Privacy Policy

VERSION: privacy-v1-2026-09-01

Bailar, Inc., a Delaware corporation (successor by statutory conversion effective May 4, 2026 to Bailar LLC, a Florida limited liability company) (“Bailar,” “we,” “us,” or “our”) operates the Bailar mobile application, the website located at bailar.site, and related services (collectively, the “Service”). This Privacy Policy explains how we collect, use, disclose, store, and protect your personal information when you use the Service.

This Privacy Policy is intended to comply with applicable data protection laws in the jurisdictions in which we offer the Service, including the United States (federal and state), Canada (PIPEDA and Quebec Law 25), the European Union and European Economic Area (GDPR), the United Kingdom (UK GDPR), Brazil (LGPD, Lei No. 13.709/2018), Mexico (LFPDPPP), Colombia (Habeas Data Law 1581), Argentina (PDPA Law 25,326), and Peru (PDPL Law 29,733).

For users in the European Union, European Economic Area, United Kingdom, Switzerland, Canada, and other jurisdictions that require an explicit lawful basis for processing, your continued use of the Service is not deemed to be implied consent for non-essential processing. Where consent is required, we collect it through opt-in mechanisms in the Service. Where we rely on legitimate interests or contractual necessity, we identify those grounds in Section 4 below.

PRIVACY OFFICER

Paul Plawin, Privacy Officer, Bailar, Inc.
Email: privacy@bailar.site
Postal: 9805 Fosbak Dr, Vienna, VA 22182, United States

For users in Quebec, this individual is the person designated under Article 3.1 of An Act respecting the protection of personal information in the private sector (Quebec Law 25). For users in Canada, this is the individual accountable for compliance with the Personal Information Protection and Electronic Documents Act (PIPEDA). EU, EEA, UK, and Swiss users may also contact the Article 27 / FADP representative designated in Section 8.10a, in addition to or instead of our Privacy Officer.

1. INFORMATION WE COLLECT

1.1 Information You Provide

Account Information: Name, email address, phone number, profile photo, date of birth (when you enter one), an optional home or mailing address if you add one to your profile, and other registration information.

Profile Information: Dance experience, preferred styles, bio, location preferences, and additional profile photos.

Address-book contacts: If you grant the contacts permission, two screens — Find Dancers and New Message — read phone numbers and email addresses from your device address book (and contact names, used on-device to label matches) and send those identifiers to our servers to find existing Bailar accounts. We use this only for contact-based discovery. Contact-based discovery is not available on the 13–15 learning experience (Section 9.3a). We do not sell your address book or use it for advertising.

Communications: All messages, images, files, media, and data transmitted through messaging or chat features (“Communications”), including message text, media attachments, timestamps, sender and recipient identifiers, read receipts, delivery status, and associated metadata.

Photos and Media: Photos, images, videos, and other media uploaded through the Service, including through messaging features, along with metadata such as file type, size, upload time, and EXIF data. As required by law to detect and report child sexual abuse material (CSAM), uploaded images and video frames are matched against known-CSAM hash databases by a third-party provider (Microsoft PhotoDNA); a confirmed match is reported to the National Center for Missing & Exploited Children (NCMEC). See our Subprocessors page.

Payment Information: Transaction records, payment amounts, and related metadata. Full credit card numbers and bank account details are processed by third-party payment processors (Apple, Google, Stripe) and are not stored directly by Bailar.

Instructor/Student Information: Booking details, scheduling preferences, session history, reviews, and ratings.

Identity-Verification Data (instructor applicants and payout recipients): If you apply to become an instructor, or if you elect to receive a marketplace payout through the optional USDC payout rail, our third-party identity-verification providers (Persona and/or Stripe Identity) collect an image of your government-issued photo ID and a live-capture selfie, and perform a facial match between them to confirm you are who your ID says you are. This facial-image data may be biometric information or special-category personal data under laws such as the EU/UK GDPR (Article 9) and U.S. state biometric-privacy statutes (for example, Illinois BIPA and Texas CUBI). We collect it only from instructor applicants and from payees who choose the USDC payout rail (which may include non-instructor studio staff who are paid through the marketplace), only to verify identity (and to meet related safety and payout-compliance requirements), and we do not use it for advertising or to train AI models. It is processed by the verification provider; see our Subprocessors page.

Audio/Voice Data: The app accesses the microphone only when you initiate a feature that needs it. That includes: (a) the optional “What’s playing?” song-identification feature, which records a short (about 12-second) clip — on Android and the server path the clip is sent to a third-party music-recognition provider (AudD); on iOS an on-device-derived acoustic signature is sent to Apple’s Shazam catalog; (b) the optional in-app voice assistant (Bia), which streams microphone audio in real time for transcription and a spoken reply, processed ephemerally and not stored as a voice recording; and (c) audio captured as part of a story, reel, or other video you record in the app. These clips and streams are not used for advertising or to train general-purpose foundation models. We do not access your microphone in the background.

Support Communications: Content of messages sent to us for support, feedback, or inquiries.

Survey and Contest Information: Information provided in response to surveys, promotions, or contests.

Consent Records: Where we rely on consent as a lawful basis for processing (for example, marketing email opt-ins under CASL or GDPR), we maintain records of when and how consent was granted, modified, or withdrawn, including the consent type, the country of the data subject at time of consent, the source (signup, settings, drip resubscribe, etc.), and timestamp.

1.2 Information Collected Automatically

Location Data: With your permission, we collect precise or approximate geographic location data from your device to show nearby events and instructors. You may disable location services through device settings, but this may limit functionality.

Location handling for known minors: for users whose account indicates they are a minor (under 18), we automatically coarsen precise GPS coordinates to a less precise, area-level location before using or storing them for discovery. This coarsening applies to all users whose account indicates they are a minor, regardless of location, consistent with the Texas SCOPE Act and children’s-privacy design standards generally.

How location is used: location data is used to rank and display nearby events, studios, and instructors, and is not shared with advertising networks or used for cross-app tracking (see Section 3, “With Advertising Partners”). You can revoke location permission at any time in your device settings; doing so will limit Bailar to showing content based on a manually entered or last-known location, or no location-based content at all.

Device Information: Device type, operating system, version, unique device identifiers (such as installation IDs, push-notification tokens, and similar values used to operate the Service and to maintain your session), browser type, language, time zone, and mobile network information. We do not request access to the iOS Identifier for Advertisers (IDFA), the Android Advertising ID, or any other identifier whose primary purpose is cross-app advertising.

Usage Data: Pages viewed, features used, search queries, events viewed, messaging activity and patterns, click data, scroll data, interaction patterns, session duration, and dates/times of visits.

Log Data: IP address, browser type, referring/exit pages, crash reports, error logs, and system activity.

Login and Device-Recognition Data: When you sign in to your account, we record the login event — including the date and time, a per-installation device identifier, your device model and operating-system version, and the IP address associated with the sign-in — so that we can recognize the devices you use and detect sign-ins from a new or unrecognized device. This is a standard account-security feature applied to all accounts; where a lawful basis is required, we rely on our legitimate interest in protecting account security (see Section 4). We use this login information for account-security purposes, including alerting you by email and push notification when a new device signs in to your account; the same categories of data may also be collected and used for the other purposes described in this Policy (see Sections 1.2 and 2). These records are retained as described in Section 6.6.

Cookies and Similar Technologies: We use cookies, web beacons, pixels, and similar technologies to collect information about your activity on the Service. You may manage cookie preferences through your browser settings or, where required by law (including in the EU/EEA, UK, and Quebec), through our cookie consent interface on the website.

1.3 Information Derived Through Automated Processing

We use automated systems, algorithms, artificial intelligence, machine learning, natural language processing, and computer vision technologies to process and analyze information collected through the Service, including Communications and User Content. Through this processing, we may derive or infer additional information, including user preferences, behavioral patterns, content categorizations, interest profiles, engagement metrics, sentiment indicators, risk scores, and other analytical insights (“Derived Data”). Derived Data is the proprietary property of Bailar, Inc.. For users in jurisdictions providing rights against fully-automated decision-making with legal effects (including Article 22 GDPR and Article 12.1 of Quebec Law 25), Bailar routes unfavorable or uncertain eligibility outcomes to human review. Certain favorable eligibility determinations — in particular, approving an instructor application when automated identity-verification and eligibility checks pass — may be made by solely automated processing; you may request human review of, express your point of view on, and contest any such determination by contacting our Privacy Officer (see Section 5.5).

1.4 Information from Third Parties

We may receive information about events, studios, and instructors from third-party sources, including event listing platforms, mapping providers, and publicly available websites, in order to seed and update the directory. We may also receive information from authentication providers (e.g., Apple Sign In, Google Sign In, Facebook Login, Kakao Sign In), payments processors (e.g., Stripe), and analytics providers about how you reach and use the Service. The data received from any authentication provider is limited to what you authorize at sign-in (typically a stable account identifier, your display name, and, where you have granted permission, your email address). We do not receive personal information about you from advertising networks. The Bailar mobile app integrates no third-party advertising SDK; the bailar.site website uses the consent-gated advertising tags described under “With Advertising Partners” below and in our Cookie Policy.

If you operate a studio listed in our directory and want the listing removed, email dmca@bailar.site or submit the DMCA report form.

2. HOW WE USE YOUR INFORMATION

We use collected information, including Communications and User Content, for the following purposes:

(a) To provide, maintain, operate, and improve the Service;
(b) To create and manage your account and verify your identity;
(c) To display nearby events, instructors, and relevant content based on your location and preferences;
(d) To facilitate messaging, connections, and interactions between users;
(e) To process transactions and payments;
(f) To send transactional communications (booking confirmations, payment receipts, account notifications);
(g) To send promotional communications, where you have opted in or such communications are otherwise permitted under applicable law (you may opt out at any time);
(h) To personalize your experience, including content recommendations and feature customization;
(i) To detect, prevent, and address fraud, spam, abuse, harassment, and security issues through automated and manual review;
(j) To enforce our Terms of Service and community guidelines;
(k) To perform analytics, research, trend analysis, and product research, including through analysis of Communications and User Content in aggregated, anonymized, or de-identified form;
(l) To tune, evaluate, and improve the operational automated systems that deliver the Service — including ranking, search, recommendations, language detection, translation, content moderation, spam and fraud detection, accessibility features, and abuse-pattern analysis. We do not use your personal information, your Communications, or your User Content to train general-purpose foundation models for our own commercial sale or for sale or sublicense to third parties. For live, user-facing message and image moderation inference, we route your content to Google’s Gemini API using a paid or enterprise key when one is configured — those terms do not train the vendor’s foundation models on the inputs we send. When no such key is configured, the lead is a free-tier Google AI Studio pool. In both configurations, Cerebras (a United States-hosted inference provider) is the runtime failover. The free AI Studio pool is the default when a paid key is not set; it is not the runtime failover from a provisioned paid key. The in-app assistant (Bia) uses a dedicated paid Gemini key only while that key is configured and the monthly spend and ledger gate permits paid use. If the cap has been reached, the spend ledger cannot be read, or no paid key is configured, Bia uses the free AI Studio pool. This Bia free-pool route is separate from the general text chain’s Cerebras runtime failover. When the Claude Sonnet bridge is enabled and that same paid-use gate permits the turn, a typed Bia conversation may instead be processed by Anthropic. The bridge sends the current message, up to nine prior Bia conversation messages, and profile/location personalization context such as locale, dialect, date, and city. Bailar keeps the caller’s authentication token within its bridge and uses it only for user-scoped tools such as plans and bookmarks; the token is not included in the Claude prompt. When those tools run, Anthropic may also receive the user’s RSVP status and saved-event or saved-studio results, including names, dates, venues, and cities. The current bridge uses Claude Max subscription accounts governed by Anthropic’s Consumer Terms, not Anthropic’s Commercial Terms or Data Processing Addendum. The Consumer Terms permit Anthropic to use submitted materials to improve its services and train models unless the account has opted out of training; feedback and safety-reviewed materials are not covered by that opt-out. Materials allowed for model improvement may be retained by Anthropic in de-identified form for up to five years. Anthropic states that deleted consumer conversations are removed from back-end storage within 30 days, subject to safety, legal, and policy-enforcement exceptions. Turns corroborated as voice do not use the Sonnet bridge. If a successful ledger check finds no recent transcription row, the claimed voice turn is handled as typed and may use the bridge; if the ledger check itself fails, the turn remains voice and does not use the bridge. Some free-tier standard terms permit the vendor to use inputs to improve its services (see our Subprocessors page for how each vendor is used);
(m) To produce aggregated, anonymized, or de-identified statistics and reports for internal product, operational, financial, and security purposes — for example, the Service’s aggregate active-user count, city-level event density, or the share of users in a given dance-style cohort. We do not sell, license, or otherwise commercialize identifiable personal information, and any aggregated or de-identified data shared externally is restricted by contract from being re-identified;
(n) To develop new products, services, features, and functionality of the Service;
(o) To comply with legal obligations and respond to legal process;
(p) To protect the rights, property, or safety of Bailar, its users, or third parties; and
(q) For any other purpose disclosed to you at the time of collection or with your consent.

3. HOW WE SHARE YOUR INFORMATION

We do not sell your personal information that identifies you individually. We may share your information as follows:

With Other Users: Profile information (name, photo, bio, dance preferences) is visible to other users. Messages are visible to recipients.

With Instructors or Students: Relevant contact and booking information is shared between parties for facilitated transactions.

With Subprocessors and Service Providers: We share information with third parties who process information on our behalf under contractual confidentiality and security obligations. The current list of subprocessors that handle personal information is published at bailar.site/legal/subprocessors. We update this list when we add or remove subprocessors. Subprocessors are bound to use information only for the purposes for which we engage them and are subject to data processing agreements aligned with applicable laws (including GDPR Article 28, Quebec Law 25 Article 18.3, and PIPEDA Principle 4.1.3). The current Anthropic Claude Max bridge is the disclosed exception: Anthropic receives bridge data under its Consumer Terms and own data-use rights, rather than as a DPA-bound subprocessor.

With Advertising Partners: The Bailar mobile app does not serve advertising and integrates no advertising SDK. On the bailar.site website, and only after you accept marketing/advertising cookies through the site’s cookie controls (and never when your browser sends a Global Privacy Control signal), Bailar loads a Pinterest conversion/audience tag and, where configured, the Google AdSense loader, as described in our Cookie Policy and Subprocessors page. These receive limited data (such as IP address and cookie identifiers) to measure ad conversions and, for AdSense, to deliver ads on the website. Bailar does not “sell” your personal information for money. Bailar also maintains an optional “No Ads” consumer subscription (described in our Terms of Service). If we introduce any in-app advertising or other advertising partners, we will update this Privacy Policy in advance, identify the partner and the data shared, and provide any consent prompts required by applicable law (including, on iOS, the App Tracking Transparency prompt before any cross-app tracking).

Aggregated and De-Identified Data: We may use aggregated, anonymized, or de-identified data derived from the Service for internal product, research, security, financial, and reporting purposes, and we may share such data with our advisors, prospective and current investors, and statistical or academic researchers, provided the data does not identify you and is restricted by contract or technical safeguard from being re-identified. We do not sell or license aggregated or de-identified data derived from Communications or private User Content as a standalone commercial product.

For Legal Reasons: We may disclose your information, including Communications content, if required by law, regulation, legal process, or governmental request, or to protect the rights, property, or safety of Bailar, its users, or the public.

For Safety and Enforcement: We may access and disclose Communications to investigate Terms violations, respond to user reports, address fraud or security issues, or protect the safety of any person.

CSAM Reporting: We will disclose information to NCMEC and law enforcement as required when child sexual abuse material is detected.

Business Transfers: In the event of a merger, acquisition, reorganization, bankruptcy, or sale of assets, your information, including Communications and Derived Data, may be transferred as part of that transaction. We will notify users in advance where required by applicable law.

With Your Consent: We may share your information for other purposes with your express consent.

GOVERNMENT AND LAW ENFORCEMENT REQUESTS

No voluntary disclosure. Bailar does not voluntarily provide user data — including location data — to any government agency, domestic or foreign. We disclose user information to a public authority only when compelled by valid legal process (such as a warrant, court order, or subpoena) that identifies a specific user and the data sought, and even then only as set out below. We do not grant any government bulk, direct, or standing access to our systems or user data, and we do not participate in voluntary data-sharing programs that would expose user data absent lawful process.

Legality review. When Bailar receives a request from a public authority — including domestic and foreign law enforcement, regulators, intelligence agencies, courts, and other governmental bodies — for personal information about a user, we review the request to confirm that it is lawful, properly issued, and within the requesting authority’s jurisdiction before disclosing any information. Requests that lack a valid legal basis or that are facially defective are rejected.

Challenging unlawful requests. Where Bailar reasonably believes a request is unlawful, overbroad, or contrary to applicable law, we will challenge it through the appropriate judicial or administrative channels — including, where appropriate, by filing a motion to quash, by seeking judicial review, or by declining to comply pending lawful order. We may consult outside counsel for any request whose validity is unclear.

Data minimization. When we are required to disclose personal information in response to a lawful request, we disclose only the minimum information necessary to comply. We narrow the scope of any disclosure where possible — for example, by producing only the specific records, accounts, or time periods expressly required, rather than all records associated with a user.

Documentation. Bailar maintains an internal record of each request from a public authority, including the requesting authority, the legal instrument relied upon, the data categories disclosed (or withheld), the legal reasoning underlying our response, and the personnel involved. These records are retained to support potential transparency reporting, internal compliance reviews, and any subsequent legal challenges. Bailar publishes a Transparency Report summarizing the number of requests received and what was disclosed, and maintains a Warrant Canary.

User notice. Where not legally prohibited (for example, by a non-disclosure order, gag order, or sealing requirement), we will notify affected users of requests for their personal information so that the user may seek appropriate legal remedies. Notice may be delayed where doing so is reasonably necessary to avoid prejudicing an ongoing investigation, endangering safety, or violating a court order.

Inquiries from public authorities should be directed to legal@bailar.site. Service of legal process must comply with applicable rules and may also be directed to the registered agent of Bailar, Inc. in Delaware.

4. LAWFUL BASES FOR PROCESSING (EU/EEA, UK, AND OTHER REGIMES)

For users in jurisdictions requiring identification of a lawful basis (including Article 6 GDPR and Article 6 UK GDPR), we rely on the following bases for the processing activities described in Section 2:

Processing Activity	Lawful Basis
Account creation and identity verification (purposes a, b)	Contractual necessity (Art 6(1)(b))
Biometric identity verification for instructor applicants and USDC-payout recipients (government-ID + selfie facial match)	Explicit consent for special-category data (Art 9(2)(a)), obtained at the point of the verification flow, in addition to the Art 6(1)(b)/(f) basis; where you are in a U.S. state with a biometric-privacy statute (e.g., Illinois BIPA, Texas CUBI), collection is on notice-and-consent as those statutes require
Discovery, recommendations, and event display (purposes c, h)	Contractual necessity for core functionality; legitimate interests for personalization
Messaging and connections (purpose d)	Contractual necessity
Transactions and payment processing (purposes e, f)	Contractual necessity; legal obligation (tax/anti-fraud)
Marketing communications (purpose g)	Consent (Art 6(1)(a)). Required by GDPR, CASL, and Quebec Law 25 prior to first commercial message
Fraud prevention and Terms enforcement (purposes i, j)	Legitimate interests (Art 6(1)(f)); legal obligation
Analytics, research, and product development (purposes k, l, m, n)	Legitimate interests, balanced against your interests; consent for non-essential cookies
Legal compliance and safety (purposes o, p)	Legal obligation; legitimate interests; vital interests

You may object to processing based on legitimate interests by contacting our Privacy Officer.

5. AUTOMATED PROCESSING AND ARTIFICIAL INTELLIGENCE

5.1 Bailar uses automated processing technologies, including artificial intelligence, machine learning, natural language processing, and computer vision, to analyze information collected through the Service. These technologies are applied to Communications, User Content, and all other collected data.

5.2 Automated Processing is used for content moderation, safety enforcement, spam and fraud detection, CSAM detection and NCMEC reporting, personalization, accessibility, language detection, translation, search and ranking, internal analytics and research, and service operation and improvement. Automated Processing is not used to serve targeted third-party advertising.

5.3 Automated Processing of Communications and User Content is performed by technical systems and does not ordinarily involve direct human review of individual messages. Authorized Bailar personnel may access Communications in the limited circumstances described in our Terms of Service, including to investigate reports, comply with legal obligations, maintain platform integrity, and evaluate the quality of operational moderation systems — not to train third-party general-purpose AI models on your content.

5.4 Bailar relies on third-party inference vendors (identified on our Subprocessors page) to run AI models we call at the moment of use. For live, user-facing message and image moderation paths we route your content to Google’s Gemini API using a paid or enterprise key when one is configured (those terms do not train the vendor’s foundation models on the inputs we send). When no such key is configured, the lead is a free-tier Google AI Studio pool. In both configurations, Cerebras is the runtime failover. The free AI Studio pool is the default when a paid key is not set; it is not the runtime failover from a provisioned paid key. The in-app assistant (Bia) uses a dedicated paid Gemini key only while that key is configured and the monthly spend and ledger gate permits paid use. If the cap has been reached, the spend ledger cannot be read, or no paid key is configured, Bia uses the free AI Studio pool, whose standard terms may permit the vendor to use inputs to improve its services. This Bia free-pool route is separate from the general text chain’s Cerebras runtime failover. When the Claude Sonnet bridge is enabled and that same paid-use gate permits the turn, a typed Bia conversation may instead be processed by Anthropic. The bridge sends the current message, up to nine prior Bia conversation messages, and profile/location personalization context such as locale, dialect, date, and city. Bailar keeps the caller’s authentication token within its bridge and uses it only for user-scoped tools such as plans and bookmarks; the token is not included in the Claude prompt. When those tools run, Anthropic may also receive the user’s RSVP status and saved-event or saved-studio results, including names, dates, venues, and cities. The current bridge uses Claude Max subscription accounts governed by Anthropic’s Consumer Terms, not Anthropic’s Commercial Terms or Data Processing Addendum. The Consumer Terms permit Anthropic to use submitted materials to improve its services and train models unless the account has opted out of training; feedback and safety-reviewed materials are not covered by that opt-out. Materials allowed for model improvement may be retained by Anthropic in de-identified form for up to five years. Anthropic states that deleted consumer conversations are removed from back-end storage within 30 days, subject to safety, legal, and policy-enforcement exceptions. Turns corroborated as voice do not use the Sonnet bridge. If a successful ledger check finds no recent transcription row, the claimed voice turn is handled as typed and may use the bridge; if the ledger check itself fails, the turn remains voice and does not use the bridge. Back-office batch classification of public or host-submitted content uses a free-tier chain whose no-training position rests on each vendor’s standard terms. We route AI traffic only to vendors operating under United States, European Union, United Kingdom, or Canadian data-protection law. The Derived Data, configurations, prompts, and operational models we build internally on top of those vendors’ capabilities are the proprietary property of Bailar, Inc. and may be used for the operational purposes described in this Privacy Policy and Section 2 of our Terms of Service, but are not sold or licensed as a standalone commercial dataset product.

5.5 Most decisions producing legal or similarly significant effects are not made solely by automated processing without human review, and any unfavorable or uncertain outcome — for example, a declined or flagged instructor application — is routed to human review. One favorable determination may be made by solely automated processing: an instructor application may be automatically approved when automated identity verification and eligibility checks pass. Where you have a right under Article 22 GDPR or Article 12.1 of Quebec Law 25 in relation to a solely-automated decision, you may obtain human intervention, express your point of view, and contest the decision by contacting our Privacy Officer.

6. DATA RETENTION

6.1 We retain your personal information, including Communications, for as long as your account is active or as needed to provide the Service and fulfill the purposes described in this Privacy Policy.

6.2 We may retain certain information, including Communications and Derived Data, as necessary to comply with legal obligations, resolve disputes, enforce agreements, prevent fraud, and support legitimate business interests including analytics, research, and product development.

6.3 When you request permanent deletion of your account, your profile and content are hidden immediately and your account remains deactivated for a 30-day grace window, during which you can cancel the deletion by signing back in. Your account and personal-data records are permanently deleted or anonymized within one day after that window ends, except where retention is required or permitted by law, where data has been anonymized or aggregated such that it no longer identifies you, or as described in Section 6.2 and on our Data Deletion page (for example legal, tax, safety, identity-verification, and disaster-recovery backups). Any residual copies of your stored media are erased promptly afterward as our storage purge completes. A small number of referential records may remain until remaining deletion-pipeline work is completed; we do not represent that every associated row is erased on the day you confirm deletion. An in-app portable export is available; it covers core account data and is not a complete dump of every record we store.

6.4 Anonymized and aggregated data derived from your information, including from Communications, may be retained indefinitely.

6.5 Deleted Communications and other personal information may persist in encrypted disaster-recovery backups for up to ninety (90) days after deletion, after which they are rotated out, and in aggregated or de-identified form indefinitely. We do not maintain “trained models” built from your personal information as a separate retention bucket; operational models that have been tuned on internal data are subject to the same deletion and re-training cycle as the underlying source data. For users in Quebec exercising the right to data destruction under Article 28.1 of Law 25, we will document and explain any retention beyond your deletion request.

6.6 Login and device-recognition records used to detect new-device sign-ins and to send account-security alerts are retained for ninety (90) days from the login event, after which they are automatically deleted. This ninety-day period is separate from, and not to be confused with, the disaster-recovery backup window described in Section 6.5.

6.7 Biometric / identity-verification data. The government-ID image and live-selfie facial-match data collected for identity verification (described in Section 1.1) are retained for no longer than three (3) years from the date the verification is approved, after which they are destroyed by an automated purge. A genuinely new verification starts a new retention period; re-approval of the same verification does not extend it. This is Bailar’s published biometric retention schedule for purposes of the Illinois Biometric Information Privacy Act (740 ILCS 14/15(a)) and the Texas Capture or Use of Biometric Identifier Act.

7. DATA SECURITY

7.1 We implement reasonable technical and organizational measures to protect your personal information, including encryption of data in transit, access controls, security monitoring, and regular security assessments.

7.2 No method of transmission or storage is 100% secure. We cannot guarantee absolute security.

7.3 Communications transmitted through the Service are not end-to-end encrypted. You transmit Communications at your own risk.

7.4 Do not use the Service to transmit sensitive information such as Social Security numbers, financial account numbers, passwords, or medical information.

7.5 Breach notification: We will notify personal-data breaches as required by applicable law. Under the GDPR, we will notify the relevant supervisory authority without undue delay and, where feasible, within 72 hours (Article 33), and will notify affected users without undue delay where the breach is likely to result in a high risk to their rights and freedoms (Article 34). We will also notify as soon as possible under PIPEDA section 10.1 and Quebec Law 25 Article 3.5, and as required under applicable U.S. state breach-notification statutes.

8. YOUR RIGHTS AND CHOICES

8.1 Account Information

You may update or correct account information through the App. You may delete your account at any time in the App (Settings → Accounts Center → Account Management → Delete Account) or on the web (Account → Security & account), or by contacting privacy@bailar.site. You may also download a copy of your data from either surface before deleting. What is removed, what may be retained, and the 30-day processing window are described in Section 6.3 and on our Data Deletion page.

8.2 Location Data

Control location data through your device’s operating system settings.

8.3 Marketing Communications

Email: Where required by applicable law (including for users in Canada under CASL, in the EU/EEA and UK under GDPR / PECR, and in jurisdictions with similar regimes), marketing email is sent only with prior express consent. You may withdraw consent at any time via the unsubscribe link included in every marketing message, by adjusting in-app settings, or by contacting our Privacy Officer. You will continue to receive transactional emails (booking confirmations, password resets, account notifications) as long as you have an active account.

Push notifications: Opt out through your device’s notification settings, or through the in-app notification preferences screen.

SMS / text messages: Bailar sends two categories of text messages, each with its own consent rules.

• Transactional SMS (one-time verification codes, two-factor authentication codes, account recovery codes, password reset codes, and other security-related messages) are sent only when you actively request them — for example, by tapping “send code” during sign-in. These messages are part of the Service and are not considered marketing communications.
• Marketing SMS (promotional offers, event recommendations, announcements, and other non-transactional messages) is opt-in only. We will not send you marketing texts unless you have explicitly consented by checking the “Yes, send me text message updates from Bailar” box during sign-up or in your account settings. By opting in, you consent to receive recurring automated promotional text messages at the phone number you provided. Consent is not a condition of purchase or account creation. Message and data rates may apply. Message frequency varies.
• To stop marketing SMS: reply STOP to any marketing text message at any time, or disable the SMS marketing toggle in your account settings. Replying HELP to any Bailar text message will return contact information. Opting out of marketing SMS does not affect transactional SMS.

SMS communications are subject to the U.S. Telephone Consumer Protection Act (TCPA), the FCC’s rules on autodialed messages, Canada’s Anti-Spam Legislation (CASL), the GDPR / ePrivacy Directive in the EU/EEA, and equivalent regulations in other jurisdictions. Bailar does not share your phone number with unaffiliated third parties for marketing purposes.

8.4 Automated Processing

Certain automated processing is integral to the Service and cannot be opted out of while maintaining an active account. To stop processing, discontinue use and delete your account. For automated decisions producing legal or similarly significant effects, see Section 5.5.

8.5 California Residents (CCPA / CPRA)

You have the right to: (a) know what personal information we collect; (b) request access and a portable copy; (c) request deletion; (d) request correction; (e) opt out of the sale or sharing of personal information for cross-context behavioral advertising (we do not sell information that identifies you individually; where you have consented to marketing cookies on our website, the Pinterest tag described in Section 3 may involve “sharing” for cross-context behavioral advertising, which a Global Privacy Control signal or a marketing-cookie opt-out prevents); (f) limit our use of sensitive personal information — the sensitive categories we may collect include precise geolocation and, for instructor applicants and USDC-payout recipients, the biometric facial-match data described in Section 1.1, which we use only to verify identity and not for inferring characteristics about you; and (g) not be discriminated against for exercising these rights. Contact privacy@bailar.site. We will verify your identity before responding to a verifiable consumer request.

8.6 Florida Residents (FDBR)

Under the Florida Digital Bill of Rights, you may have rights to access, correct, and delete personal information, opt out of targeted advertising, and obtain a portable copy of your information. Contact privacy@bailar.site.

8.7 Other U.S. State Residents

Residents of states with comprehensive privacy laws (including Colorado, Connecticut, Delaware, Iowa, Indiana, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia) may have rights similar to those described above. Contact privacy@bailar.site.

8.8 Canada (PIPEDA)

If you are a resident of Canada, you have the right under PIPEDA to: (a) be informed of the existence, use, and disclosure of your personal information; (b) request access to your personal information; (c) request correction of inaccurate or incomplete information; (d) withdraw consent for processing (subject to legal or contractual restrictions); and (e) make a complaint to our Privacy Officer regarding compliance with PIPEDA. If unresolved, you may complain to the Office of the Privacy Commissioner of Canada at priv.gc.ca.

8.9 Quebec Residents (Loi 25)

If you are a resident of Quebec, you have the rights described in 8.8 above plus additional rights under An Act respecting the protection of personal information in the private sector (Quebec Law 25), including:

(a) the right to be informed of the categories of personal information collected, the purposes, the categories of recipients, and where applicable the names of subprocessors and the location of processing;
(b) the right to data portability — the right to receive your personal information in a structured, commonly-used technological format, and the right to have it transmitted to another party of your choice (Article 27);
(c) the right to object to certain processing and the right to data erasure (“destruction”) where information is no longer necessary for the purposes for which it was collected (Article 28.1);
(d) the right to obtain human intervention regarding decisions based exclusively on automated processing that produce legal or similarly significant effects (Article 12.1);
(e) the right to information about cross-border transfers of personal information, including the existence of safeguards, before such transfers occur. Bailar transfers Quebec residents’ personal information outside Quebec to the United States and other jurisdictions for hosting (Supabase, Vercel), error monitoring (Sentry), email delivery (Resend), and other purposes. We have assessed the privacy protection afforded in those jurisdictions in light of the criteria set out in Article 17 of Law 25 and rely on contractual safeguards (data processing agreements) with each subprocessor except the current Anthropic Claude Max bridge. Anthropic receives bridge data under its Consumer Terms and own data-use rights disclosed in Sections 2(l) and 5.4 and on the Subprocessors page, rather than under a DPA; and
(f) the right to lodge a complaint with the Commission d’accès à l’information du Québec (CAI) at cai.gouv.qc.ca.

Quebec residents may exercise any of these rights by contacting our Privacy Officer at privacy@bailar.site. We will respond within 30 days of receiving a verified request, with a possible 30-day extension for complex requests.

8.10 European Union and European Economic Area (GDPR)

If you are a resident of the EU or EEA, you have the rights set out in Articles 13–22 of the General Data Protection Regulation (Regulation (EU) 2016/679):

(a) the right to be informed of the processing of your personal data (Articles 13–14);
(b) the right of access (Article 15) and to receive a portable copy in a structured, commonly used, machine-readable format (Article 20);
(c) the right to rectification of inaccurate or incomplete data (Article 16);
(d) the right to erasure (“right to be forgotten”) where applicable (Article 17);
(e) the right to restrict processing (Article 18);
(f) the right to object to processing based on legitimate interests, including for direct marketing (Article 21);
(g) the right not to be subject to a decision based solely on automated processing producing legal or similarly significant effects (Article 22); and
(h) the right to withdraw consent at any time, where processing is based on consent (Article 7(3)).

You may exercise the rights of access, portability (data export), and erasure (account deletion) directly in the App (Settings → Accounts Center) or on the web (Account → Security & account), or exercise any of these rights by contacting privacy@bailar.site. We will respond within one month, extendable by two further months for complex or numerous requests. You also have the right to lodge a complaint with your local supervisory authority. The list of EU supervisory authorities is available at edpb.europa.eu.

8.10a EU, UK, and Swiss Representative (Article 27 GDPR / UK GDPR; FADP)

Pursuant to Article 27 of the GDPR, Article 27 of the UK GDPR, and Article 14 of the Swiss FADP, Bailar, Inc. has designated Data Protection Representative Limited (trading as DataRep), an Irish company (no. 616588), as its representative in the European Union / European Economic Area, the United Kingdom, and Switzerland. Data subjects may contact DataRep on issues related to processing of their personal data, in addition to or instead of our Privacy Officer:

Data Protection Representative Limited (DataRep)
77 Camden Street Lower
Dublin D02 XE80
Ireland

United Kingdom office: 85 Great Portland Street, London W1W 7LT.

Submit a request through DataRep’s published request channel at datarep.com/data-request, quoting “Bailar, Inc.” You may also continue to contact our Privacy Officer at privacy@bailar.site.

8.11 United Kingdom (UK GDPR)

UK residents have the rights described in 8.10 above under the UK General Data Protection Regulation and the Data Protection Act 2018. Complaints may be addressed to the Information Commissioner’s Office (ICO) at ico.org.uk.

8.12 Mexico (LFPDPPP)

If you are a resident of Mexico, you have ARCO rights under the Ley Federal de Protección de Datos Personales en Posesión de los Particulares (the new LFPDPPP published in the Diario Oficial de la Federación on 20 March 2025, in force 21 March 2025, which abrogated the 2010 statute): Acceso (Access), Rectificación (Rectification), Cancelación (Cancellation), and Oposición (Objection), plus the right to revoke consent. To exercise these rights, contact privacy@bailar.site. Complaints about private-sector processing may be addressed to the Secretaría Anticorrupción y Buen Gobierno (SABG) at gob.mx/buengobierno. INAI was dissolved in December 2024 and is no longer the competent authority for private-sector data-protection complaints.

8.13 Other Latin American Jurisdictions

Colombia (Habeas Data Law 1581 of 2012): rights to know, update, rectify, and request proof of consent; complaints may be addressed to the Superintendencia de Industria y Comercio at sic.gov.co.

Argentina (Personal Data Protection Law 25,326): rights of access, rectification, update, and suppression; complaints may be addressed to the Agencia de Acceso a la Información Pública at argentina.gob.ar/aaip.

Peru (Personal Data Protection Law 29,733): rights of access, rectification, cancellation, and opposition; complaints may be addressed to the Autoridad Nacional de Protección de Datos Personales at gob.pe/anpd.

Residents of these jurisdictions may exercise rights by contacting our Privacy Officer at privacy@bailar.site.

8.13a Brazil (LGPD)

If you are located in Brazil, the Lei Geral de Proteção de Dados Pessoais (LGPD, Lei No. 13.709/2018) applies to our processing of your personal data, regardless of where Bailar is established, because you are located in Brazil at the time of collection or use of the Service.

Legal bases (Art. 7). We process your personal data on the bases of: performance of a contract to which you are a party (account creation, bookings, payments); legitimate interests, where not overridden by your fundamental rights (fraud prevention, service improvement, security); consent, where required (marketing communications); and compliance with a legal obligation.

Your rights (Art. 18). You have the right to: confirm the existence of processing; access your data; correct incomplete, inaccurate, or outdated data; anonymization, blocking, or deletion of unnecessary or excessive data, or data processed in noncompliance with the LGPD; data portability; deletion of personal data processed with your consent; information about public and private entities with which we have shared data; information about the possibility of not providing consent and the consequences; and revocation of consent.

Data Protection Officer / Encarregado. Bailar’s designated Encarregado de Dados (DPO) for LGPD purposes is Paul Plawin, reachable at privacy@bailar.site — the same contact as our Privacy Officer.

Supervisory authority. You may lodge a complaint with the Autoridade Nacional de Proteção de Dados (ANPD) at gov.br/anpd.

You may exercise any of these rights by contacting our Privacy Officer / Encarregado at privacy@bailar.site. We will respond within a reasonable time consistent with LGPD requirements.

9. CHILDREN’S PRIVACY AND TEEN PROTECTIONS

9.1 Minimum age (per-country). The Service is intended for individuals 13 years of age or older everywhere, and older where the law of your country sets a higher minimum. Bailar maintains a per-country minimum-age table derived from each country’s digital age of consent and statutory social-media minimums — for example 16 in Germany, the Netherlands, Ireland, and Australia, 15 in France and Türkiye, and 14 in Italy and Spain. In a small number of countries whose law requires verified parental consent for minors to use a service like Bailar (for example Colombia, Mexico, the Philippines, South Africa, Israel, Thailand, and India), the Service is currently not available to anyone under 18 (under 20 in Thailand) because Bailar does not yet operate a verified parental-consent program there. We do not knowingly collect personal information from anyone under 13 anywhere, or from anyone under their local minimum age. If we become aware that we have collected information from a person under 13, we will take steps to delete it promptly and report any child sexual abuse material (“CSAM”) as required by law.

9.2 Age verification. Before a new user can access the Service — on the Bailar mobile app and on bailar.site — they must pass an age gate. The consumer path is year-first: every user enters a birth year. If that year proves they are 18 or older, we store it as a synthetic date of birth using July 1 of that year (YYYY-07-01) so the birth year remains available for age-group personalization, and do not require a month or day. If the year could mean they are under 18, we ask for the exact birthday so the per-country minimum and the 13–17 protections resolve precisely. Instructor and studio applicants provide a full legal date of birth. Where available, we also accept an age-range or parental-consent signal supplied by the device app store (Apple Declared Age Range / Google Play Age Signals). That signal sets the compliance age band but does not replace the birth-year step; unless an actual date of birth is already on file, every user still enters a birth year. We do not require every user to enter a birth month and day. Existing users with no birth year on file are prompted on a later visit. Accounts that resolve to an age below 13, or below the higher minimum age that applies in the user’s country under the per-country table described in Section 9.1, are not created (or, for existing under-13 accounts, are signed out and queued for deletion). An existing account that resolves below its local minimum age is placed in a restricted state — the app presents a hold notice and bookings, payments, and social features are refused server-side — until the user reaches the local minimum. We store only the minimum information necessary to enforce this gate and to apply age-appropriate protections.

9.3 Special protections for minors 13–17. When a user is identified as 13–17, Bailar applies age-appropriate defaults: private account (visible only to approved followers); non-discoverable in “Find Dancers” lists; messaging restricted to followers (16–17); sensitive-content level clamped to “Less”; and exclusion from the popular-dancers and people-you-may-know surfaces visible to adults. Adults (18+) cannot direct-message a minor unless the minor follows them. These defaults are enforced server-side and cannot be loosened by the user below the age-appropriate floor.

9.3a The 13–15 learning experience. Users aged 13–15 receive a learning-focused version of the Service: the rhythm game, the dance library, academy lessons, and studio and class discovery are available; social events, direct messaging and group chats, posting to the feed and stories, contact-based discovery, and self-directed payments are not. For these users we additionally do not collect a street address, do not use their data for behavioral profiling or personalized advertising of any kind, limit push notifications to educational and booking-related categories, and keep their profile entirely non-discoverable. These restrictions are enforced server-side.

9.4 Family Center. Minor users (13–17) may invite a trusted adult to act as a guardian through Bailar’s Family Center. A guardian can view the minor’s account activity (RSVP counts, follow lists, post counts, recent reports against their content), set daily time limits, configure a bedtime window during which notifications are muted, and lock the minor’s sensitive-content setting. Guardian access is consensual on both sides — the minor invites by email and the guardian must accept. Before a guardian accepts, either party may cancel the pending invitation. After a guardian link has been accepted, only the guardian may revoke it; a linked minor cannot unilaterally remove an accepted guardian (so a minor cannot quietly return to unsupervised use). For users aged 13–15, a linked guardian is required to book: every private-lesson or class booking made by a 13–15 user is held until a linked guardian reviews it, confirms that a parent, guardian, or another trusted adult will accompany the minor, approves it, and pays for it from the guardian’s own account. Receipts and any refunds go to the guardian’s payment method. Unapproved requests expire automatically after 72 hours; approved-but-unpaid requests expire after 7 days. The same windows apply to a class and a lesson. Either party can cancel a pending request at any time.

9.5 European Union – GDPR-K (Article 8). Bailar’s minimum age in each EU/EEA member state (and the United Kingdom) equals or exceeds that state’s digital age of consent under Article 8 GDPR (16 in Germany, Ireland, and the Netherlands; 15 in France; 14 in Italy and Spain; 13 in the United Kingdom, Denmark, and Sweden; and so on per the table described in Section 9.1) — so Bailar does not rely on parental consent under Article 8 to process EU/EEA users’ personal data: every EU/EEA user admitted to the Service is at or above their state’s Article 8 age and consents for themselves. Users aged 13–15 admitted in lower-age states receive the learning-focused experience described in Section 9.3a with guardian-mediated booking per Section 9.4. Bailar’s Family Center remains a consensual supervision arrangement: we do not independently verify that an invited adult is the minor’s parent or legal guardian before granting them guardian-level visibility and controls.

9.6 United States – COPPA. Bailar does not knowingly collect, use, or disclose personal information from children under 13 in violation of the Children’s Online Privacy Protection Act (15 U.S.C. §§ 6501–6506) or its implementing regulations (16 C.F.R. Part 312). Our age gate is designed to prevent such collection at the source. If we learn we have collected information from a child under 13 without verifiable parental consent, we will delete that information immediately and disable the account. For users whose web signup resolves to Florida, Bailar currently applies a minimum age of 16 as a conservative posture under Florida HB 3 while its applicability to Bailar’s learning-focused minor experience is under legal review.

9.7 Texas – SCOPE Act (HB 18) and TDPSA. For users in Texas, Bailar complies with the Securing Children Online through Parental Empowerment Act (HB 18) and treats the personal data of known minors as sensitive data under the Texas Data Privacy and Security Act. For known minors (under 18): we do not engage in targeted advertising; we do not sell or share their personal identifying information; we coarsen their precise geolocation to an area-level location before using or storing it for discovery (as described in Section 1.2), rather than retaining precise coordinates; and we restrict the financial transactions they may make through the Service (for example, event tickets and merchandise) absent verifiable parental consent. Where the user’s device app store (Apple or Google) supplies an age category or parental-consent signal, Bailar relies on that store-provided signal. We retain a minor’s personal data and any store-provided age or consent signal only as long as necessary to provide the Service and meet our legal obligations, and we maintain a documented data-protection assessment of this processing.

9.8 Reporting concerns. If you believe Bailar has collected information from a child under 13, or if you are a parent or guardian who wishes to review, amend, or request deletion of information about a minor in your care, contact privacy@bailar.site. We respond to verifiable requests within 30 days (or sooner where required by law).

10. THIRD-PARTY LINKS AND SERVICES

The Service may contain links to third-party websites, applications, or services. We are not responsible for the privacy practices of these third parties. Review their privacy policies.

11. INTERNATIONAL DATA TRANSFERS

11.1 Bailar is established in the United States. Your personal information is stored, processed, and accessed in the United States and other countries where our subprocessors and other recipients operate (see bailar.site/legal/subprocessors for the current list and locations).

11.2 Transfers from the EU/EEA, UK, and Switzerland: where personal data is transferred from the EU/EEA, the UK, or Switzerland to a country that has not received an adequacy decision, we rely on Standard Contractual Clauses (SCCs) approved by the European Commission, the UK International Data Transfer Addendum, or the Swiss-equivalent SCCs, as applicable, and on supplementary measures including encryption in transit and access controls. Copies of the relevant clauses are available on request from our Privacy Officer. These clause-based safeguards do not apply to the current Anthropic Claude Max bridge, which is governed instead by the Consumer Terms and data-use posture disclosed in Sections 2(l) and 5.4 and on the Subprocessors page.

11.3 Transfers from Canada and Quebec: we have assessed the data protection regimes of jurisdictions to which we transfer personal information using the criteria in PIPEDA Principle 4.1.3 and Article 17 of Quebec Law 25. We rely on contractual safeguards in data processing agreements with each subprocessor and on technical safeguards including encryption. Those DPA-based safeguards do not apply to the current Anthropic Claude Max bridge, whose Consumer Terms and data-use posture are disclosed in Sections 2(l) and 5.4 and on the Subprocessors page.

11.4 Transfers from Mexico (LFPDPPP): cross-border transfers are conducted with the recipient’s commitment to comply with the same obligations as Bailar with respect to the personal data transferred. That commitment does not apply to the current Anthropic Claude Max bridge, whose Consumer Terms and data-use posture are disclosed in Sections 2(l) and 5.4 and on the Subprocessors page.

11.5 Transfers from Brazil (LGPD): where personal data is transferred from Brazil to a country without an ANPD adequacy determination, we rely on standard contractual clauses and other safeguards recognized under LGPD Art. 33, and on the same subprocessor data processing agreements described elsewhere in this Policy. Those DPA-based safeguards do not apply to the current Anthropic Claude Max bridge, whose Consumer Terms and data-use posture are disclosed in Sections 2(l) and 5.4 and on the Subprocessors page.

12. DO NOT TRACK SIGNALS

The Service does not currently respond to “Do Not Track” signals from your browser. We do, however, respect Global Privacy Control (GPC) signals where required by applicable U.S. state law.

13. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. Material changes will be notified through the App or by other means. Where required by applicable law (including under Quebec Law 25 Article 8 and GDPR Article 13), we will provide advance notice of material changes that affect your rights. Continued use after changes take effect constitutes acceptance, except in jurisdictions where renewed consent is required.

14. CONTACT US

For privacy inquiries, data subject requests, or to contact our Privacy Officer:

Paul Plawin, Privacy Officer
Bailar, Inc.
9805 Fosbak Dr
Vienna, VA 22182
United States
Email: privacy@bailar.site

For general legal correspondence: legal@bailar.site.