For the purposes of applicable data-protection law, appronify Limited is generally the controller of the personal information described in this Privacy Policy unless we tell you otherwise.
Please read this Privacy Policy together with our Terms of Use and any additional privacy notices shown to you when we collect specific information.
Information We Collect
The information we collect depends on how you use the Service and which features you choose to use.
Sensitive and Special-Category Information
Because inwali is a relationship and dating service, some information you provide or that can be inferred from your use of the Service may be considered sensitive or "special-category" personal data under applicable law.
This may include information revealing or relating to religious or philosophical beliefs, sex life, sexual orientation, health information or biometric information if a feature uses biometric data for identification purposes.
Where applicable law requires an additional legal condition for this type of information, we will rely on an appropriate condition, such as your explicit consent where appropriate, or another condition permitted by law.
How We Collect Information
We collect information directly from you when you create or update an account, upload content, communicate with another user, nominate a support person, contact us or otherwise use the Service. We may also collect technical and usage information automatically from your device and receive information from service providers where necessary to operate the Service.
Why We Use Your Information
We use personal information for purposes including:
- ✓creating, maintaining and authenticating your account;
- ✓providing profile, matching, discovery and relationship features;
- ✓enabling communications and relationship-support features;
- ✓operating account review, verification and moderation processes;
- ✓detecting fraud, abuse, scams, security incidents and violations of our Terms;
- ✓responding to support requests and communicating important account or service information;
- ✓improving the reliability, functionality and safety of the Service;
- ✓complying with legal, regulatory and law-enforcement obligations.
Our Legal Bases
Where UK GDPR or EU GDPR applies, we process personal information only where we have an appropriate legal basis.
How Profile Information Is Shared
Dating and relationship services necessarily involve sharing certain profile information with other users. Depending on your settings and account type, other users may be able to see information such as your first name, age, city, profile photograph, biography, preferences and other profile details.
Information intended to remain private, such as login credentials, session tokens and internal moderation records, is not displayed as public profile information.
When We Share Information
We may share personal information where reasonably necessary with:
- ✓hosting, cloud infrastructure and database providers;
- ✓email, SMS and push-notification providers;
- ✓analytics, security, fraud-prevention and technical service providers;
- ✓payment processors and app stores where paid features are offered;
- ✓professional advisers such as lawyers, accountants and auditors;
- ✓regulators, courts, law-enforcement agencies or public authorities where disclosure is legally required or reasonably necessary to protect rights, safety or security;
- ✓a purchaser, investor or successor in connection with a merger, financing, restructuring, acquisition or sale of all or part of our business, subject to appropriate protections.
We require service providers that process personal information on our behalf to use it only for authorised purposes and to apply appropriate privacy and security protections.
Selling or Sharing Personal Information
We do not sell personal information for money. If our practices ever constitute a "sale" or "sharing" of personal information under an applicable U.S. state privacy law, we will provide the notices and opt-out rights required by that law.
Cookies and Similar Technologies
Our website and services may use cookies, local storage, SDKs and similar technologies to maintain sessions, remember preferences, provide security, measure performance and support Service functionality.
Where applicable law requires consent for non-essential cookies or similar technologies, we will request that consent before using them. More information may be provided in our Cookie Policy or consent controls.
Push Notifications, Email and SMS
We may send transactional communications that are necessary to operate your account, such as security notices, verification messages, account updates and notifications relating to relationship or support requests.
Where we send marketing communications, we will do so in accordance with applicable law and provide an appropriate way to unsubscribe or change your preferences.
Matching, Recommendations and Profiling
We may use profile information, preferences and activity to organise, filter or recommend profiles and features that may be relevant to you.
Unless we expressly tell you otherwise, we do not make decisions based solely on automated processing that produce legal effects or similarly significant effects on you. If we introduce such processing, we will provide additional information and safeguards where required by law.
Security
We use appropriate technical and organisational measures designed to protect personal information against unauthorised access, alteration, disclosure, loss or destruction.
No internet or mobile service can be guaranteed to be completely secure. You should protect your account credentials and notify us promptly if you suspect unauthorised access.
How Long We Keep Information
We keep personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, including providing the Service, maintaining security, resolving disputes, enforcing our agreements and complying with legal obligations.
Retention periods vary depending on the type of information and why we hold it. When information is no longer required, we will delete, anonymise or otherwise securely dispose of it, subject to any lawful retention requirement.
Account Deletion
You may request deletion of your account using the account-deletion features we provide or by contacting us.
Deleting an account does not necessarily require immediate deletion of every record. We may retain limited information where necessary for legal compliance, fraud prevention, security, dispute resolution or other lawful purposes.
International Transfers
Some service providers may process personal information in countries outside the United Kingdom or European Economic Area.
Where required, we use recognised safeguards for international transfers, such as an adequacy decision, the UK International Data Transfer Agreement or Addendum, European Commission Standard Contractual Clauses, or another lawful transfer mechanism.
Your Privacy Rights
Depending on where you live and the applicable law, you may have rights in relation to your personal information, including:
- ✓access to personal information we hold about you;
- ✓correction of inaccurate or incomplete information;
- ✓deletion of personal information in applicable circumstances;
- ✓restriction of certain processing;
- ✓objection to certain processing, including direct marketing;
- ✓data portability where applicable;
- ✓withdrawal of consent where processing relies on consent;
- ✓lodging a complaint with an applicable data-protection regulator.
California and Other U.S. State Privacy Rights
If you live in a U.S. state with an applicable consumer privacy law, you may have additional rights, which can include rights to know or access personal information, correct it, delete it, obtain a portable copy, and opt out of certain sales, sharing, targeted advertising or profiling where applicable.
We will not discriminate against you for exercising a privacy right provided by applicable law.
Children
The dating features of inwali are intended only for adults aged 18 and over. We do not knowingly permit children to create dating profiles. If we become aware that a child has provided personal information in circumstances where they are not permitted to use the Service, we may take steps to remove the account and information as appropriate.
Third-Party Services and SDKs
The Service may use third-party services and software development kits for functions such as hosting, analytics, messaging, crash reporting, payments or push notifications. These providers may process information on our behalf or, in some cases, under their own privacy policies. We assess and use such providers in accordance with applicable privacy and platform requirements.
Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our Service, technology, legal requirements or privacy practices. We will update the "Last updated" date above and, where required by law, provide additional notice of material changes.
Contact Us
If you have questions about this Privacy Policy or want to exercise a privacy right, please contact:
Complaints
If you are located in the United Kingdom and believe your data-protection rights have been infringed, you may have the right to complain to the Information Commissioner's Office. If you are located in the European Economic Area, you may have the right to complain to the competent data-protection authority in your country. We encourage you to contact us first so that we have an opportunity to address your concern.