Privacy Policy

Introduction

Nattrly, Inc. ("Nattrly," "we," "our," or "us") values your privacy. This Privacy Policy explains how we collect, use, store, share, and protect your personal information when you visit nattrly.com and all related subdomains, use our mobile or web applications, or interact with our services (collectively, the "Platform"). By using the Platform, you consent to the practices described in this policy.

Information We Collect

We collect information that you voluntarily provide to us, as well as information collected automatically through your use of the Platform.

Information you provide:

Information collected automatically:

We do not sell or rent your personal information to third parties.

• Name, email address, phone number, and mailing address
• Date of birth and age verification data
• Profile details such as interests, preferences, and accessibility needs
• Emergency contact names and phone numbers
• Payment information processed securely by our payment processors (Cardknox and Stripe); we do not store full credit card numbers
• For Trusted Companions: government-issued identification, Social Security Number (last 4 digits), photograph, and background check consent
• Communications you send to us, including support tickets, feedback, and chat messages
• Session notes and feedback submitted after companionship sessions
• Affiliate referral codes and referral relationship data
• Device information (browser type, operating system, device identifiers)
• IP address and approximate geographic location
• Pages visited, time spent on pages, and navigation patterns
• Cookies and similar tracking technologies (see Cookies & Analytics section)
• Session metadata (start/end times, duration, connection quality)

How We Use Your Information

We use your information to:

• Provide, operate, and maintain the Platform and our services
• Create and manage your account
• Match Members with compatible Trusted Companions based on shared interests
• Process bookings, payments, subscription management, and refunds
• Send session reminders, confirmations, receipts, and safety alerts via SMS and email
• Notify your emergency contacts during sessions when the SOS feature is activated
• Conduct Trusted Companion identity verification and background screening
• Monitor virtual sessions for safety through automated content moderation
• Detect, prevent, and address fraud, abuse, and security issues
• Respond to your inquiries and provide customer support
• Improve, personalize, and develop the Platform
• Comply with legal obligations, enforce our Terms, and protect our rights
• Administer the affiliate referral program, including commission tracking and payouts

Data Sharing Third Parties

We share your information only in the following circumstances:

We will not share your information with any third party for their own marketing purposes without your express opt-in consent.

• Service Providers: We share data with third-party service providers who perform services on our behalf, including payment processing (Cardknox, Stripe), identity verification (Pipl, Au10tix), background screening (KIT Recon), video calling (Daily.co), SMS messaging (Twilio), email communications (Resend), cloud storage (Cloudflare R2), content moderation (Anthropic), and analytics tools. These providers are contractually bound to use your data only for the services they provide to us.
• Trusted Companions and Members: When a session is booked, we share limited profile information (name, interests, session details) between the Member and Trusted Companion to facilitate the session.
• Emergency Contacts: When the SOS feature is activated, we share your name and session details with your designated emergency contacts via SMS.
• Legal Requirements: We may disclose your information when required by law, court order, subpoena, or government request, or when we believe disclosure is necessary to protect our rights, your safety, or the safety of others.
• Business Transfers: In the event of a merger, acquisition, or sale of all or a portion of our assets, your information may be transferred as part of that transaction. We will notify you of any such change.
• With Your Consent: We may share your information for other purposes with your explicit consent.

Background Check Disclosure (fcra Notice)

For Trusted Companion applicants: As part of our verification process, Nattrly obtains consumer reports and investigative consumer reports (collectively, "Background Reports") through our screening partners. These reports may include:

In accordance with the Fair Credit Reporting Act (FCRA):

• Criminal records (50-state, federal, and county-level searches)
• Sex offender registry checks
• Social media and online presence analysis
• Facial recognition and reverse image searches
• Identity validation and government ID verification
• Address history and public records
• You will be provided with a clear written disclosure that a Background Report may be obtained, in a document consisting solely of the disclosure, before the report is procured.
• You must provide written authorization before we obtain any Background Report.
• If information in a Background Report is used, in whole or in part, to make an adverse decision (such as denial of your application), you will be provided with: (a) a copy of the report; (b) a written summary of your rights under the FCRA; and (c) the name, address, and phone number of the consumer reporting agency that furnished the report.
• You have the right to dispute the accuracy or completeness of any information in a Background Report directly with the consumer reporting agency.
• Background check data is retained only for as long as necessary to maintain verification status and comply with legal requirements, and is deleted within 90 days of account closure unless required for ongoing legal proceedings.

Data Retention

We retain your personal information for as long as your account is active or as needed to provide services to you. Specific retention periods:

After the applicable retention period, personal data is securely deleted or anonymized.

• Account and profile data: retained while your account is active and for 30 days after account closure to allow for reactivation
• Payment transaction records: retained for 7 years as required by tax and financial regulations
• Session history and notes: retained for 2 years after the session date
• Background check data for Trusted Companions: retained for the duration of active status plus 90 days after deactivation
• Communications and support tickets: retained for 3 years
• Automated content moderation data (transcription analysis): retained for 90 days for safety review, then permanently deleted
• SOS alert records: retained for 5 years for safety and legal purposes
• Anonymized and aggregated data: may be retained indefinitely for analytics and service improvement

Mobile Text Messaging Privacy

No mobile number information will be shared with third parties or affiliates for marketing or promotional purposes. All categories above exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

By providing your phone number, you consent to receive SMS messages from Nattrly related to your account, including session reminders, booking confirmations, receipts, safety alerts, and account notifications. Message frequency varies based on your account activity. Standard message and data rates may apply.

Your Access To & Control Over Information

You may request at any time:

• A copy of the personal data we have about you in a portable, machine-readable format
• Corrections to inaccurate or incomplete information
• Deletion of your personal information (see our Data Deletion Policy at nattrly.com/data-deletion)
• Restriction of processing of your personal information
• That we cease future marketing communications (transactional communications related to your account may continue)
• An accounting of the categories of data we have collected and shared about you

California Privacy Rights (ccpa/cpra)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA):

Categories of personal information collected in the preceding 12 months are described in the "Information We Collect" section above. We collect this information for the business purposes described in the "How We Use Your Information" section.

• Right to Know: You have the right to request that we disclose the categories and specific pieces of personal information we have collected about you, the categories of sources, the business purpose for collection, and the categories of third parties with whom we share it.
• Right to Delete: You have the right to request deletion of personal information we have collected from you, subject to certain exceptions (legal obligations, fraud detection, completing transactions).
• Right to Correct: You have the right to request correction of inaccurate personal information.
• Right to Opt-Out of Sale/Sharing: We do not sell your personal information. We do not share your personal information for cross-context behavioral advertising.
• Right to Non-Discrimination: We will not discriminate against you for exercising your CCPA rights.

Security

We take reasonable administrative, technical, and physical precautions to protect your information. Our security measures include:

While we strive to protect your personal information, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security.

• HTTPS encryption for all data in transit
• Encryption at rest for sensitive data including passwords and payment tokens
• Access to personal information restricted to authorized personnel on a need-to-know basis
• Regular security audits and vulnerability assessments
• Secure, access-controlled server infrastructure
• Firebase Authentication with multi-factor authentication support

Third-party Links

The Platform may contain links to external websites or services not operated by Nattrly. We are not responsible for the privacy practices, content, or security of those third-party websites. We encourage you to review their privacy policies before providing any personal information.

Cookies Analytics

Our Platform uses cookies and similar technologies to:

We use Google Analytics and Meta Pixel for analytics purposes. These tools collect non-personally identifiable information such as browser type, pages visited, and time spent on site. You may disable non-essential cookies through your browser settings. Essential cookies required for authentication and core Platform functionality cannot be disabled while using the Platform.

• Maintain your authentication session (essential cookies)
• Remember your preferences and settings
• Analyze Platform usage and performance (analytics cookies)
• Track affiliate referral codes

Children's Privacy

International Users

The Platform is operated in the United States. If you access the Platform from outside the United States, your information will be transferred to, stored, and processed in the United States. By using the Platform, you consent to the transfer of your information to the United States, which may have different data protection laws than your country of residence.

Updates

This Privacy Policy may be updated from time to time. Material changes will be communicated to registered users by email and/or prominent notice on the Platform at least 14 days before taking effect. The revised effective date will be posted at the top of this page. Your continued use of the Platform after the effective date constitutes acceptance of the updated Privacy Policy.

Contact Us

If you have questions about this Privacy Policy, wish to exercise your data rights, or believe we are not abiding by this policy, please contact:

Nattrly, Inc.

1965 US-9

Toms River, NJ 08755

[email protected]

(888) 925-5855