usage Information

• Device type, operating system, app version

• Browser type and settings (for web)

• Device identifiers and network information

• Log data (e.g., IP address, timestamps, error logs, crash reports)

• For agent-mediated sessions: the user-agent string and platform identifier of the AI Agent

• For messaging-mediated sessions: available channel, sender, recipient or participant, timestamp, delivery, device, network, carrier, and interaction metadata

Approximate Location

• Approximate location derived from your IP address

• More precise location only if you enable relevant device permissions or choose to provide it. Unless a feature clearly says otherwise and you consent, Eka does not continuously track your precise location.

Cookies and Similar Technologies (Web)

• Cookies, pixels, SDKs, and similar technologies for authentication, preferences, analytics, and security. See Cookies and Similar Technologies below.

5. Your Privacy Controls and "Memory" Settings

The Services are designed to give you meaningful controls over what we store and how the Services learn about you.

Depending on your settings and the features you use, the Services may support options such as:

• Embeddings-only learning mode: storing embeddings and structured signals without storing human-readable conversation histories or transcripts.

• Expanded memory modes: storing additional user-provided profile information and/or certain conversation-derived notes to improve matching and user experience.

• Feature-specific consents: where you can enable or disable categories of processing (for example, voice features, certain integrations, or personalization features).

• Per-photo privacy levels: when you (or an AI Agent acting on your behalf) upload a photo, you can set its privacy level — Glow can share (included with introductions), Ask before sharing (you approve each use), Only I can share (you control sharing), or Hidden (not visible to anyone). Photos uploaded by teen users default to Hidden and cannot be raised to a more visible level.

Important: Even if you use a more private mode, we may still need to store some information necessary to operate the Services, such as account identifiers, eligibility confirmations (e.g., age gating), essential security logs, group membership and logistics, and your settings choices.

Eka group sharing. When you accept an Eka group, ordinary profile and logistics information needed to introduce and coordinate the group may be shared with all confirmed participants as described in Section 7. This may include a broad food preference or other non-health logistical information you chose to disclose. Once information or a message has been delivered to another participant, we cannot control copies, screenshots, forwarding, contact records, or storage on that person's device or messaging account. Leaving a group or deleting your account does not erase copies already received by others.

Location and logistics controls. You may decline to provide precise location, broad food preferences, transportation preferences, or other optional logistics information, although doing so may limit our ability to recommend or coordinate an experience. Provide only the minimum information you are comfortable sharing, and use a general meeting area rather than a home address whenever possible.

Messaging choices. You can leave an Eka group or ask us to stop service-related automated messages. Depending on the channel, you may also use device or platform controls to mute, block, or leave a conversation. These actions do not remove previously delivered messages.

Consent records. We retain records of consents you grant or withdraw within the Services (for example, consent to AI data sharing, precise location, specific data-processing categories, or acceptance of Eka terms), including the timestamp and scope of the consent. We use these records to honor your choices and to demonstrate compliance with applicable law.

We will describe the available settings in-product and may update them over time.

5A. AI Agent Access

You may authorize one or more AI Agents (such as Claude, ChatGPT, OpenClaw, or other personal AI assistants) to interact with the Services on your behalf. Agent access works as follows.

What we collect about your agent. When an AI Agent registers to act on your behalf, we collect the agent's name, description, capabilities, and platform type. We store this information to manage authorized access and for security purposes. See Section 4 under AI Agent Information.

How agents authenticate. Your AI Agent authenticates using either an API key (a unique credential prefixed with `glw_`) or an OAuth access token. API keys are cryptographically hashed before storage — we cannot retrieve your original key after registration. You are responsible for keeping your API key secure. Anyone with your API key can act as you through the Services.

Authorization and verification. When an AI Agent first requests access to act on your behalf, we send you an email containing an authorization link and a 4-digit verification code. Your agent will tell you this code. You should verify that the code in the email matches the code your agent reported before clicking Approve, to confirm the request came from your own agent and not from a third party. Treat authorization codes the same way you would treat a password — never share them with anyone other than the agent that requested them.

Bot-initiated account creation. An AI Agent may create a Talk to Glow account on your behalf using your email address. When this happens, we collect the applicable account and AI Agent information described in Section 4, including your year of birth (and, if needed, your full date of birth) for age verification. The account is not active until you approve the authorization email. You will receive the authorization email at the address the agent provided.

What agents can and cannot access. Authorized AI Agents can set up your account, express your preferences, check for introductions, send and receive messages, upload photos, and manage your settings — the same actions you could take directly. Agents cannot access other users' data, bypass the Services' privacy controls, or take any action you have not authorized.

Agents acting on behalf of teen users. An AI Agent may register or act on behalf of a user aged 13–17. When the agent's registered user is a teen, the same restrictions described in Section 13 apply: the user is placed in the teen-segregated community, romantic features are not available, dating-context profile fields are not collected, photos default to Hidden, and the agent cannot bypass any of these restrictions on the user's behalf. Parents and legal guardians have the rights described in Section 13, including the right to revoke an AI Agent's access to a child's account.

Conversation processing for agent interactions. When your AI Agent communicates with the Services on your behalf, we process the content to update your preferences and embeddings, in the same way and subject to the same privacy controls described in Sections 5 and 8. We may also process content sent by AI Agents through automated safety, moderation, and abuse-detection systems. Full No Transcript Retention (NTR) mode — where raw conversation transcripts are automatically discarded after processing — is a planned privacy feature. Until NTR is fully enforced, conversation content (including content sent by your AI Agent) may be retained as described in Section 9 (Retention).

Activity logging. By authorizing an AI Agent, you consent to Glow Tech logging the agent's activity for security, abuse detection, and dispute resolution purposes. These logs may include action types, timestamps, the IP address and platform identifier of the agent, and references to the affected resources.

Revoking agent access. You can revoke any AI Agent's access at any time from your Talk to Glow account settings. Revocation is immediate — the agent's API key or OAuth token will stop working. Glow Tech administrators may also suspend or revoke an AI Agent's access if it is used in a way that violates our Terms of Use, including spam, harassment, mass registration, or attempts to circumvent rate limits.

Rate limits. Automated access through AI Agents is subject to rate limits on API calls, messages, photo uploads, and other actions. Limits exist to protect the Services and other users. Attempts to circumvent rate limits may result in agent suspension.

6. How We Use Your Information

We may use Personal Data for the following purposes:

A. Provide and operate the Services

• Create and manage accounts

• Authenticate users and provide login functionality

• Provide Talk to Glow and Eka interactions via text and/or voice

• Make one-to-one introductions, form Eka groups, and facilitate user-to-user or group messaging

• Recommend and help coordinate Eka Experiences, including scheduling, venue or route selection, reservations, invitations, reminders, and changes

• Maintain preferences, settings, and personalization choices

• Provide customer support and respond to requests

B. Matchmaking and personalization

• Learn your preferences (subject to your settings)

• Generate embeddings and matching signals

• Recommend one-to-one introductions, group composition, activities, venues, routes, schedules, and other experience logistics, and explain matching at a high level

• Use broad food preferences as venue-selection guidelines, not to identify or infer health status

• Improve relevance and quality of matching over time based on feedback

C. Safety, integrity, and trust

• Detect and prevent fraud, abuse, harassment, spam, and other harmful activity

• Enforce our Terms and community guidelines

• Investigate reports and respond to safety incidents

• Maintain audit trails and logs for security and compliance

• Detect misuse of AI Agent access (e.g., mass registration, rate-limit circumvention)

• Apply additional safeguards to interactions involving teen users

• Confirm adult eligibility for Eka and detect or investigate suspected underage access

• Investigate safety incidents connected with an in-person meeting or Eka Experience

• Apply automated content moderation to user-uploaded media (including photos and voice) and messages available to us to detect prohibited content. When child sexual abuse material (CSAM) is detected, we report it to the National Center for Missing & Exploited Children (NCMEC) and law enforcement as required by 18 U.S.C. § 2258A.

D. Improve and develop the Services

• Debug, test, and monitor performance

• Conduct analytics to understand how the Services are used

• Develop new features and refine existing ones

• Conduct research and product development using aggregated and/or de-identified data where feasible

E. Communications and marketing

• Send transactional and service-related messages (e.g., account notices, security alerts, invitations, group updates, reminders, changes, and safety notices) through email, push notifications, Apple Messages/iMessage, SMS, or another supported channel

• Send product updates and service-related communications

• Send marketing messages only where permitted by law and provide opt-out choices. Where an automated text or message is subject to consent requirements, you may revoke consent by replying STOP or by another reasonable method that clearly communicates your request. Marketing consent, if requested, is separate from consent to receive messages needed to provide a service you requested.

We do not use teen users' personal information for behavioral advertising and do not sell or share teen users' personal information with third parties for cross-context behavioral advertising as defined under applicable state laws.

F. Legal and compliance

• Comply with applicable laws, regulations, and lawful requests

• Protect our rights, property, and safety, and that of our users and others

• Resolve disputes and enforce agreements

7. How We Share Your Information

We share Personal Data only as described below, subject to your settings and applicable law.

A. Sharing with other users (introductions, groups + messaging)

Because the Services are designed to introduce users, form groups, and enable communication, some information will be shared with other users depending on the context and your choices.

When you are introduced to another user, we may share:

• Basic profile details you provide (for example: name or first name, general location such as city/region, age range, and other profile fields you choose to provide)

• Compatibility summaries at a high level (designed to avoid exposing raw conversations)

• Any content you choose to send to another user

For a one-to-one introduction, both users must confirm mutual interest before we facilitate direct contact.

When you accept or join an Eka group, we may share with every confirmed participant:

• Basic profile details, an age or adult-eligibility indicator, general location, interests, activity preferences, and a high-level reason for the group match

• Your group membership, availability, RSVP or attendance status, proposed or confirmed date and time, venue, meeting point, route, reservation, and other logistics

• Messages, attachments, reactions, and content you send in the group

• The phone number, email address, name, photo, or other contact identifier that your messaging account or device exposes to the conversation, depending on your settings and how the group is created

• Broad food, activity, transportation, or other non-health coordination preferences when you choose to share them

By accepting an Eka group, you authorize us to share the ordinary profile, group-membership, and logistics information identified in the group acceptance flow with all confirmed participants. You may not be asked to approve each participant individually before the group is finalized. Other participants may save your contact information, retain or screenshot messages, forward content, or communicate with you outside the Services. Glow Tech does not control those actions.

User-to-user and group messages

• When you send a message to another user or group, each recipient may store it on their device or in their account history consistent with the product and messaging platform.

• We may process messages available to us to provide the feature, prevent abuse, and support investigations (e.g., if a message is reported), consistent with this Privacy Policy.

Community segregation for teen users. We use technical controls — including community segregation, application-layer enforcement, and automated invariant testing — designed to prevent teen users from being matched with, communicating with, or appearing as candidates to adult users. Teen users cannot access Eka or be included in Eka groups. While we work to ensure these controls are effective, no system is infallible. Please report any concerns to safety@talktoglow.com.

We do not intend to make your information publicly visible by default. The Services are designed around introductions, accepted group placement, and selective sharing rather than public browsing, subject to how the product is implemented and your choices.

B. Service providers and processors ("vendors" / "subprocessors")

We may share Personal Data with third-party service providers that perform services on our behalf, such as:

• Cloud hosting and infrastructure providers (e.g., Google Cloud Platform)

• AI model and inference providers (text generation, embeddings, or similar)

• Voice processing, transcription, and audio infrastructure providers

• Analytics providers

• Customer support tooling

• Payment processors

• Email, SMS, and messaging delivery or communications providers

• Maps, geocoding, reservation, ticketing, event-logistics, and customer-communications providers

• Security, trust-and-safety, and fraud-prevention vendors

These providers are authorized to use Personal Data only as necessary to provide services to us, and are contractually required to protect it.

Your AI Agent is not a Glow Tech service provider. When you authorize a third-party AI Agent (such as Claude or ChatGPT) to act on your behalf, that agent is acting under your direction, not under contract with Glow Tech. The agent's provider has its own privacy policy that governs how it handles the inputs and outputs you exchange with it. The data processing relationship between you and your AI Agent's provider is separate from the relationship described in this Privacy Policy.

C. Messaging platforms, venues, and experience providers

When Eka uses Apple Messages/iMessage or another communications channel, your use of that channel is subject to the platform provider's own terms and privacy practices. Apple, telecommunications carriers, device or operating-system providers, and other platform participants may process contact identifiers, metadata, and, depending on the message type and settings, message content. They may act independently of Glow Tech rather than as Glow Tech service providers.

If Eka makes or coordinates a reservation, we may provide a venue or activity provider with limited information such as a reservation name, group size, date and time, contact information where needed, and a broad food preference, preferably in aggregate where practical. Eka is not designed to manage allergies, intolerances, medical needs, disabilities, or individual accommodations; contact the venue or activity provider directly about those matters. A venue or provider may collect additional information directly from you under its own privacy policy.

D. Business transfers

If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of all or a portion of our business or assets, Personal Data may be transferred as part of that transaction, subject to customary confidentiality protections.

E. Legal, safety, and compliance disclosures

We may disclose Personal Data if we believe disclosure is necessary to:

• Comply with law, regulation, or legal process

• Respond to lawful requests by public authorities

• Protect the rights, property, and safety of Glow Tech, our users, or others

• Detect, prevent, or address fraud, security, or technical issues

F. Aggregated / de-identified data

We may share aggregated, anonymized, or de-identified information that cannot reasonably be used to identify you, for research, analytics, and product improvement.

G. With your direction or consent

We may share information when you direct us to do so (for example, by connecting third-party integrations, authorizing an AI Agent, or choosing to share certain profile fields) or when you otherwise consent.

8. AI Processing, Training, and Human Review

The Services use AI to generate responses, learn preferences, create one-to-one and group introductions, and recommend or coordinate Eka Experiences. This can include processing your text and/or voice inputs, availability, group and logistics information, generating embeddings, and producing inferences. The same processing applies whether you interact with the Services directly, through a supported messaging channel, or through an authorized AI Agent.

A. Model providers and processing

When you interact with the Services, your inputs may be transmitted to third-party AI and voice processing providers to generate responses and operate the Services. We share specific personal data (including your chat transcripts and preferences) with our third-party AI providers, Google LLC and OpenAI LLC, for processing via their APIs. These providers act as service providers/processors under contract.

We confirm that these AI providers are contractually obligated to provide the same or equal protection of user data as stated in this Privacy Policy and as required by the Apple App Store Review Guidelines. Data transmitted to these AI providers is used strictly to provide the Services' conversational functionality and is contractually prohibited from being used to train public AI foundation models.

Distinction between our AI providers and your AI Agent. Google and OpenAI act as our service providers — they process inputs to operate the Services on Glow Tech's behalf. Your AI Agent (also possibly a product of OpenAI, Anthropic, or another provider) acts as your delegate — it processes inputs on your behalf, independently of Glow Tech. The two relationships are distinct, even when the underlying provider is the same.

B. Improving the Services

We may use information (including embeddings, feedback, and other signals) to improve matching and system performance. Where feasible, we aim to use aggregated and/or de-identified information to improve our systems.

If we offer a choice to opt out of certain improvement uses, we will provide that choice in settings or via a data request process.

C. Human review

We may review limited information where necessary to:

• Provide customer support

• Investigate safety reports and abuse

• Debug and improve system reliability

• Comply with law

We aim to restrict access to Personal Data to personnel with a need to know, and to log and control such access.

D. AI-generated content about other users

The Services may generate AI-derived descriptions, summaries, "why this match" explanations, group composition, activity or venue suggestions, routes, schedules, and other content about users or an Eka Experience. This content reflects model output rather than verified facts. We do not warrant the accuracy of AI-generated content, and you should not treat it as a factual representation of any person, place, availability, condition, or risk.

E. Automated decision-making

We use automated systems (including machine-learning models) to generate match recommendations and rank candidate introductions. These automated decisions do not produce legal or similarly significant effects on you — they affect only which voluntary introductions you are offered, and you may always decline any introduction.

Where required by law, you may request information about how matching works at a high level, request human review of an automated decision that affects you, or object to automated decision-making by contacting privacy@talktoglow.com. We will respond in accordance with applicable law.

9. Retention of Personal Data

We retain Personal Data for as long as reasonably necessary to provide the Services and fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law.

Retention periods may depend on factors such as:

• Whether you maintain an active account

• Your chosen privacy/memory settings (e.g., embeddings-only mode)

• Per-photo privacy level settings

• The need to maintain safety records (e.g., fraud prevention, enforcement, and abuse reports)

• Legal, tax, and accounting requirements

General retention guidance. The following describes our typical retention practices. Specific periods may vary based on the factors above and applicable law:

• Account profile data — retained while your account is active and for a reasonable period after deletion to satisfy legal, safety, and dispute-resolution requirements.

• Conversation transcripts — retained according to your privacy/memory settings. If you have not configured a shorter retention period, transcripts may be retained while your account is active, except where retained longer for safety investigations or legal compliance.

• Eka group and experience records — invitations, group composition, RSVPs, schedules, meeting details, reservation information, attendance or no-show records, and related messages available to us may be retained while needed to operate Eka and for a reasonable period for safety, fraud prevention, dispute resolution, and legal compliance.

• Location and logistics information — retained for as long as reasonably necessary for the purpose for which you provided it and any applicable safety, dispute-resolution, or legal purpose.

• Embeddings and matching signals — retained while your account is active and for a reasonable period after deletion or until you change your memory settings.

• Age attestation records — retained for the life of the account plus a reasonable period thereafter for legal and compliance purposes.

• AI Agent activity logs — retained for security, abuse detection, and dispute resolution purposes for a period proportionate to those purposes.

• Safety and abuse records — retained as long as necessary to maintain platform safety, even after account deletion.

Account deletion

If you request deletion of your account, we will delete or de-identify Personal Data in accordance with applicable law and our retention practices. We may retain certain information for legitimate business purposes (for example, to comply with legal obligations, resolve disputes, enforce agreements, and maintain safety and fraud-prevention records).

When you delete your account, all AI Agents authorized to act on your behalf are also revoked and their API keys invalidated. Account deletion does not delete messages, contact details, calendar entries, reservation records, screenshots, or other copies retained by other participants, Apple or another messaging platform, a carrier, a venue, or another third party.

Backups may persist for a limited period, after which they will be overwritten or deleted according to our backup policies.

10. Security

We use administrative, technical, and physical safeguards designed to protect Personal Data, including (as appropriate):

• Encryption in transit (e.g., TLS) and encryption at rest

• Access controls and least-privilege principles

• Logging and monitoring

• Hashing of API keys before storage

• Vendor due diligence and contractual protections

• Security testing and incident response processes

No method of transmission over the Internet or electronic storage is completely secure. While we work to protect your information, we cannot guarantee absolute security. We also do not control the security of Apple Messages/iMessage, telecommunications networks, another participant's device or account, or a venue or third-party provider.

11. International Data Transfers

Glow Tech is based in the United States, and your Personal Data may be processed and stored in the United States and other jurisdictions where we or our service providers operate.

If you are located in the European Economic Area (EEA), the United Kingdom, or Switzerland, we will implement appropriate safeguards for international transfers where required (such as Standard Contractual Clauses or other lawful transfer mechanisms).

12. Your Rights and Choices

Depending on where you live, you may have rights regarding your Personal Data. We will honor applicable rights requests in accordance with law.

A. General rights and controls

You may be able to:

• Access, correct, or update your profile information in-app

• Change your privacy/memory settings (including limiting what is stored)

• Set or change per-photo privacy levels

• Authorize, view, or revoke AI Agents that have access to your account

• Opt out of marketing communications (via unsubscribe links or account settings)

• Ask us to stop automated service messages, leave or mute an Eka group, or use available messaging-platform controls. These choices may limit or end your ability to use Eka and do not erase previously delivered messages.

• Request access, deletion, or portability of your Personal Data by contacting us

B. U.S. state privacy rights (including California)

Residents of certain U.S. states may have rights such as:

• Right to know/access

• Right to delete

• Right to correct

• Right to opt out of targeted advertising

• Right to opt out of certain "sharing" or "sales" (as defined by state law)

• Right to limit use and disclosure of sensitive personal information (where applicable)

• Right to not be discriminated against for exercising privacy rights

• Right to appeal a denied request (in some states)

• Right to know about and request human review of automated decision-making (where applicable under state law)

We do not intend to "sell" Personal Data in the traditional sense. However, some uses of analytics and advertising technologies may be considered "sharing" for targeted advertising under certain laws. Where required, we will provide opt-out mechanisms.

C. EEA/UK/Switzerland rights and legal bases (GDPR)

If you are in the EEA/UK/Switzerland, you may have rights to:

• Access, rectification, erasure

• Restrict or object to processing

• Data portability

• Withdraw consent (where processing is based on consent)

• Lodge a complaint with a supervisory authority

Legal bases (where applicable) may include:

• Performance of a contract (e.g., providing the Services)

• Legitimate interests (e.g., improving the Services, securing the platform, preventing abuse)

• Consent (e.g., certain sensitive data uses, certain marketing, certain optional features)

• Compliance with legal obligations

D. Identity verification

To protect your privacy and security, we may need to verify your identity before fulfilling certain requests.

13. Children and Teen Users

Talk to Glow is open to users 13 and older, but Eka is strictly limited to adults 18 and older. We do not knowingly collect personal information from children under 13. If you believe a child under 13 has provided us personal information, or that any person under 18 is using or participating in Eka, please contact us at privacy@talktoglow.com or safety@talktoglow.com and we will investigate and take appropriate action.

Geographic availability

Teen-user accounts (13–17) are currently available only to users located in the United States. We do not knowingly create teen accounts for users located outside the United States. If we determine a teen account was created outside the United States, we may suspend or terminate the account.

Teen users (13–17)

Users between the ages of 13 and 17 ("teen users") have additional protections:

• We collect only the personal information necessary to operate the age-appropriate features of Talk to Glow available to teen users: name, email or phone number, year of birth (and full birthdate only if necessary to confirm age), pronouns, general location (city/region), and the interests you choose to share with us.

• We do not collect dating-context or adult-context attributes from teen users, including physical descriptors, relationship status or history, sexual orientation, religion, political views, or income.

• Teen users are placed in a separate matching community designed to prevent them from being matched with, contacted by, or appearing as candidates to adult users. We use technical controls — including community segregation, application-layer enforcement, and automated invariant testing — to maintain this separation. While we work to ensure these controls are effective, no system is infallible; please report any concerns to safety@talktoglow.com.

• Photos uploaded by teen users default to Hidden and cannot be raised to a more visible privacy level.

• Romantic and dating connection types are not available to teen users.

• Eka is not available to teen users. Teen users cannot be placed in, invited to, or participate in an Eka group or Eka Experience, and adult users may not add or bring minors.

• We do not use teen users' personal information for behavioral advertising. We do not sell or share teen users' personal information with third parties for cross-context behavioral advertising as defined under applicable state laws.

• We may apply additional automated content filtering, human review, and moderation safeguards to interactions involving teen users.

• AI Agents may register or act on behalf of teen users; the same protections above apply to all agent-mediated actions, and the agent cannot bypass them.

Parental rights

A parent or legal guardian may contact us at privacy@talktoglow.com to:

• Review the personal information we have collected from their child

• Request that we delete their child's account and personal information

• Refuse to permit further collection or use of their child's personal information

• Revoke any AI Agent's authorization to act on their child's behalf

We will respond to verified parental requests within 30 days.

Transition to adulthood

When a teen user reaches age 18, additional profile fields and adult-only features (including romantic and dating connection types and Eka) may become available only after the user confirms adult eligibility and completes any required adult-feature onboarding and terms acceptance. We begin collecting additional adult-only or Eka-specific fields only when the user explicitly provides them. We do not retroactively infer, derive, or backfill dating-context attributes — such as physical descriptors, relationship status, sexual orientation, religion, political views, or income — based on prior teen-era interactions.

14. Cookies and Similar Technologies

We may use cookies and similar technologies on our websites to:

• Provide core functionality (e.g., authentication, security)

• Remember preferences

• Understand usage and improve performance (analytics)

• Support marketing (where applicable)

You can control cookies through your browser settings and, where implemented, through our cookie preference tools.

Do Not Track

Some browsers offer a "Do Not Track" signal. There is currently no universally accepted standard for responding to these signals. We may update our practices if an industry standard emerges.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes, we will provide notice by updating the "Last Updated" date and, where appropriate, providing additional notice through the Services or by email.

Your continued use of the Services after the effective date of an updated Privacy Policy means you agree to the updated policy to the extent permitted by law.

16. How to Contact Us

If you have questions about this Privacy Policy or want to exercise your privacy rights, contact us at:

Glow Tech, Inc.
Email: privacy@talktoglow.com
Data Requests: privacy@talktoglow.com
Safety and incident reports: safety@talktoglow.com