Privacy Policy

FaithLink Ltd. ("FaithLink", "we", "us", or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, store, share, and safeguard your personal information when you use the FaithLink mobile application, website, and related services (collectively, the "Service").

We comply with the Data Protection Act, 2019 of Kenya, and where applicable, the principles of the EU General Data Protection Regulation (GDPR). By using the Service, you consent to the practices described in this policy.

FaithLink Ltd. is the Data Controller responsible for your personal data.

Registered Address: P.O. Box 12345-00100, Nairobi, Kenya Data Protection Officer: privacy@faithlink.app

We collect the following categories of personal data:

A. Information You Provide Directly • Account Information: email address, encrypted password hash, optional phone number, and date of birth (used for age verification). • Profile Information: display name, gender, denomination/church affiliation, bio/about me, city/location, photos, and optional voice/video introductions. • Preference Information: age range preferences, denomination preferences, dealbreakers, and matching criteria. • Communications: messages sent through our platform, reports, support inquiries, and feedback. • Verification Information: selfie verification photos (used solely for identity verification and not shared with other users).

B. Information Collected Automatically • Device Information: device type, operating system version, unique device identifiers (where permitted), and mobile network information. • Usage Data: app feature usage, swipe actions, matches, messages sent/received, session duration, and interaction patterns. • Log Data: IP address, browser type, access times, pages viewed, and crash reports. • Location Data: approximate city-level location derived from IP or GPS (with your permission). Precise GPS is only collected if you explicitly grant permission, and you can disable it in device settings. • Cookies & Similar Technologies: authentication tokens, preference cookies, and analytics identifiers.

We process your personal data for the following purposes:

• Service Provision: To create and manage your account, match you with compatible users, deliver messages, and provide core dating features. • Safety & Security: To verify identity, detect and prevent fraud, spam, harassment, and abuse, enforce our Terms of Service, and investigate violations. • Communication: To send you service-related notifications (matches, messages, security alerts), marketing emails (only with your consent, which you can withdraw anytime), and respond to your inquiries. • Improvement & Research: To analyze usage trends, diagnose technical issues, develop new features, and improve match algorithms. • Legal Compliance: To comply with applicable laws, regulations, legal processes, and law enforcement requests. • Monetization: To process payments, manage subscriptions, and prevent billing fraud.

We rely on the following legal bases: • Contractual Necessity: Processing necessary to provide the Service under our Terms (e.g., account creation, matching, messaging). • Legitimate Interests: Processing for safety, security, fraud prevention, and service improvement, balanced against your privacy rights. • Consent: For marketing communications, precise location tracking, and optional profile fields. You can withdraw consent anytime in Settings. • Legal Obligation: Where required by law (e.g., responding to valid legal requests, retaining transaction records). • Vital Interests: In rare cases, to protect your or another person's life or safety.

We do NOT sell your personal data. We share data only in the following circumstances:

• With Other Users: Your public profile information (name, photos, bio, city, denomination) is visible to other registered users as part of the matching service. Messages are shared only with the intended recipient. • Service Providers: We use trusted third-party providers for cloud hosting, database storage, image/video storage, push notifications, email delivery, analytics, payment processing, and customer support. These providers process data on our behalf under strict data processing agreements. • Payment Processors: Apple App Store and Google Play process your subscription payments. We receive only transaction status and subscription metadata, not your full card details. • Legal Authorities: We may disclose data if required by law, court order, or governmental regulation, or if necessary to protect our rights, property, or safety, or that of our users or the public. • Business Transfers: If FaithLink is involved in a merger, acquisition, or asset sale, your data may be transferred as part of that transaction, subject to the same privacy commitments.

We retain your personal data for as long as necessary to fulfill the purposes for which it was collected:

• Active Accounts: Profile and account data are retained while your account is active. • Deleted Accounts: When you delete your account, we begin a 30-day grace period during which you can recover your account. After this period, we permanently delete your profile, photos, messages, matches, and activity data from our active systems. • Legal Retention: Some data may be retained longer where required by law (e.g., payment records for 7 years, abuse investigation data for up to 3 years) or for legitimate safety purposes (e.g., hashed device identifiers of banned users to prevent re-registration). • Anonymized Data: We may retain anonymized, aggregated data that cannot identify you for analytics and research purposes indefinitely.

Depending on your jurisdiction, you have the following rights regarding your personal data:

• Access: Request a copy of the personal data we hold about you. • Correction: Request that we correct inaccurate or incomplete data. • Deletion: Request deletion of your personal data (right to be forgotten). You can do this via Settings → Delete Account, or by emailing privacy@faithlink.app. • Restriction: Request that we restrict processing of your data in certain circumstances. • Portability: Request a machine-readable copy of your data for transfer to another service. • Objection: Object to processing based on legitimate interests or for direct marketing. • Withdraw Consent: Withdraw consent for optional processing (e.g., marketing, location) at any time. • Lodge a Complaint: File a complaint with the Office of the Data Protection Commissioner (Kenya) or your local supervisory authority.

To exercise these rights, contact us at privacy@faithlink.app. We will respond within 30 days. We may need to verify your identity before processing your request.

We implement appropriate technical and organizational measures to protect your data:

• Encryption: All data in transit is encrypted using TLS 1.2+. Sensitive data at rest is encrypted using AES-256. • Authentication: Passwords are hashed using bcrypt. We support biometric/passkey authentication. • Access Controls: Database access is restricted via Row-Level Security (RLS) policies. Only authorized personnel with a need-to-know basis can access user data. • Monitoring: We monitor for unauthorized access, data breaches, and anomalous activity. • Incident Response: In the event of a data breach, we will notify affected users and relevant authorities within 72 hours as required by law.

No method of transmission over the Internet is 100% secure. While we strive to protect your data, we cannot guarantee absolute security.

Your data is primarily stored and processed in secure cloud infrastructure located within regions that provide adequate data protection. Where we use service providers outside Kenya or the EEA, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses (SCCs) or equivalent mechanisms, to protect your data in accordance with Kenyan and EU data protection laws.

We use the following categories of cookies and similar technologies:

• Essential: Required for authentication, security, and core functionality. These cannot be disabled. • Preferences: Remember your settings (theme, language, notification preferences). • Analytics: Help us understand how users interact with the Service so we can improve it. We use anonymized analytics where possible.

You can manage cookie preferences in your browser or device settings. We do NOT use third-party advertising cookies or tracking pixels for ad targeting.

FaithLink is strictly for users aged 18 and over. We do not knowingly collect personal data from anyone under 18. If we learn that a minor has created an account, we will immediately terminate the account and delete all associated data.

If you believe a minor is using FaithLink, please contact us immediately at safety@faithlink.app with details so we can investigate.

Our mobile app may request the following permissions, each explained below:

• Camera: To take profile photos and selfie verification images. We do not access your camera without your explicit action. • Photo Library / Storage: To upload existing photos to your profile. We only access photos you explicitly select. • Microphone: To record optional voice introductions. We do not listen to or record audio without your explicit initiation. • Location: To show your approximate city to potential matches and enable location-based features. Precise location is only collected if you grant permission and can be disabled anytime in device settings. • Notifications: To send you match alerts, messages, and safety notifications. You can manage these in device settings.

You can revoke any permission at any time through your device settings, though this may limit certain features.

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or Service features. Material changes will be communicated via an in-app notice or email at least 14 days before taking effect. The "Last updated" date at the top of this policy will always reflect the latest version.

Continued use of the Service after changes take effect constitutes your acceptance of the revised policy.

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

Email: privacy@faithlink.app Address: FaithLink Ltd., P.O. Box 12345-00100, Nairobi, Kenya Data Protection Officer: privacy@faithlink.app

We aim to respond to all privacy inquiries within 2 business days.