Privacy Policy

Last updated 7 June 2025

OUR COMMITMENT TO YOU

At Bloc, your privacy is a top priority. Your privacy is at the core of the way we design and build the services and products you know and love, so that you can fully trust them and focus on building meaningful connections. We appreciate that you put your trust in us when you provide us with your information and we do not take this lightly.

We do not compromise with your privacy. We design all of our products and services with your privacy in mind. We involve experts from various fields, including legal, security, engineering, product design and others to make sure that no decision is taken without respect for your privacy.

We strive to be transparent in the way we process your data. Because we use many of the same online services you do, we know that insufficient information and overly complicated language are common issues in privacy policies. We take the exact opposite approach: we have written our Privacy Policy and related documents in plain language. We actually want you to read our policies and understand our privacy practices!

We work hard to keep your information secure. We have teams dedicated to keeping your data safe and secure. We constantly update our security practices and invest in our security efforts to enhance the safety of your information.

We appreciate that you trust us with your information and we intend to always keep that trust. This starts with making sure you understand the information we collect, why we collect it, how it is used and your choices regarding your information. This Policy describes our privacy practices in plain language, keeping legal and technical jargon to a minimum.

This Privacy Policy explains the information that Thundersnow Ltd (“Thundersnow Ltd,” “we,” or “us”) collect about users of the Bloc mobile application and related website (“Bloc”), how we use that information, and with whom we share it. If we make any material changes to our privacy practices, we will post a revised Privacy Policy on this page. If you have any questions, please contact us by sending an email to [email protected] or writing to Bloc, 17 Broughton Road, Fulham, London, SW6 2LE.

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1. Who we are

The company that is responsible for your information under this Privacy Policy (the “data controller”) is:

Thundersnow Ltd 17 Broughton Road Fulham London SW6 2LE

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2. Where this privacy policy applies

This Privacy Policy applies to websites, apps, events and other services operated by Bloc. For simplicity, we refer to all of these as our “services” in this Privacy Policy. To make it extra clear, we’ve added links to this Privacy Policy on all applicable services.

Some services may require their own unique privacy policy. If a particular service has its own privacy policy, then that policy — not this Privacy Policy — applies.

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3. INFORMATION WE COLLECT

It goes without saying, we can’t help you develop meaningful connections without some information about you, such as basic profile details and the types of people you’d like to meet. We also collect information generated as you use our services, for example access logs, as well as information from third parties, like when you access our services through a social media account. If you want additional info, we go into more detail below.

Information you give us:

You choose to give us certain information when using our services. This includes:

• When you create an account, you provide us with at least your login credentials, as well as some basic details necessary for the service to work, such as your gender and date of birth.
• When you complete your profile, you can share with us additional information, such as details on your personality, lifestyle, interests and other details about you, as well as content such as photos and videos. To add certain content, like pictures or videos, you may allow us to access your camera or photo album. Some of the information you choose to provide us may be considered “special” or “sensitive” in certain jurisdictions, for example your racial or ethnic origins, sexual orientation and religious beliefs. By choosing to provide this information, you consent to our processing of that information.
• When you subscribe to a paid service or make a purchase directly from us (rather than through a platform such as iOS or Android), you provide us or our payment service provider with information, such as your debit or credit card number or other financial information.
• When you participate in surveys or focus groups, you give us your insights into our products and services, responses to our questions and testimonials.
• When you choose to participate in our promotions, events or contests, we collect the information that you use to register or enter.
• If you contact our customer care team, we collect the information you give us during the interaction. Sometimes, we monitor or record these interactions for training purposes and to ensure a high quality of service.
• If you ask us to communicate with or otherwise process information of other people (for example, if you ask us to send an email on your behalf to one of your friends), we collect the information about others that you give us in order to complete your request.
• Of course, we also process your chats with other users as well as the content you publish, as part of the operation of the services.

Information we receive from others

In addition to the information you provide us directly, we receive information about you from others, including:

• Other Users: Other users may provide information about you as they use our services. For instance, we may collect information about you from other users if they contact us about you.
• Social Media: You may be able to use your social media login (such as Facebook Login) to create and log into your Bloc account. This saves you from having to remember yet another user name and password and allows you to share some information from your social media account with us.
• Other Partners: We may receive info about you from our partners, for instance where Bloc ads are published on a partner’s websites and platforms (in which case they may pass along details on a campaign’s success).

Information collected when you use our services

When you use our services, we collect information about which features you’ve used, how you’ve used them and the devices you use to access our services. See below for more details:

• Usage Information We collect information about your activity on our services, for instance how you use them (e.g., date and time you logged in, features you’ve been using, searches, clicks and pages which have been shown to you, referring webpage address, advertising that you click on) and how you interact with other users (e.g. users you connect and interact with, time and date of your exchanges, number of messages you send and receive).
• Device information We collect information from and about the device(s) you use to access our services, including:
  • hardware and software information such as IP address, device ID and type, device-specific and apps settings and characteristics, app crashes, advertising IDs (such as Google’s AAID and Apple’s IDFA, both of which are randomly generated numbers that you can reset by going into your device’ settings), browser type, version and language, operating system, time zones, identifiers associated with cookies or other technologies that may uniquely identify your device or browser (e.g., IMEI/UDID and MAC address);
  • information on your wireless and mobile network connection, like your service provider and signal strength;
  • information on device sensors such as accelerometers, gyroscopes and compasses.
• Other information with your consent If you give us permission, we can collect your precise geolocation (latitude and longitude) through various means, depending on the service and device you’re using, including GPS, Bluetooth or Wi-Fi connections. The collection of your geolocation may occur in the background even when you aren’t using the services if the permission you gave us expressly permits such collection. If you decline permission for us to collect your geolocation, we will not collect it. Similarly, if you consent, we may collect your photos and videos (for instance, if you want to publish a photo, video or streaming on the services).

When you complete your profile, you can share additional information, such as details on your personality, lifestyle, interests, and other details about you, as well as content like photos and videos. To add certain content, like pictures or videos, you may allow us to access your camera or photo album. Some of the information you choose to provide us may be considered “special” or “sensitive” in certain jurisdictions, such as your racial or ethnic origins, sexual orientation, and religious beliefs.

We collect this sensitive information only if you choose to provide it and with your explicit consent. We use this information to enhance your experience and help you find meaningful connections by allowing you to express yourself more fully and, where you choose, enabling us to suggest matches or interactions based on these shared characteristics or preferences. For example, if you indicate a specific religious belief, you might be shown other users who share similar beliefs, if you and they choose to make this information visible for matching purposes. By choosing to provide this information, you consent to our processing of that information for these purposes.

Other Partners

We may receive information about you from our partners, for instance, where Bloc ads are published on a partner’s websites and platforms. In such cases, they may pass along details on a campaign’s success, such as whether an ad led to a registration. Generally, the information we receive from these partners is aggregated and anonymized (meaning it doesn’t directly identify you). In limited instances, if you specifically interact with a Bloc advertisement on a partner’s site and grant them permission, our partners might share certain non-sensitive personal information (like a hashed identifier to confirm your interaction with the ad) to help us measure the effectiveness of our advertising campaigns and understand user acquisition better. We always ensure these partners adhere to strict data protection standards.

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4. COOKIES AND OTHER SIMILAR DATA COLLECTION TECHNOLOGIES

We use and may allow others to use cookies and similar technologies (e.g., web beacons, pixels) to recognize you and/or your device(s).

Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) have a “Do Not Track” (“DNT”) feature that tells a website that a user does not want to have his or her online activity tracked. If a website that responds to a DNT signal receives a DNT signal, the browser can block that website from collecting certain information about the browser’s user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many businesses, including Bloc, do not currently respond to DNT signals.

We use and may allow others to use cookies and similar technologies (e.g., web beacons, pixels) to recognize you and/or your device(s). These technologies help us understand how you use our services, improve your experience, and deliver relevant content and advertising.

Some web browsers (including Safari, Internet Explorer, Firefox, and Chrome) have a “Do Not Track” (“DNT”) feature that tells a website that a user doesn’t want their online activity tracked. Currently, there isn’t a universally accepted standard for how websites should respond to these DNT signals. For this reason, many businesses, including Bloc, don’t currently respond to DNT signals. However, you can generally manage your cookie preferences directly within your browser settings to control which cookies are accepted or blocked.

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5. HOW WE USE INFORMATION

The main reason we use your information is to deliver and improve our services. Additionally, we use your info to help keep you safe and to provide you with advertising that may be of interest to you. Read on for a more detailed explanation of the various reasons we use your information, together with practical examples.

To administer your account and provide our services to you:

• Create and manage your account
• Provide you with customer support and respond to your requests
• Complete your transactions
• Communicate with you about our services, including order management and billing

To help you connect with other users

• Analyze your profile and that of other users to recommend meaningful connections
• Show users’ profiles to one another

To ensure a consistent experience across your devices

• Link the various devices you use so that you can enjoy a consistent experience of our services on all of them. We do this by linking devices and browser data, such as when you log into your account on different devices or by using partial or full IP address, browser version and similar data about your devices to help identify and link them.

To provide new Bloc services to you

• Register you and display your profile on new Bloc features and apps
• Administer your account on these new features and apps

To serve you relevant offers and ads

• Administer sweepstakes, contests, discounts or other offers
• Develop, display and track content and advertising tailored to your interests on our services and other sites
• Communicate with you by email, phone, social media or mobile device about products or services that we think may interest you

To improve our services and develop new ones

• Administer focus groups and surveys
• Conduct research and analysis of users’ behavior to improve our services and content (for instance, we may decide to change the look and feel or even substantially modify a given feature based on users’ behavior)
• Develop new features and services (for example, we may decide to build a new interests-based feature further to requests received from users).

To prevent, detect and fight fraud or other illegal or unauthorized activities

• Address ongoing or alleged misbehavior on and off-platform
• Perform data analysis to better understand and design countermeasures against these activities
• Retain data related to fraudulent activities to prevent against recurrences

To ensure legal compliance

• Comply with legal requirements
• Assist law enforcement
• Enforce or exercise our rights, for example our Terms

How We Use Information – Automated Decision Making/Profiling

To enhance your experience and help you find meaningful connections efficiently, we use automated processes and profiling. This involves analyzing the information you provide and how you use our services (such as your interests, location data, and interactions with other users).

The logic involved is designed to:

• Recommend meaningful connections: Our algorithms analyze your profile and activity patterns, as well as those of other users, to suggest compatible matches. For example, if you frequently interact with users who share a specific interest, our system might prioritize showing you more profiles with that interest.
• Serve relevant offers and ads: Based on your preferences, interactions, and general demographic information, we may present you with personalized content, features, and advertisements that we believe will be of interest to you, both within Bloc and on other platforms.

The significance and envisaged consequences of this profiling are to provide you with a more tailored and efficient service, helping you discover individuals and content more aligned with your preferences. While these automated processes are central to how Bloc operates, they are primarily focused on enhancing your user experience and don’t typically lead to legal effects or similarly significant effects concerning you outside of the service’s functionality. You always have control over the information you choose to share, which directly influences the personalization you experience.

The main reason we use your information is to deliver and improve our services. Additionally, we use your info to help keep you safe and to provide you with advertising that may be of interest to you.

To process your information as described above, we rely on the following legal bases as permitted by applicable law (e.g., the UK GDPR for users in the United Kingdom and the European Economic Area):

1. Performance of a Contract: This legal basis applies when processing your personal data is necessary to fulfill our contractual obligations to you, or to take steps at your request before entering into a contract.

• Activities & Examples:
  • Creating and managing your account: We need your basic details to set up and maintain your profile.
  • Providing you with customer support and responding to your requests: To address your queries and issues related to our services.
  • Completing your transactions: Processing payment information for paid services.
  • Communicating with you about our services: Including order management and billing.
  • Linking your various devices: To ensure a consistent experience across all your devices when you log in.
  • Helping you connect with other users: Analyzing profiles to recommend meaningful connections and showing users’ profiles to one another is fundamental to the service we contractually provide.
  • Processing your chats with other users: As part of the core functionality of the service.
  • Registering you and displaying your profile on new Bloc features and apps: If these are integrated services you use.

2. Legitimate Interests: We process your information where we have a legitimate interest to do so, provided these interests are not overridden by your fundamental rights and freedoms. We ensure that our legitimate interests are balanced against your privacy rights.

• Activities & Examples:
  • Improving our services and developing new ones: Conducting research and analysis of users’ behavior (e.g., how features are used) to understand engagement and inform improvements or development of new features (e.g., changing the look of a feature, building new interest-based functionalities).
  • Administering focus groups and surveys: To gather insights for service enhancement.
  • Preventing, detecting, and fighting fraud or other illegal or unauthorized activities: Addressing ongoing or alleged misbehavior, performing data analysis to understand and design countermeasures, and retaining data related to fraudulent activities to prevent recurrences. This protects both our business and our users.
  • Ensuring the security of our data and systems: Regularly monitoring for vulnerabilities and attacks, and reviewing security practices.
  • Developing, displaying, and tracking content and advertising tailored to your interests: Showing you offers and ads on our services and other sites that we believe are relevant to you, which is beneficial for our business and can enhance your experience.
  • Communicating with you by email, phone, social media, or mobile device about products or services that we think may interest you: Unless you have opted out of such communications.
  • Sharing limited information with partners who distribute and assist us in advertising our services: For instance, sharing hashed, non-human readable data with advertising partners to measure campaign success.
  • Administering sweepstakes, contests, discounts, or other offers: To promote our services.
  • For corporate transactions: Such as mergers, sales, or reorganizations, to ensure the continuity of the business.
  • Sharing with other Thundersnow businesses for internal administrative purposes: Including corporate audit, analysis, consolidated reporting, and ensuring compliance across the group.

3. Consent: From time to time, we may ask for your explicit consent to use your information for certain specific reasons, particularly for processing “special” or “sensitive” categories of personal data or for certain types of marketing.

• Activities & Examples:
  • Collecting “special” or “sensitive” personal data (e.g., racial or ethnic origins, sexual orientation, religious beliefs): We collect this only if you explicitly choose to provide it for your profile, allowing you to express yourself more fully and, where applicable, enabling us to suggest matches or interactions based on these shared characteristics or preferences.
  • Collecting your precise geolocation (latitude and longitude) through GPS, Bluetooth, or Wi-Fi connections: This only occurs if you give us permission, and may occur in the background if expressly permitted by the permission you gave.
  • Collecting your photos and videos (for instance, if you want to publish content on the services): We access your camera or photo album only with your explicit permission.
  • Certain marketing activities: Where specific consent is required by law or deemed appropriate, we will obtain your consent before sending you promotional communications.

You have the right to withdraw your consent at any time by contacting us at the address provided at the end of this Privacy Policy, or by using the tools provided within the service (e.g., adjusting device permissions). Withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.

4. Legal Obligation: We may process your information where it is necessary to comply with a legal or regulatory obligation.

• Activities & Examples:
  • Complying with legal requirements: Such as responding to court orders, subpoenas, or search warrants.
  • Assisting law enforcement: When legally required to do so, for instance, in the prevention or detection of crime.
  • Retaining certain “traffic data”: For a specified period to comply with statutory data retention obligations.
  • Providing information to regulatory bodies or authorities: When legally mandated.

5. To Enforce Legal Rights: We may process your information when it is necessary to establish, exercise, or defend our legal rights, or the rights of our users, business partners, or other interested parties.

• Activities & Examples:
  • Investigating, preventing, or taking action regarding illegal activity, suspected fraud, or other wrongdoing.
  • Enforcing or exercising our rights under our Terms of Service.
  • Mitigating our liability in an actual or threatened lawsuit.

To process your information as described above, we rely on the following legal bases:

• Provide our service to you: Most of the time, the reason we process your information is to perform the contract that you have with us. For instance, as you go about using our service to build meaningful connections, we use your information to maintain your account and your profile, to make it viewable to other users and recommend other users to you.
• Legitimate interests: We may use your information where we have legitimate interests to do so. For instance, we analyze users’ behavior on our services to continuously improve our offerings, we suggest offers we think might interest you, and we process information for administrative, fraud detection and other legal purposes.
• Consent: From time to time, we may ask for your consent to use your information for certain specific reasons. You may withdraw your consent at any time by contacting us at the address provided at the end of this Privacy Policy.

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6. HOW WE SHARE INFORMATION

Since our goal is to help you make meaningful connections, the main sharing of users’ information is, of course, with other users. We also share some users’ information with service providers and partners who assist us in operating the services, with other Thundersnow companies and, in some cases, legal authorities. Read on for more details about how your information is shared with others.

• With other users: You share information with other users when you voluntarily disclose information on the service (including your public profile). Please be careful with your information and make sure that the content you share is stuff that you’re comfortable being publically viewable since neither you nor we can control what others do with your information once you share it.
• If you choose to limit the audience for all or part of your profile or for certain content or information about you, then it will be visible according to your settings.
• With our service providers and partners: We use third parties to help us operate and improve our services. These third parties assist us with various tasks, including data hosting and maintenance, analytics, customer care, marketing, advertising, payment processing and security operations.
• We may also share information with partners who distribute and assist us in advertising our services and partners who advertise their services with us. For instance, we may share limited information on you in hashed, non-human readable form to advertising partners.
• We follow a strict vetting process prior to engaging any service provider or working with any partner. All of our service providers and partners must agree to strict confidentiality obligations.
• With other Thundersnow businesses: We may share your information with other Thundersnow companies for them to assist us in processing your information, as service providers, upon our instructions and on our behalf. Assistance provided by other Thundersnow companies may include technical processing operations, such as data hosting and maintenance, customer care, marketing and targeted advertising, finance and accounting assistance, better understanding how our service is used and users’ behaviour to improve our service, securing our data and systems and fighting against spam, abuse, fraud, infringement and other wrongdoings.
• We may also share information with other Thundersnow companies for legitimate business purposes such as corporate audit, analysis and consolidated reporting as well as compliance with applicable laws. We may also share user information with other Thundersnow companies to remove users who violate our terms of service, or have been reported for criminal activity and/or bad behavior. In some instances, we may remove that user from all platforms.
• For corporate transactions: We may transfer your information if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control.
• When required by law: We may disclose your information if reasonably necessary: (i) to comply with a legal process, such as a court order, subpoena or search warrant, government / law enforcement investigation or other legal requirements; (ii) to assist in the prevention or detection of crime (subject in each case to applicable law); or (iii) to protect the safety of any person.
• To enforce legal rights: We may also share information: (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary to protect our legal rights and legal rights of our users, business partners or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.
• With your consent or at your request: We may ask for your consent to share your information with third parties. In any such case, we will make it clear why we want to share the information.
• We may use and share non-personal information (meaning information that, by itself, does not identify who you are such as device information, general demographics, general behavioral data, geolocation in de-identified form), as well as personal information in hashed, non-human readable form, under any of the above circumstances. We may also share this information with other Thundersnow companies and third parties (notably advertisers) to develop and deliver targeted advertising on our services and on websites or applications of third parties, and to analyze and report on advertising you see. We may combine this information with additional non-personal information or personal information in hashed, non-human readable form collected from other sources.
• With Other Thundersnow Businesses: We may share your information with other companies within the Thundersnow Ltd. group for legitimate business purposes. This includes:
  • Service provision: For technical processing operations like data hosting and maintenance, customer care, and ensuring the stability and security of our systems.
  • Analysis and improvement: To better understand how our services are used and user behavior, helping us improve our offerings.
  • Marketing and advertising: To assist in marketing efforts and targeted advertising.
  • Fraud prevention and security: To secure our data and systems and fight against spam, abuse, fraud, infringement, and other wrongdoings.
  • Corporate operations: For internal corporate audit, analysis, consolidated reporting, and compliance with applicable laws.

In some instances, we may also share user information with other Thundersnow companies to remove users who violate our terms of service or have been reported for criminal activity and/or bad behavior. This may lead to the removal of that user from all platforms operated by Thundersnow Ltd.

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7. CROSS-BORDER DATA TRANSFERS

Sharing of information laid out in section 6 sometimes involves cross-border data transfers, for instance to the United States of America and other jurisdictions. As an example, where the service allows for users to be located in the European Economic Area (“EEA”), their personal information is transferred to countries outside of the EEA. We use standard contract clauses approved by the European Commission or other suitable safeguard to permit data transfers from the EEA to other countries. Standard contractual clauses are commitments between companies transferring personal data, binding them to protect the privacy and security of your data.

Sharing of information as laid out in Section 6 sometimes involves cross-border data transfers, for instance to the United States of America and other jurisdictions where our servers and service providers are located. For users located in the European Economic Area (“EEA”), their personal information is transferred to countries outside of the EEA.

To ensure your data remains protected when transferred outside the EEA, we implement suitable safeguards. This primarily includes the use of Standard Contractual Clauses (SCCs) approved by the European Commission. These clauses are legally binding agreements between companies that transfer personal data, requiring them to uphold high standards of data protection and security, ensuring your data is treated with the same level of care as it would be within the EEA.