Privacy Policy

1. Introduction

MySingleFriend Ltd (“we”, “us”, “our”), a company registered in England and Wales, is the data controller responsible for your personal data. We operate the MySingleFriend mobile application (“App”), the website at mysinglefriend.app (“Website”), and all related services (collectively, the “Service”).

This Privacy Policy explains what personal data we collect, why we collect it, how we use and protect it, and your rights. It applies to all users of the Service, including those who participate as friends helping to create profiles.

By creating an account or using the Service, you acknowledge that you have read and understood this Privacy Policy. If you do not agree, please do not use the Service. This policy should be read alongside our Terms of Service.

2. Data Controller & Legal Basis

2.1 Data controller. MySingleFriend Ltd is the data controller for the purposes of the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

2.2 Legal bases for processing. We process your personal data on the following legal bases:

• Contract — Processing necessary to perform our contract with you (i.e. providing the Service);
• Legitimate interests — Processing necessary for our legitimate interests (improving the Service, preventing fraud, ensuring security), where those interests are not overridden by your rights;
• Consent — Where you have given specific consent (e.g. location data, push notifications). You may withdraw consent at any time;
• Legal obligation — Processing necessary to comply with a legal obligation to which we are subject.

3. Information We Collect

3.1 Information you provide directly:

• Account data — Name, email address, date of birth, gender, and authentication credentials (including data from Apple Sign In or Google);
• Profile data — Photos, biography text, interests, location preferences, and answers to profile prompts;
• Video content — Video recordings you create in response to friends’ questions, including any audio, visual likeness, and metadata;
• Friend-contributed content — Questions and hype content created by friends about you;
• Communications — Messages you send to other users through the App, plus any support requests or emails you send to us;
• Payment information — We do not directly collect or store payment card details. All payments are processed by the Apple App Store or Google Play Store (see Section 6).

3.2 Information collected automatically:

• Device information — Device model, operating system and version, unique device identifiers, screen resolution, and language settings;
• Usage data — Features used, screens visited, actions taken (likes, matches, messages), session duration, and interaction patterns. We use PostHog for product analytics (see Section 6);
• Subscription data — Subscription status, plan type, purchase history, and entitlement data processed through RevenueCat (see Section 6);
• Log data — IP address, browser type, referring/exit pages, timestamps, and crash or error reports;
• Location data — Approximate location derived from your IP address. We may request precise location access with your explicit consent, which you can revoke at any time through your device settings.

3.3 Information from third parties:

• Authentication data from Apple or Google if you use those sign-in methods;
• Subscription and purchase validation data from the Apple App Store or Google Play Store via RevenueCat;
• Information you choose to import from other services (if applicable).

4. How We Use Your Information

We use the information we collect for the following purposes:

4.1 Providing the Service:

• Creating and maintaining your account and profile;
• Displaying your profile (including video content) to potential matches;
• Facilitating matching, messaging, and friend participation features;
• Processing subscriptions and verifying entitlements via RevenueCat;
• Sending you transactional communications (account verification, match notifications, messages).

4.2 Improving the Service:

• Analysing usage patterns and feature adoption through PostHog to understand how people use the App;
• Identifying and fixing bugs, crashes, and performance issues;
• Conducting internal research to improve matching quality and user experience;
• Testing new features (A/B testing).

4.3 Safety and security:

• Detecting, investigating, and preventing fraud, spam, abuse, and policy violations;
• Moderating content (including video content) to enforce our Terms of Service;
• Verifying accounts and protecting against unauthorised access.

4.4 Legal and compliance:

• Complying with applicable laws, regulations, and legal processes;
• Responding to lawful requests from public authorities;
• Enforcing our Terms of Service and protecting our legal rights.

5. What We Do Not Do

We believe in being transparent about our practices. We want to be clear:

• We do not sell your personal data to any third party, ever;
• We do not serve advertisements in the App or on the Website;
• We do not use your data for ad targeting or share it with advertising networks;
• We do not create advertising profiles based on your activity;
• We do not share your messages with anyone other than the intended recipient (unless required by law or to enforce safety policies).

6. Third-Party Services & Data Processors

We use carefully selected third-party services to help us operate the Service. These providers act as data processors on our behalf and are contractually obligated to protect your data. We only share the minimum data necessary for each service to function.

We may also share data with professional advisers (legal, accounting) and with law enforcement or regulators where required by law. We will not share your data with any third party for their own marketing purposes.

7. Video Content & Special Considerations

7.1 What we store. When you record a video response, we store the video file, associated metadata (timestamp, duration, file size), and the friend’s question it responds to.

7.2 Who sees it. Your video content is displayed on your profile and is visible to other users of the Service. We may also use anonymised or aggregated video data for security and content moderation purposes.

7.3 Biometric data. We do not use facial recognition technology. We do not extract, store, or process biometric identifiers from your videos.

7.4 Deletion. When you delete a specific video or your entire account, all associated video files are permanently deleted from our servers within 30 days. Cached or backed-up copies may take up to an additional 60 days to be fully purged from backup systems.

8. Friend-Created Content

8.1 What friends share. When a friend participates in creating your profile, they submit questions and content that appears alongside your video responses. This content is associated with your profile.

8.2 Friend data. If a friend uses the App to contribute to your profile, we collect minimal data about them (name and association with your profile). Friends who do not create their own dating profile are not shown to other users as potential matches.

8.3 Removal. You may remove any friend-created content from your profile at any time through the App. Friends may also request removal of content they have contributed by contacting us.

9. Sharing Your Information with Other Users

The Service is a dating platform. By creating a profile, you understand and agree that certain information will be visible to other users:

• Your profile (name, photos, video content, bio, interests, and friend-contributed content) is visible to other users browsing the App;
• Your messages are visible to the users you are matched and communicating with;
• Your approximate location (city/region level) may be shown to other users, if you have enabled location sharing.

You should not include sensitive personal information (e.g. financial details, national insurance numbers) in your profile, videos, or messages. We are not responsible for what other users do with information you share with them.

10. Data Retention

10.1 Active accounts. We retain your personal data for as long as your account is active and you continue to use the Service.

10.2 Account deletion. When you delete your account, we will delete or anonymise your personal data within 30 days. Video content, profile data, and messages will be permanently removed. Back-up copies may persist for up to 90 days before full deletion.

10.3 Inactive accounts. If your account has been inactive for an extended period, we may contact you before deleting it. We will provide reasonable notice before any deletion of inactive accounts.

10.4 Legal obligations. We may retain certain data beyond the periods above where required by law (e.g. financial records for tax purposes, or data relevant to an ongoing legal dispute).

10.5 Anonymised data. We may retain anonymised, aggregated data (which cannot be used to identify you) indefinitely for analytical and research purposes.

11. Your Rights

Under the UK GDPR and the Data Protection Act 2018, you have the following rights in relation to your personal data:

• Right of access — You can request a copy of the personal data we hold about you;
• Right to rectification — You can request correction of inaccurate or incomplete data;
• Right to erasure — You can request deletion of your personal data (subject to legal retention requirements);
• Right to restrict processing — You can request that we limit how we use your data in certain circumstances;
• Right to data portability — You can request a machine-readable copy of data you have provided to us;
• Right to object — You can object to processing based on legitimate interests;
• Right to withdraw consent — Where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing;
• Right to lodge a complaint — You have the right to lodge a complaint with the Information Commissioner’s Office (ICO) at ico.org.uk.

To exercise any of these rights, contact us at [email protected]. We will respond within one month of receiving your request, as required by law. We may ask you to verify your identity before processing your request.

12. Data Security

We take the security of your personal data seriously and implement appropriate technical and organisational measures, including:

• Encryption of data in transit (TLS/SSL) and at rest;
• Secure authentication mechanisms;
• Regular security assessments and monitoring;
• Access controls limiting who within our team can access personal data;
• Secure video storage with access restricted to authenticated users of the Service.

However, no method of electronic storage or transmission is 100% secure. While we strive to protect your personal data, we cannot guarantee its absolute security. If we become aware of a data breach that is likely to result in a risk to your rights and freedoms, we will notify you and the relevant supervisory authority in accordance with applicable law.

13. International Data Transfers

Your data may be transferred to and processed in countries outside the United Kingdom. Where this occurs, we ensure appropriate safeguards are in place, including:

• Transfers to countries deemed adequate by the UK government;
• Standard Contractual Clauses (SCCs) approved by the relevant authorities;
• Other legally recognised transfer mechanisms.

Our third-party processors (including PostHog and RevenueCat) may process data outside the UK. In all cases, we ensure that an adequate level of protection is provided for your data.

14. Cookies & Tracking Technologies

14.1 Website. Our Website may use essential cookies required for the site to function. We do not use third-party advertising or tracking cookies on our Website.

14.2 App analytics. Within the App, we use PostHog to collect anonymised usage analytics. This helps us understand feature usage and improve the App. PostHog does not track you across other apps or websites.

14.3 No advertising trackers. We do not use advertising SDKs, ad networks, or cross-app tracking technologies. We do not participate in advertising identifier sharing (e.g. IDFA or GAID for ad purposes).

15. Children’s Privacy

The Service is strictly for individuals aged 18 and over. We do not knowingly collect personal information from anyone under 18. If we discover that a user is under 18, we will immediately suspend their account and delete all associated data. If you believe a minor is using the Service, please report it to [email protected].

16. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will:

• Update the “Last updated” date at the top of this page;
• Notify you via the App, email, or a prominent notice on the Website;
• Where required by law, seek your consent to the updated terms.

We encourage you to review this policy periodically. Your continued use of the Service after changes take effect constitutes acceptance of the updated Privacy Policy.

17. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or how we handle your data, please contact us:

You also have the right to lodge a complaint with the UK’s Information Commissioner’s Office (ICO) if you believe your data protection rights have been violated. You can contact the ICO at ico.org.uk or by phone at 0303 123 1113.