PRIVACY POLICY

Version 1.0 – Effective date: 17 June 2024

FindingYou S.à r.l. (“FindingYou,” “we,” “our,” or “us”) values your privacy, and protecting your personal information is at the core of our services. We strive to provide a safe and regulated environment, ensuring that you can fully trust our Platform to help you build meaningful connections.

To demonstrate our commitment to your privacy rights, we have established this Privacy Policy, which explains:

What personal information we collect and how we collect it.
How we use, share, and protect your data.
Your rights and choices regarding your information.

Unless otherwise specified, any terms used in this Privacy Policy have the same meaning as in our Terms of Use.

We appreciate your trust in using our website and application (collectively, the “Platform”). However, we strongly encourage you to read this Privacy Policy carefully to fully understand how we handle your personal information.

If you have any questions, please refer to the Contact Us section of this Privacy Policy.

By using our services, you consent to the terms outlined in this Privacy Policy.

Welcome to FindingYou

Thank you for taking the time to read our Privacy Policy.

We want to ensure that you fully understand:

What information we collect and why we collect it.
How we use your data to improve your experience.
Your rights and choices regarding your personal information.

This Privacy Policy is written in plain language to make it easy to understand, minimizing legal and technical jargon.

This Privacy Policy is effective as of 17 June 2024.

1. Who We Are

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

FindingYou S.à r.l.,
36 Op Der heed,
L-1747 Luxembourg,
Luxembourg

FindingYou S.à r.l. is the owner and operator of the FindingYou Platform and its associated services. We act as the data controller for any personal information collected through the Platform.

For privacy-related inquiries, you can contact our Data Protection Officer (DPO) via email at contact_us@findingyou.me.

2. Where This Privacy Policy Applies

This Privacy Policy applies to the FindingYou Platform, which is owned and operated by FindingYou S.à r.l.

3. Information We Collect

3.1 Personal Information you provide

When you register for an account or use our services, you voluntarily provide us with personal data.
This includes:

Account Registration Details: Your phone number, email address, and (if applicable) billing information.
Profile Information: Basic details such as your gender, date of birth, and preferences (e.g., gender, age, location, and sexual orientation of users you wish to match with).
User-Generated Content: This includes your profile picture, photos, videos, bio, interests, favorites, and any content you publish on the Platform.
Optional Information: You may choose to share additional details such as sexual orientation (with explicit consent) or participate in surveys, focus groups, promotions, or contests.
Customer Support Interactions: We collect information from your interactions with customer support, including email inquiries and recorded calls for training and quality purposes.
User Communications: We process conversations between users to enforce platform policies and maintain a safe space.
Identity Verification Data (Optional): If you participate in ID + Photo Verification, we collect a copy of your ID and biometric facial data to verify your identity.

3.2 Personal Information We Collect Automatically

When you use the Platform, we collect technical and usage data to improve our services. This includes:

Device Information:
- Device ID, model, manufacturer, operating system, application version
- Unique device identifiers (e.g., IDFA, Google Advertiser ID)
- IP address, WiFi/3G status, app crash data, and SDK version
Login & Social Media Data:
- If you sign in via Facebook or Google, we collect basic details like:
  - Profile photos, interests, registration date, notification settings, and last login
- You control what data you share via social media privacy settings.
Usage Information:
- How you interact with the Platform (e.g., features used, profiles viewed, ads clicked).
- Details about messages exchanged and members you interact with.
Location Data:
- GPS, Bluetooth, and WiFi signals may be collected with your express permission.
- If you decline location tracking, some features may not be available.
Browsing & Connection Data:
- Page views, referral URLs, browsing history, and IP address.
Cookies & Tracking Technologies:
- As of today, FindingYou does not use cookies on the Platform.

3.3 User Awareness & Caution on Public Information

Your FindingYou profile is visible to other members within the app based on the search criteria they select, such as gender, distance, and age preferences. Profiles are not publicly searchable outside the app, nor are they indexed by external search engines.

FindingYou does not offer features that allow users to download or share profiles directly within the app. However, we remind users to exercise caution when sharing personal information with others, as we cannot prevent members from taking screenshots of profiles and distributing them through external platforms. Once content is shared outside of FindingYou, we cannot control how it is used.

3.4 Information we receive from Third-Parties

In addition to the information you provide and data automatically collected, we may receive information about you from third parties, including:

Information from Other Users
- Other members may provide information about you while using the Platform, such as when they interact with you or submit a report regarding your behavior.
Information from Business & Advertising Partners
- Advertising Partners: If our ads are displayed on third-party platforms, we may receive analytics data about how these campaigns perform (e.g., ad engagement, conversion rates).
- Safety & Security Partners: Where permitted by law, we may receive information about individuals suspected or convicted of misconduct to help maintain the safety and integrity of our Platform.
Third-party sign-in & use of personal data
FindingYou allows users to sign up and log in using third-party authentication services such as Google, Facebook, and Apple. When you choose to use these services, we collect and process certain personal data to facilitate account creation and secure authentication.
- Data We Collect from Third-Party Sign-In Services
  - Email Address → Used to create and manage your account, identify you uniquely in our system, and facilitate account-related communications (e.g., password recovery, notifications).
  - Public Profile Information (if applicable) → Some third-party services allow you to share additional details such as your name or profile picture. We only collect what is necessary for account functionality.
- How Third-Party Sign-In Data is Handled
  - Google Sign-In → We request access to your Google email address to register your account.
  - Facebook Sign-In → We collect your primary email address linked to your Facebook account.
  - Apple Sign-In → You may choose to share either your actual email or a relay email provided by Apple.

Security & User Control
Your email address is strictly used for authentication and account management. We do not share your email with third parties for marketing without your explicit consent. You can manage or revoke access through your Google, Facebook, or Apple account settings at any time.

4. How We Use Information

We use your personal information to operate, improve, and protect our services. Below is a detailed breakdown of why and how we use your information:

To Operate and Provide Our Services
We process your information to:
- Create and manage your account and enable your access to the Platform.
- Provide customer support and respond to your inquiries.
- Facilitate profile visibility so other users can find and connect with you.
- Analyze your profile, activity, and preferences to suggest compatible matches.
- Link your devices to ensure a seamless experience across multiple platforms.
To Enhance Your Experience & Develop New Features
We analyze data to:
- Personalize recommendations based on your activity and preferences.
- Improve the app’s design and features based on user feedback and behavior.
- Test and develop new features, such as interest-based matching tools.
To Provide Relevant Offers & Advertising
We use your data to:
- Administer sweepstakes, contests, and promotions.
- Deliver personalized content and ads based on your interests.
- Communicate with you about services, offers, and promotions via email, phone, or social media.
To Ensure Safety, Prevent Fraud & Enforce Our Terms
To maintain a safe community, we:
- Detect and prevent fraud, spam, and unauthorized activities.
- Investigate and take action against Terms of Service violations.
- Retain data related to fraudulent activities to prevent recurrence.
- Process user reports and complaints to resolve disputes.
To Comply with Legal Obligations
We process your information as required to:
- Comply with applicable laws, law enforcement requests, and regulatory requirements.
- Retain transaction and traffic data for tax, accounting, and compliance purposes.
- Maintain records of user consent and opt-in/out decisions.

5. How We Share Information

FindingYou’s goal is to help you make meaningful connections, which means some of your information is shared with other users on the Platform. Additionally, we share your Personal Information with third parties who help us operate our services, always ensuring they comply with strict confidentiality obligations. Below is a detailed breakdown of when and how we share your information:

5.1 Sharing with other users

Profile Visibility: Your profile is visible to other users of the Platform. You should only share information you are comfortable being publicly viewable, as we cannot control how others use the content you share.

Privacy Settings: You may have the option to limit the audience for specific parts of your profile or content.

User Reports & Violations: If another user reports you for violating our Terms of Use, we may inform the reporter about actions taken (if any) in response to their complaint.

5.2 Sharing with Service Providers & Partners

We use third-party vendors to help operate, secure, and improve FindingYou. These partners assist with:

Data hosting & maintenance
Analytics & performance tracking
Customer support & security operations
Marketing & advertising (e.g., showing relevant ads or promotions)
Payment processing (if applicable in the future)
Strict Confidentiality & Vetting

Before working with any third party, we conduct a strict vetting process, and all partners must agree to confidentiality obligations.

Advertising & Limited Data Sharing

We may share limited user data (such as demographics) in hashed, non-human readable form with advertising partners to run marketing campaigns.

5.3 Sharing in Corporate Transactions

If FindingYou is involved in a merger, acquisition, sale, restructuring, or other corporate transaction, your data may be transferred as part of the business assets. In such cases:

We will continue to protect your information under this Privacy Policy.
If a material change in data processing occurs, we will notify you in advance.

5.4 When Required by Law

We may disclose your information if necessary to:

Comply with legal obligations, such as court orders, subpoenas, or law enforcement requests.
Assist in crime prevention (subject to applicable laws).
Protect public safety or prevent harm.

We will only share the essential portion of your information required for the investigation.

5.5 To Enforce Our Legal Rights

We may disclose your information if necessary to:

Protect FindingYou from lawsuits or liability.
Defend our legal rights and those of our users and business partners.
Enforce our Terms of Use and investigate suspected fraud or violations.

5.6 With Your Consent

We may request your explicit consent to share your information with third parties for purposes not covered in this Privacy Policy.

In such cases, we will clearly explain why the data is needed.

5.7 Sharing Non-Personal & De-Identified Data

We may use and share non-personal information (data that does not directly identify you), such as:

Device information
General demographics & behavioral trends
De-identified location data

We may also combine hashed, non-human readable personal information with non-personal data for analytics, research, and advertising.

6. Cross-Border Data Transfers

FindingYou operates globally, which means your personal data may be transferred to, stored in, or processed in jurisdictions outside your country of residence. This includes countries inside and outside the European Economic Area (EEA), the United Kingdom (UK), Switzerland, and other regions.

6.1 Why Do We Transfer Data Internationally?

We transfer your personal data across jurisdictions for the following reasons:

To operate and provide our services → Ensuring users worldwide can access and interact through the FindingYou platform.
To store and process data securely → FindingYou may use third-party service providers (such as cloud hosting, analytics, and security providers) that process data in multiple locations.
To comply with legal and regulatory requirements → In some cases, data may need to be processed in different regions due to legal or contractual obligations.

6.2 How We Ensure Your Data is Protected

We use legally approved safeguards to ensure that any transfers of personal data outside your home country comply with applicable data protection laws, including GDPR, DPDP 2023, CCPA, and LGPD. These safeguards include:

Standard Contractual Clauses (SCCs) → If we transfer your data outside the EEA, UK, or Switzerland to a country not deemed “adequate” by the European Commission, we implement SCCs to ensure GDPR-level protection.
Binding Corporate Rules (BCRs) → For certain internal transfers between FindingYou and its affiliates, we may rely on BCRs approved by data protection authorities.
Technical & Organizational Safeguards → These include data encryption, access controls, and security audits to protect personal data during transfers.

6.3 Your Rights Regarding Cross-Border Transfers

Right to Know → You have the right to request information about where your data is stored and transferred.
Right to Object → In certain cases, you may have the right to object to the transfer of your personal data.
Right to Withdraw Consent → If you previously consented to a data transfer, you can withdraw your consent at any time.
Right to File a Complaint → If you believe your data transfer rights have been violated, you can lodge a complaint with the relevant data protection authority in your country.

To exercise any of these rights, contact us at contact_us@findingyou.me

7. How We Protect Your Information

Encryption → We encrypt sensitive personal data both in transit and at rest.
Access Controls → Access to your data is restricted to authorized personnel only.
Security Audits → We conduct regular security reviews and vulnerability assessments.
Breach Notification → In case of a data breach, we will:
- Notify affected users within 24 hours.
- Report the breach to regulatory authorities where required.

If you believe your account security has been compromised, please notify us immediately at contact_us@findingyou.me

7.1. How You Can Control Your Information

Tools to manage your information:

Access / Update Tools in the App
- You can access, update, or delete certain information directly within the FindingYou app’s settings.
- If you need assistance, our customer support team can be contacted via contact_us@findingyou.me
Device Permissions
- Mobile platforms allow you to control app permissions (e.g., location access, camera, notifications).
- You can update your settings at any time to limit data collection and permissions.
Deleting Your Account
You can request to delete your FindingYou account by following these steps:
- Through the FindingYou App:
  - Log in to your FindingYou account.
  - From the Menu Navigate to Profile → Settings.
  - Select “Delete Account” and follow the on-screen instructions to confirm deletion.
- Through the FindingYou Website:
  - Go to the Account Settings section on our website.
  - Select “Delete My Account” and log in to confirm your request.
- What Happens After Account Deletion?:
  - After account deletion your account will be deactivated and removed from public visibility immediately.
  - Your profile, matches, messages, and user-generated content will be scheduled for deletion according to our Data Retention Policy.
  - As per our retention policy, certain information may be temporarily stored for up to three months for security, fraud prevention, and legal compliance before being permanently erased or anonymized.
  - After the retention period expires, your data will be permanently deleted, unless we are legally required to retain certain information.
  Account deletion is final and cannot be reversed. If you wish to use FindingYou again, you will need to create a new account.
Uninstalling the App
- You can uninstall the app at any time. However, uninstalling does NOT delete your account.
- To permanently delete your data, you must request account deletion separately.
Your Rights & Data Deletion Requests
- You can request data deletion at any time by contacting contact_us@findingyou.me
- If we must retain some data for legal reasons, we will inform you of the specific reason and duration.

8. How Long We Retain Your Information

We only retain your personal data for as long as necessary to:

Provide our services.
Comply with legal obligations.
Ensure the safety and security of users.

8.1 Retention After Account Deletion

When you delete your account, we retain certain personal data for a safety retention period of three months. During this time:

Your account is no longer visible or accessible.
Data is retained only for fraud prevention, security, and legal compliance.
After three months, your data is permanently deleted or anonymized, unless required for legal reasons.

8.2 Retention of Inactive Accounts

If your account remains inactive for two years, and you have not manually deleted it:

Your data may be automatically deleted or anonymized.
You may receive a reminder before deletion, allowing you to log in and keep your account active.

8.3 Exceptions: When We Keep Data Longer

We may retain certain data beyond the standard retention periods if:

Required by law → Some data (e.g., “traffic data”) may be kept for one year due to legal obligations.
For compliance verification → Records of user consent to our Terms & Privacy Policy may be stored for up to five years.
Ongoing legal or security investigations → If there is an active claim, fraud investigation, or regulatory request, we retain necessary data until resolved.
Preventing banned users from re-registering → We may store limited non-identifiable data to prevent malicious users from creating new accounts.

9. Children’s Privacy

FindingYou strictly prohibits the use of its services by anyone under the age of 18. We do not knowingly collect, store, or process personal information from minors.

9.1 Age Restriction Policy

Our services are intended only for individuals who are 18 years of age or older. If you are under 18, you are not permitted to create an account, use our platform, or provide any personal data.

9.2 Preventing Underage Access

We take active measures to prevent minors from accessing our services, including:

Age Verification → Users must confirm they are 18 or older during sign-up.
Profile Reviews → We review user-reported profiles suspected of belonging to minors.
Underage Reporting Mechanism → If you suspect a user is under 18, please report them immediately via email at contact_us@findingyou.me

9.3 Handling of Underage Data

If we discover that we have collected personal data from a user under 18, we will:

Immediately delete their account and associated data.
Notify the user (if possible) and explain the policy.
Allow parents or guardians to contact us to request removal.

9.4 Parental Rights & Requests

If you are a parent or guardian and believe that your child has provided us with personal information, you can:

Request deletion of the child’s data by contacting us at contact_us@findingyou.me.
Provide proof of guardianship if necessary to ensure secure handling of deletion requests.

10. Privacy Policy Changes

We are constantly improving FindingYou to help you build meaningful connections, which means this Privacy Policy may be updated from time to time. If we make material changes that affect your rights or how we process your personal data, we will notify you in advance through appropriate channels, such as email, in-app notifications, or website alerts, depending on the significance of the change. This will ensure you have time to review the updates before they take effect.

The “Last Updated” date at the top of this Privacy Policy will always reflect the most recent version for your reference.

11. Acceptance of this Privacy Policy

By using FindingYou, you acknowledge and accept the terms of this Privacy Policy and the related Terms of Use Agreement. Your continued use of our services constitutes your agreement to these policies and your commitment to complying with them.

If you do not agree with any part of this Privacy Policy, you should discontinue your use of the platform immediately. Acceptance of this Privacy Policy and the Terms of Use Agreement is a precondition for accessing and using our services.

You further agree that you will not create, develop, or operate any database, website, software, legal entity, or service that competes with FindingYou. Any such activity will be investigated, and we reserve the right to take appropriate legal action, including civil, criminal, and injunctive remedies.

12. How to Contact Us

If you have questions about this Privacy Policy, here’s how you can reach us:

By post:

FindingYou S.à r.l.,
36 Op Der heed,
L-1747 Luxembourg,
Luxembourg

By email: contact_us@findingyou.me