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The policy discloses that Grindr collects precise geolocation data (subject to device permissions) to calculate and display distance information between users, and explicitly warns that displayed Distance Information could be used by other users to determine a user's exact location and identity.
This analysis describes what Grindr's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
This provision establishes that precise geolocation is collected and that Distance Information shared in profiles may enable third-party trilateration or inference of a user's exact location and identity; the policy discloses this risk directly and states that hiding Distance Information still results in profile sorting based on relative distance.
Under these terms, Grindr collects precise geolocation data and displays distance-based information that the policy itself acknowledges could be used by other users to determine a user's exact location and identity; users may hide Distance Information from their profile but the Services will continue to use relative location data for profile sorting regardless of this choice.
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"Consistent with your permissions, we may collect your location information, including your precise geolocation, for purposes like determining your distance from other users ('Distance Information') and displaying your location on our maps features. If you choose to display your Distance Information in your profile, it could be used by some users to determine your exact location and to determine your identity. You can choose to hide your Distance Information, but the Services will continue to sort and display your profile based on your relative distance from other users.Excerpt from Grindr's Privacy Policy
1. REGULATORY LANDSCAPE: This provision engages CCPA/CPRA (which classifies precise geolocation as sensitive personal information), the Washington My Health MY Data Act (which may cover location data used to infer health-related patterns), GDPR Article 5 data minimization principles, and U.S. state consumer health data statutes in Nevada. The FTC has previously taken enforcement action regarding deceptive location data practices. The explicit disclosure of trilateration risk by Grindr itself is operationally significant for GDPR transparency compliance. 2. GOVERNANCE EXPOSURE: Medium. The policy explicitly discloses the trilateration risk associated with Distance Information, which satisfies transparency obligations but does not eliminate the underlying privacy risk for users. The continued collection and use of relative location data for profile sorting even when Distance Information is hidden is disclosed and may warrant assessment under data minimization principles. 3. JURISDICTION FLAGS: California CPRA requires opt-out mechanisms for processing of precise geolocation as sensitive personal information. Washington My Health MY Data Act may apply if location data is used to infer health conditions or proximity to health-related locations. EU/EEA GDPR data minimization and purpose limitation principles apply to precise geolocation collection. 4. CONTRACT AND VENDOR IMPLICATIONS: If precise geolocation data is shared with service providers or advertising partners (for example, for location-based ad targeting), data processing agreements should address the sensitive nature of this data and applicable statutory restrictions. Advertising partner contracts should be assessed for compliance with CPRA sensitive personal information restrictions on location data use. 5. COMPLIANCE CONSIDERATIONS: Legal teams should assess whether the continued use of relative location data for profile sorting after a user hides Distance Information is adequately disclosed and consistent with data minimization principles. CPRA compliance review should address whether precise geolocation is processed for targeted advertising purposes and whether the required opt-out mechanism is implemented. The trilateration risk disclosure should be maintained in future policy versions as a documented transparency measure.
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This provision establishes that precise geolocation is collected and that Distance Information shared in profiles may enable third-party trilateration or inference of a user's exact location and identity; the policy discloses this risk directly and states that hiding Distance Information still results in profile sorting based on relative distance.
Under these terms, Grindr collects precise geolocation data and displays distance-based information that the policy itself acknowledges could be used by other users to determine a user's exact location and identity; users may hide Distance Information from their profile but the Services will continue to use relative location data for profile sorting regardless of this choice.
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