Sapian: Privacy Policy

SAPIAN PRIVACY POLICY

Last Updated: December 7, 2025
Version: 1.0

INTRODUCTION

Sapian ("we," "our," "us") respects your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application and services (the "Service").
BY USING SAPIAN, YOU CONSENT TO THIS PRIVACY POLICY. IF YOU DO NOT AGREE, DO NOT USE THE SERVICE.
Key Points:
We collect information you provide (name, photos, profile) and automatically (location, device data, usage) We show your profile to other users to enable connections We use approximate location to show nearby users We do NOT sell your personal information You can delete your account anytime We are NOT responsible for offline meetings

INFORMATION WE COLLECT

2.1 Information You Provide
Registration and Account:
Email address or phone number Date of birth (to verify 18+; only age shown to others) Authentication credentials
Profile Information (visible to other users):
Name Gender Photos About Me description Meeting format preferences (walks, sports, coffee) Interests and activities Topics of conversation
Communications:
Messages to other users Reports and feedback Customer support inquiries
Payment Information:
Processed by third parties (Apple, Google) We receive transaction confirmation only We do NOT store credit card numbers
2.2 Automatically Collected Information
Location Data:
GPS coordinates when enabled We show only approximate distance to others (e.g., "2 km away"), NOT exact location Used to display nearby users and suggest meeting areas You control location permissions in device settings
Device and Technical Information:
Device identifiers (UDID, IDFA, Advertising ID) Device type, model, OS version IP address Mobile carrier App version and settings
Usage and Activity:
Users you view, match with, message Features used and when Time spent in app Session frequency and duration Response rates and patterns
Performance Data:
Crash reports and errors Performance metrics Debugging information
2.3 Information from Third Parties
Social Sign-In (Google, Apple):
Email, name, profile picture Only what you authorize them to share
Analytics Services:
Usage data through SDKs and cookies Aggregated behavioral data
2.4 Information We Do NOT Collect
Health or medical information Precise home addresses Credit card numbers Biometric data (no facial recognition) Government IDs Children's information (18+ only)

HOW WE USE YOUR INFORMATION

We use collected information to:
Provide the Service:
Create and maintain your account Display your profile to other users Show you nearby users based on location Enable messaging between users Match users based on preferences and proximity
Improve the Service:
Analyze usage patterns Develop new features Optimize performance and algorithms Fix bugs and technical issues
Safety and Security:
Detect fraud, spam, and abuse Moderate content and enforce policies Investigate violations Verify accounts and prevent fakes
Communications:
Send notifications about matches and messages Provide customer support Send service updates and policy changes Marketing emails (you can opt out)
Legal Compliance:
Comply with laws and legal requests Protect our rights and property Respond to emergencies
Legal Basis (EU/EEA):
Consent (location, marketing) Contract performance (provide Service) Legitimate interests (improvements, security) Legal obligations

HOW WE SHARE YOUR INFORMATION

4.1 With Other Users
Other users can see:
Name, age, gender Photos and profile description Interests and topics Meeting preferences Approximate distance from them When you were last active (if enabled)
Other users CANNOT see:
Email or phone number Exact date of birth Precise GPS location IP address or device info Your messages with other users
IMPORTANT: We cannot control what users do with information you share. Users may screenshot your profile or share information outside the Service. Share only what you're comfortable becoming public.
4.2 With Service Providers
We share data with third parties who help operate the Service. They must protect your data and use it only for specified purposes.
Categories of Service Providers:
Cloud Hosting and Infrastructure - Store and process user data, photos, messages
Analytics and Data Services - Understand usage patterns and improve the Service
Communications - Email verification, SMS codes, push notifications
Payment Processing - Handle subscriptions and purchases (do NOT receive full credit card numbers)
Customer Support - Ticketing systems, help desk platforms
Security and Fraud Prevention - Detect spam, fake accounts, violations
Marketing - Email campaigns, engagement tools (if we run ads in future)
4.3 For Legal and Safety Reasons
We may disclose information when required to:
Comply with laws, regulations, court orders Respond to law enforcement requests Protect safety and rights of users or public Prevent fraud and illegal activity Enforce our Terms of Service Defend legal claims
We will notify you before disclosure unless legally prohibited or in emergencies.
4.4 Business Transfers
If Sapian is acquired or merged, your information may transfer to the new entity. We will notify you and the new entity must honor this Privacy Policy.
4.5 With Your Consent
We may share for other purposes with your explicit permission, such as featuring your testimonial or success story.
4.6 Aggregated Data
We may share aggregated, de-identified data that cannot identify you (e.g., "70% prefer coffee meetings") for research, marketing, and public reports.
4.7 What We Do NOT Do
We do NOT:
Sell your personal information Rent contact information to third parties Share exact location with other users Provide email/phone to other users Share messages except with intended recipients

YOUR CHOICES AND RIGHTS

5.1 Account Settings
You can edit your profile, photos, interests, and preferences anytime in Settings.
5.2 Location Control
Control location access in device settings:
iOS: Settings → Privacy → Location Services → Sapian Android: Settings → Apps → Sapian → Permissions → Location
Disabling location limits Service functionality.
5.3 Communications
Opt out of marketing emails via unsubscribe links or app settings.
You cannot opt out of essential service communications (security alerts, policy changes).
5.4 Data Rights
Right to Access:
Request a copy of your data by emailing alexey.bystritsky@gmail.com We respond within 30 days
Right to Correction:
Edit information in app settings or contact us to correct inaccuracies
Right to Deletion:
Delete your account in Settings → Account → Delete Account, or email us Most data deleted within 30 days; backups within 90 days Some data retained for legal compliance
Right to Data Portability (EU/EEA):
Request data in machine-readable format
Right to Object and Restrict (EU/EEA):
Object to processing or request limitations
Right to Withdraw Consent:
Disable location, opt out of marketing, or delete account
5.5 Automated Decisions
We use algorithms for matching and content moderation. You can request human review by emailing alexey.bystritsky@gmail.com
5.6 Do Not Sell (California)
We do NOT sell personal information. If this changes, we will provide opt-out mechanism.
5.7 Lodge a Complaint
EU/EEA: Contact your data protection authority California: Contact Attorney General Others: Contact local privacy regulator
We encourage contacting us first at alexey.bystritsky@gmail.com

DATA SECURITY

6.1 Security Measures
Technical Safeguards:
Encryption in transit (TLS/SSL) Encryption at rest for sensitive data Firewalls and intrusion detection Secure authentication
Access Controls:
Limited employee access Role-based permissions Multi-factor authentication Audit logs
Operational Safeguards:
Regular security audits Employee training Vendor assessments Incident response plan
6.2 Your Responsibility
Keep account credentials secure Don't share login information Use strong passwords Report suspicious activity Secure your device
6.3 Limitations
NO SYSTEM IS 100% SECURE. We cannot guarantee absolute security. You use the Service at your own risk regarding data security.
We cannot control information you share with other users through messages or meetings.
6.4 Data Breach Response
If a breach occurs, we will:
Investigate and remediate promptly Notify affected users as required by law Report to authorities (EU: within 72 hours) Provide guidance on protective steps
Contact for security issues: alexey.bystritsky@gmail.com

DATA RETENTION

7.1 Retention Periods
Active Accounts:
We retain data while your account is active
Deleted Accounts:
Profile removed immediately from public view Most data deleted from active systems within 30 days Backup systems: up to 90 days Transaction records: 7 years (legal requirement) Aggregated/anonymized data: indefinitely
Inactive Accounts:
After 24 months of inactivity, we may send reminders After 30 months, we may delete your account
7.2 Exceptions
We may retain data longer for:
Legal compliance (tax, transaction records) Fraud prevention (banned user list) Backup systems (auto-deleted within 90 days) De-identified analytics

INTERNATIONAL DATA TRANSFERS

Your data may be transferred to and processed in countries other than your own.
8.1 EU/EEA Transfers
We protect international transfers using:
Standard Contractual Clauses (EU Commission approved) Adequacy decisions (recognized countries) Additional safeguards (encryption, access controls)
You can request details at alexey.bystritsky@gmail.com

CHILDREN'S PRIVACY

Sapian is 18+ ONLY.
We do NOT knowingly collect data from anyone under 18.
If we discover underage users, we immediately:
Terminate their account Delete all their data Do not notify them (to prevent re-registration with false age)
Parents: If your child created an account, contact alexey.bystritsky@gmail.com immediately with evidence you're the parent/guardian.

THIRD-PARTY SERVICES AND LINKS

10.1 Third-Party Services
We use various third-party services (hosting, analytics, communications, payments). Each has its own privacy policy. We are not responsible for their practices.
Review their privacy policies:
Google: policies.google.com/privacy Apple: apple.com/legal/privacy
10.2 Third-Party Links
The Service may contain links to other websites. We are not responsible for their content or privacy practices.
10.3 User-Posted Links
Be cautious of links posted by other users. Don't click suspicious links or provide personal information to unknown sites.

COOKIES AND TRACKING

11.1 What We Use
Cookies and similar technologies (web beacons, SDKs, device identifiers) for:
Strictly Necessary:
Authentication, security, basic functionality (cannot opt out)
Analytics:
Usage statistics, performance monitoring (can disable)
Functionality:
Preferences, settings
11.2 Control Options
Web Browsers:
Refuse or delete cookies in browser settings
Mobile:
iOS: Settings → Privacy → Tracking (toggle off) Android: Settings → Google → Ads → Opt out
Do Not Track:
We do not respond to DNT signals, but you can control tracking via above methods

CHANGES TO THIS POLICY

We may update this Privacy Policy to reflect changes in practices, services, or laws.
Material Changes:
We notify via email, in-app notice, or push notification at least 30 days before changes take effect
Non-Material Changes:
We update the "Last Updated" date
Continued use after changes = acceptance.
If you disagree:
Stop using Service and delete account before effective date
Review this policy regularly at: Settings → Legal → Privacy Policy

Privacy Questions: alexey.bystritsky@gmail.com
General Support: alexey.bystritsky@gmail.com

Response time: 30 days

JURISDICTION-SPECIFIC RIGHTS

14.1 EU/EEA Residents (GDPR)
You have rights detailed in Section 5, including access, rectification, erasure, portability, objection, and restriction.
Supervisory Authority:
You can lodge complaints with your local data protection authority List at: edpb.europa.eu/about-edpb/board/members_en
Legal Basis:
Consent, contract, legitimate interests, legal obligations (see Section 3)
International Transfers:
See Section 8 for safeguards
14.2 California Residents (CCPA/CPRA)
Right to Know:
Request categories and specific pieces of data we collect
Right to Delete:
Request deletion (with exceptions)
Right to Correct:
Request correction of inaccurate data
Right to Opt Out of Sale:
We do NOT sell data
Right to Non-Discrimination:
No discrimination for exercising rights
How to Exercise:
Email alexey.bystritsky@gmail.com with "California Privacy Request" in subject We respond within 45 days
Shine the Light:
We don't share data with third parties for their direct marketing
14.3 Nevada Residents
We do NOT sell personal information under Nevada law.
14.4 Virginia, Colorado, Connecticut, Utah
You have rights to access, correct, delete, and obtain copies of data.
We do NOT sell data, engage in targeted advertising, or use data for profiling with legal effects.
To Exercise:
Email alexey.bystritsky@gmail.com with "State Privacy Request"
14.5 Other Jurisdictions
We comply with applicable laws in all jurisdictions.
Contact alexey.bystritsky@gmail.com for information about your specific rights.
ACKNOWLEDGMENT
BY USING SAPIAN, YOU ACKNOWLEDGE:

You've read and understood this Privacy Policy
You're at least 18 years old
You consent to data collection and use as described
Your profile will be visible to other users
We use approximate location to show nearby users
We're not responsible for offline meetings
You can delete your account anytime

IF YOU DO NOT AGREE, DO NOT USE SAPIAN.
Last Updated: December 7, 2025
Version: 1.0
END OF PRIVACY POLICY