Privacy Policy

1. Who are we?

Sugarfar.com is operated by Disp I/S, a partnership registered in Denmark under CVR no. 38507508, with registered address at Maglebjergvej 6, 2800 Kongens Lyngby, Denmark. We are the organization responsible for the personal information of our Canadian users under the federal Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy legislation.

For privacy questions and to contact our privacy officer, write to: support@sugarfar.com

2. What information do we collect?

We collect the following types of personal information from Canadian users, with your knowledge and consent:

Information you provide to us

• Account information: Email address, username and password upon registration
• Profile data: Age, gender, Canadian city or province, profile text, interests and preferences
• Photos: Profile pictures and gallery images you upload
• Messages: Chat messages and images sent to other users
• Payment information: Processed directly by Stripe — we never receive or store your card details

Information we collect automatically

• Technical data: IP address, browser type, device type and operating system
• Usage data: Page views, clicks and interactions with the platform
• Cookies: See section 8 on cookies

We collect only the personal information that is reasonably necessary for the purposes identified below, in line with the limiting-collection principle under PIPEDA Schedule 1.

3. What do we use your information for?

We process your personal information for the following identified purposes:

• Service delivery: Creating and maintaining your profile, displaying you to other users, and enabling chat
• Security: Verifying profiles, detecting and preventing abuse, fraud and fake profiles
• Improvement: Optimizing the platform, features and user experience
• Communication: Sending service notifications, match notifications and (with your express consent) commercial electronic messages in compliance with Canada's Anti-Spam Legislation (CASL)
• Payment: Processing subscription payments via Stripe in Canadian dollars (CAD)

By creating an account, you provide express consent for these purposes. Where consent has been given, you may withdraw it at any time, subject to legal or contractual restrictions.

4. Who do we share information with?

We never sell your personal information. We share information only with trusted service providers that process data on our behalf, including Stripe (payments), our hosting provider, and email/transactional service providers.

Some service providers are located outside Canada (primarily in the European Union and the United States). When personal information is transferred across borders, it may be subject to the laws of the foreign jurisdiction, including potential lawful access by foreign government authorities. We use Standard Contractual Clauses and written data processing agreements to ensure a comparable level of protection, consistent with the cross-border transfer guidance from the Office of the Privacy Commissioner of Canada (OPC).

5. Security

We protect your information with the following safeguards (administrative, technical and physical):

• All data transmission takes place via HTTPS (TLS encryption)
• Passwords are hashed with industry-standard algorithms — we can never see your password
• Payment details are handled exclusively by Stripe (PCI DSS certified) and are never stored on our servers
• Access to personal information is restricted to authorized personnel on a need-to-know basis
• Row Level Security (RLS) ensures that users can only see information they are entitled to

6. Retention and deletion

We retain your personal information only as long as necessary to fulfill the purposes for which it was collected, in accordance with PIPEDA's limiting-retention principle.

• Chat images: Automatically deleted after 5 days
• Profile data: Deleted upon deletion of your account
• Payment history: Retained for up to 5 years for tax and bookkeeping purposes (consistent with Canada Revenue Agency record-keeping expectations and our Danish bookkeeping obligations)
• Log files: Automatically deleted after 90 days

You can delete your profile at any time under "My Account". All your profile data, photos and messages will be permanently deleted.

7. Your rights under PIPEDA and provincial law

Under PIPEDA and provincial private-sector privacy laws (including British Columbia's PIPA, Alberta's PIPA, and Quebec's Act respecting the protection of personal information in the private sector — as amended by Law 25), you have the following rights:

• Access: The right to be informed of the existence, use and disclosure of your personal information and to be given access to that information
• Correction: The right to challenge the accuracy and completeness of the information and have it amended as appropriate
• Withdrawal of consent: The right to withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice
• Deletion: The right to delete your profile and all associated data via "My Account"
• Portability: Where the Quebec Law 25 right to data portability applies, you may request your information in a structured, commonly used technological format
• Challenging compliance: The right to address any concerns about our handling of your personal information to our privacy officer

Requests should be sent to: support@sugarfar.com. We will respond within 30 days, as required by PIPEDA.

If you are not satisfied with our response, you have the right to file a complaint with the Office of the Privacy Commissioner of Canada at priv.gc.ca. Residents of Quebec may also contact the Commission d'accès à l'information du Québec, residents of British Columbia the Office of the Information and Privacy Commissioner for British Columbia, and residents of Alberta the Office of the Information and Privacy Commissioner of Alberta.

8. Cookies

Sugarfar uses cookies to deliver and improve the service. We distinguish between:

• Necessary cookies: Required for the platform to function (login sessions, security). These do not require consent.
• Analytical cookies: Used to understand how visitors use the site. Subject to your consent.
• Marketing cookies: Used to target advertisements. Subject to your consent.

You can change your cookie preferences at any time via the cookie settings in the site footer. You can also block cookies in your browser, but certain features may not function optimally.

9. Breach notification

If we experience a breach of security safeguards involving personal information that creates a real risk of significant harm, we will notify affected Canadian users and the Office of the Privacy Commissioner of Canada as soon as feasible, in accordance with the federal Breach of Security Safeguards Regulations under PIPEDA.

10. Changes to this policy

We may update this privacy policy from time to time. In the event of significant changes, we will inform you via email or a notice on the platform. The latest version will always be available on this page.

11. Contact

Questions or concerns about this privacy policy or the handling of your personal information can be directed to our privacy officer:

Disp I/S
Maglebjergvej 6, 2800 Kongens Lyngby, Denmark
CVR: 38507508
Email: support@sugarfar.com