This business is not currently operating. These Terms of Service and Privacy Policy are subject to change and are not final. Once confirmed with a lawyer, they will almost certainly be updated.
Vybes Privacy Policy
This Privacy Policy explains how Vybes collects, uses, shares and protects personal information when you use our dating service, including the Vybes mobile application and related websites.
1. Who is responsible for your information
“Vybes”, “we”, “us” and “our” mean [FULL LEGAL ENTITY NAME], a company registered in [JURISDICTION] under number [COMPANY NUMBER], whose registered office is [REGISTERED ADDRESS]. We are the controller of personal information processed for the purposes described in this Policy.
For privacy questions or to exercise your rights, contact [PRIVACY EMAIL / WEB FORM]. Our data protection officer, if appointed, can be contacted at [DPO CONTACT]. Our UK representative, if required, is [NAME AND CONTACT DETAILS].
2. The information we collect
The exact information depends on the features you use and the choices you make. We collect information you provide, information generated as you use Vybes, and limited information from service providers or other users.
Information you provide
Account details: email address, password credentials (stored in protected form), date of birth or age, account identifiers, and account preferences.
Dating profile information: name or display name, age, photographs, short profile videos, biography, gender, pronouns, who you are interested in, age range or other matching preferences, and any other fields you choose to complete.
Sensitive profile information: information about sexual orientation or sex life, including information that may be revealed by the gender or people you select as dating interests, your profile, messages, or how you use matching features. We treat this as special category data where UK data protection law requires.
Messages and interactions: messages, likes, matches, blocks, reports, and communications with our support or safety teams.
Verification and safety information: information you submit when verifying age or identity, and information about reports, investigations, appeals or safety incidents. [Specify whether verification images, documents, face scans, or biometric templates are collected, who verifies them, and when they are deleted.]
Payment information: if paid features are offered, purchase and transaction details are generally handled by the relevant app store or payment provider. We receive limited information such as transaction identifiers, subscription status and billing country. [Confirm actual payment model and provider.]
Information collected from your device or through use
Technical and usage data: device and app identifiers, operating system, crash and diagnostic logs, IP address, timestamps, feature interactions, and security events. [Confirm each SDK and analytics tool.]
Location: [STATE WHETHER PRECISE DEVICE LOCATION IS COLLECTED].
Content and moderation signals: information needed to deliver profile content, detect spam or abuse, review user reports and enforce our rules. [Describe any automated moderation, matching or recommendation systems and whether third-party AI is used.]
Information from others
We may receive information when another user reports or blocks an account, sends a message, or shares content involving you. We may receive account, purchase, fraud-prevention or app-install information from app stores, hosting providers, identity or age-assurance services, and other vendors. [List actual sources and categories.]
3. How we use information and our legal grounds
We use information only for the purposes below and only where we have a valid legal ground. A legal ground under Article 6 UK GDPR is required for personal data; special category data also needs a separate Article 9 condition.
| Purpose | Information and legal ground |
|---|---|
| Create and administer accounts; provide profiles, matching, likes, matches and messaging | Account and profile information, including matching preferences. Article 6 ground: performance of our contract with you, to the extent necessary. |
| Use sexual orientation or sex-life information for dating preferences or matching | Special category data. Approach: a separate, affirmative, explicit consent statement under Article 6(1)(a) and Article 9(2)(a), only for specified necessary purposes. |
| Keep the service secure; prevent spam, fraud, impersonation and abuse; investigate reports | Account, device, usage and report data. Article 6 ground: legitimate interests in protecting users and the service, subject to a documented balancing assessment; legal obligation where applicable. |
| Respond to support requests and provide service notices | Contact and account information. Legal grounds: contract, legitimate interests, or legal obligation depending on the communication. |
| Comply with legal duties and establish, exercise or defend legal claims | Relevant records. Legal grounds: legal obligation or legitimate interests; Article 9(2)(f) only where special category data is strictly necessary for legal claims. |
| Measure reliability, diagnose errors and improve the service | Technical and usage information. Legal ground: legitimate interests after assessment, or consent where required for non-essential cookies or device access. |
| Send optional marketing | Contact and preference data. Legal ground: consent where required by electronic marketing law. You can unsubscribe at any time; service and safety messages are not marketing. |
Where we rely on legitimate interests, those interests are [DESCRIBE EACH INTEREST] and we have assessed the effect on your rights. You may object to processing based on legitimate interests; see “Your rights”. If we rely on consent, you can withdraw it at any time without affecting processing that took place before withdrawal.
Explicit consent for sensitive dating information
In-app consent wording: “I explicitly consent to Vybes processing the sexual orientation and sex-life information I choose to provide, including my dating interests, to show me relevant profiles and provide the matching features I request. I can withdraw this consent at any time in [SETTINGS / CONTACT ROUTE]. If I withdraw it, [EXPLAIN WHICH FEATURES STOP WORKING AND WHETHER THE ACCOUNT CAN REMAIN ACTIVE].”
4. How we share information
We do not sell personal information. We share it only as described below, under appropriate contracts or other safeguards, and only to the extent needed:
With other users: the profile information, photos, videos and profile preferences you choose to make visible; and messages or interactions you choose to send. [Specify visibility defaults, audience, blocking behavior, and whether matched users retain access to prior messages.]
If another user makes a valid request for a copy of their personal information, that copy may include messages you sent to them. We handle requests under applicable law and consider the rights of everyone involved.
With vendors acting on our instructions: hosting and storage, content delivery, email, customer support, security, age assurance, moderation, analytics, and payment administration providers. Our current vendor list: [VENDOR LIST / LINK].
With app stores or payment services: to process app distribution, purchases, refunds, subscription status and related support.
For legal and safety reasons: where reasonably necessary to comply with law, respond to lawful requests, protect users or the public, investigate suspected fraud or abuse, or establish, exercise or defend legal claims. We assess requests and disclose only what is legally permitted and necessary.
As part of a business transfer: if a merger, financing, reorganisation or sale occurs, subject to appropriate confidentiality and legal safeguards.
We do not let advertising partners use sexual orientation, sex-life information, private messages, or sensitive profile details for advertising. [Confirm ad model. If ads or ad SDKs are used, specify each data flow, consent mechanism, and whether sensitive data is technically excluded.]
5. International transfers
Vybes and its providers may process information outside the United Kingdom. Where a transfer requires a safeguard, we use a legally recognised mechanism, such as UK adequacy regulations or the UK International Data Transfer Agreement / UK Addendum to the EU Standard Contractual Clauses, together with any required transfer risk assessment. You can request information about safeguards at [PRIVACY CONTACT].
6. How long we keep information
We keep personal information only for as long as needed for the purpose for which it was collected, subject to legal, safety and dispute-resolution needs. Our retention periods are set out below:
| Information | Retention period |
|---|---|
| Active account and profile content | While the account remains active; delete or anonymise within [X] days after account deletion, subject to limited exceptions below. |
| Messages, likes and matches | While needed to provide the feature and for [X] after account closure. |
| Sensitive profile fields and consent records | Until you remove the field, withdraw consent or close the account; retain a minimal consent/audit record for [X] where necessary to demonstrate compliance. |
| Safety reports and enforcement records | [X] after closure or resolution, based on severity, repeat abuse and legal limitation periods. |
| Security logs and diagnostics | [X] days, unless needed to investigate an active incident. |
| Backups | Deleted data expires from rolling backups within [X] days; backups are isolated and not restored except for disaster recovery. |
| Financial / legal records | For the period required by applicable law or necessary for claims. |
If we must preserve information for a legal claim, safety investigation, fraud prevention or legal duty, we restrict access and use it only for that purpose. We then delete or anonymise it when the need ends. Deleting the app from your device does not delete your account.
7. Your choices and rights
You can edit profile fields, change visibility and preferences, withdraw optional consent, block or report users, and request account deletion in [IN-APP SETTINGS PATH]. If a control is not available in the app, contact [PRIVACY EMAIL]. We will respond within the time required by law and may need to verify your identity.
Access: ask for a copy of your personal information.
Correction: ask us to correct inaccurate or incomplete information.
Erasure: ask us to delete information where the law gives you that right.
Restriction: ask us to pause certain processing in specific circumstances.
Portability: receive certain information you provided in a structured, commonly used, machine-readable format, where the right applies.
Objection: object to processing based on legitimate interests. You have an absolute right to object to direct marketing.
Withdraw consent: where processing relies on consent, withdraw it at any time. Withdrawal does not affect earlier lawful processing.
These rights are subject to legal conditions and exceptions. You can complain to the UK Information Commissioner’s Office (ICO) at ico.org.uk or by calling 0303 123 1113. You may also complain to a data protection authority where you live or work.
8. Account deletion
You can request deletion through [IN-APP PATH] or [WEB ACCOUNT-DELETION URL]. We will delete or anonymise information associated with the account within [CONFIRMED PERIOD], except for limited records we must retain for legal obligations, safety, fraud prevention or legal claims. We will tell you what is retained, why, and for how long or under what criteria. Blocking or suspending an account is not a substitute for deletion. [Confirm separate web deletion route and Google Play compliance.]
9. Security
We use technical and organisational measures appropriate to the risk, including [CONFIRM: encryption in transit/at rest, access controls, least privilege, staff confidentiality, backups, monitoring, vulnerability management, incident response, vendor reviews]. No internet service can guarantee absolute security. We will handle personal data breaches and notify affected people or regulators where required by law.
10. Automated processing and recommendations
Vybes may use preferences you select to filter or order profiles. [Describe the actual matching/recommendation logic, whether profiles are ranked, whether sensitive data is used, and whether a person reviews any decisions.] We do not make decisions solely by automated processing that have legal or similarly significant effects on you, unless this changes and we provide the information and safeguards required by law.
11. Children
Vybes is intended only for people aged 18 or older. We do not knowingly allow anyone under 18 to create or maintain an account. If you believe a minor is using Vybes, report the account through [IN-APP REPORT FLOW] or contact [CHILD SAFETY CONTACT]. We will investigate and take appropriate action, including account removal and legally required reporting. [Confirm age assurance measures and child-safety response process.]
12. Cookies and similar technologies
Our website may use cookies or similar technologies for essential operation, preferences, analytics or marketing. [List cookies, SDKs, purpose, duration, providers and consent controls. State how to change preferences.] We will obtain consent where required for non-essential technologies.
13. Changes to this Policy
We may update this Policy as the service or law changes. We will update the “Last updated” date and give additional notice where required, including asking for fresh consent if a new use requires it. Continued use does not replace consent where consent is legally required.
14. Contact
Privacy contact: [EMAIL / WEB FORM]
Controller: [FULL LEGAL ENTITY NAME]
Postal address: [ADDRESS]
DPO / UK representative, if applicable: [CONTACT DETAILS]
Child safety contact: [EMAIL OR ROLE-BASED ADDRESS]