1. Information We Collect

1.1 Information You Provide Directly

• Account Registration Information: Full name, email address, phone number, date of birth, gender, and password when you create an account.
• Profile Information: Photos, biography, interests, education, occupation, city/country location, religion, ethnicity, and personality assessment responses that you voluntarily provide.
• Dating & Networking Preferences: Gender preferences, preferred age range, relationship goals, and deal-breaker criteria.
• Communications: Text messages, voice notes, images, videos, and other files you send or receive through the in-app messaging system.
• Identity Verification Data: Selfie photographs submitted for identity verification, which are processed by a secure third-party facial recognition service (Microsoft Azure Face API). Verification images are stored securely and used solely for verification purposes.
• User-Generated Content: Posts, comments, reactions, and media you share on the community feed.
• Support Communications: Information you provide when contacting us for help or reporting issues.

1.2 Information We Collect Automatically

• Device Information: Device model, operating system and version, unique device identifiers (e.g., Android Advertising ID), app version, and screen resolution.
• Log and Usage Data: Pages and features accessed, time and date of access, session duration, interaction events (e.g., taps, swipes), navigation paths, and crash/error reports.
• Location Information: Approximate location at city/country level based on your IP address or the location you set in your profile. We do not access or continuously track your precise GPS location in the background.
• Network Information: IP address, internet service provider, connection type (Wi-Fi or cellular), and browser user-agent string.

1.3 Information from Third-Party Sources

• Identity Verification Providers: Verification pass/fail results and confidence scores.

2. How We Use Your Information

We use your information for the following purposes and legal bases:

2.1 To Provide and Operate the Service (Contractual Necessity)

• Create, authenticate, and manage your user account
• Display your profile to other users based on your preferences and theirs
• Provide AI-powered matching, compatibility scoring, and user discovery
• Enable real-time text messaging, voice calling, and video calling between matched users
• Deliver personality assessments and compatibility insights
• Provide our AI assistant (CHARLéY) for personalized guidance and recommendations
• Translate user content across 23 supported languages

2.2 To Ensure Safety and Security (Legitimate Interest)

• Verify user identities to prevent catfishing and impersonation
• Moderate content to detect and remove policy-violating material
• Detect, investigate, and prevent fraud, spam, abuse, and harassment
• Enforce our Terms of Service and Community Guidelines
• Respond to legal requests and prevent harm to users

2.3 To Improve and Personalize the Service (Legitimate Interest)

• Analyze usage patterns to improve features and fix bugs
• Personalize your experience, including match recommendations and feed content
• Conduct internal research and analytics
• Test new features and product improvements

2.4 To Communicate with You (Consent / Legitimate Interest)

• Send transactional notifications (new matches, messages, account alerts)
• Deliver push notifications (which you can manage in your device settings)
• Send promotional communications (only with your opt-in consent; you may opt out at any time)

3. How We Share Your Information

We do not sell, rent, or trade your personal information to third parties. We share data only in the following circumstances:

3.1 With Other Users

• Profile information you choose to make publicly visible (name, photos, bio, interests, city)
• Messages and media you send to a specific user within a conversation
• Compatibility indicators displayed when you match with someone
• Online status (which you can disable in your privacy settings)

3.2 With Service Providers

We engage trusted third-party companies to perform services on our behalf. These providers are contractually bound to use your data only to provide their specific services and are required to protect your data:

• Cloud Hosting & Storage: For secure data storage and application infrastructure
• Communication Services: Agora for video/voice calling; Firebase Cloud Messaging for push notifications; SendGrid for transactional emails; Twilio for SMS verification
• Identity Verification: Microsoft Azure Face API for selfie verification
• AI Services: OpenAI for AI-powered features including matching, moderation, and the CHARLéY assistant

3.3 For Legal Compliance and Safety

• When required by applicable law, regulation, legal process, or governmental request
• To protect the rights, property, or safety of CHARLéY, our users, or the public
• To detect, prevent, or address fraud, security issues, or technical problems
• To enforce our Terms of Service

3.4 Business Transfers

In the event of a merger, acquisition, reorganization, or sale of assets, your information may be transferred. We will provide notice before your data becomes subject to a different privacy policy.

4. Sensitive Permissions

Our app requests the following device permissions. Each permission is used only for the stated purpose and is never accessed without your knowledge:

• Camera (android.permission.CAMERA): Required for taking profile photos within the app, completing selfie identity verification, and participating in live video calls with matched users. The camera is activated only when you explicitly tap to take a photo, start verification, or initiate/accept a video call. Camera data is never accessed in the background.
• Microphone (android.permission.RECORD_AUDIO): Required for recording voice notes in conversations and for audio during video/voice calls. The microphone is only active during these user-initiated actions.
• Photo Library / Storage (android.permission.READ_MEDIA_IMAGES): Required to allow you to select and upload photos from your device to your profile or to share images in conversations.
• Push Notifications: Used to notify you of new matches, messages, likes, and important account updates. You can disable notifications at any time through your device settings or in-app preferences.
• Internet Access: Required for all app functionality including loading profiles, sending messages, and making calls.

You can revoke any permission at any time via your device's Settings > Apps > CHARLéY > Permissions. Revoking a permission will disable the associated feature but will not affect other app functionality.

5. Data Security

We implement industry-standard security measures to protect your personal information:

• Encryption in Transit: All data transmitted between your device and our servers is encrypted using TLS/SSL (HTTPS).
• Encryption at Rest: Private messages are encrypted using AES-256-GCM before storage in our database.
• Secure Authentication: User sessions are managed with secure, encrypted tokens. Passwords are hashed using industry-standard algorithms and are never stored in plaintext.
• Access Controls: Internal access to user data is restricted to authorized personnel on a need-to-know basis, with role-based permissions and multi-factor authentication for administrative access.
• Regular Audits: We conduct periodic security reviews and vulnerability assessments.
• PII Protection: Our logging systems automatically sanitize personally identifiable information to prevent accidental data leakage.

While we strive to protect your data, no method of electronic transmission or storage is 100% secure. We cannot guarantee absolute security.

6. Your Rights and Choices

Depending on your location, you may 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 that we delete your personal data. You can delete your account directly in the app via Settings > Delete Account.
• Data Portability: Request your data in a structured, commonly-used format.
• Restrict Processing: Request that we limit how we process your data in certain circumstances.
• Object to Processing: Object to our processing of your data for specific purposes.
• Withdraw Consent: Where processing is based on your consent, you may withdraw it at any time without affecting the lawfulness of prior processing.
• Opt Out of Marketing: Unsubscribe from promotional emails using the link in any marketing email, or adjust notification preferences in the app settings.

To exercise any of these rights, please contact us at admin@charleyhub.com. We will respond within 30 days.

7. Data Retention and Deletion

We retain your personal data only for as long as necessary to fulfill the purposes described in this policy:

• Active Accounts: Your data is retained while your account remains active.
• Deleted Accounts: When you delete your account (via Settings > Delete Account), your profile information, photos, and preferences are permanently removed within 30 days. Messages you sent are disassociated from your identity.
• Legal Retention: Certain data may be retained for up to 90 days after deletion to comply with legal obligations, resolve disputes, or enforce our agreements. After this period, all remaining personal data is permanently deleted.
• Anonymized Data: We may retain anonymized, aggregated data (which cannot identify you) indefinitely for analytics and service improvement purposes.

8. International Data Transfers

CHARLéY operates globally. Your data may be processed in countries other than your country of residence, including the United States. When we transfer data internationally, we implement appropriate safeguards including:

• Standard Contractual Clauses approved by the European Commission
• Data processing agreements with all third-party service providers
• Compliance with applicable data transfer regulations

9. Artificial Intelligence and Automated Decision-Making

CHARLéY uses artificial intelligence to enhance your experience. Our AI systems are used for:

• Matching: AI algorithms analyze your preferences, personality assessment results, and behavioral patterns to suggest compatible users. You retain full control over who you connect with.
• Content Moderation: Automated systems review user-generated content to detect policy violations. Flagged content is reviewed by human moderators before action is taken.
• Language Translation: AI translates messages and content across 23 supported languages to facilitate cross-language communication.
• CHARLéY AI Assistant: An optional conversational AI that provides guidance on profile optimization, dating advice, and platform navigation. All interactions with CHARLéY are voluntary.

No automated decision-making with legal or similarly significant effects is applied without human review. You can contact us to request human review of any automated decision.

10. Children's Privacy

CHARLéY is strictly intended for users aged 18 years and older. We do not knowingly collect, use, or disclose personal information from anyone under the age of 18. Age verification is required during account registration. If we become aware that we have inadvertently collected data from a person under 18, we will take immediate steps to delete that data and terminate the associated account. If you believe a minor is using our service, please contact us immediately at admin@charleyhub.com.

11. Third-Party Links and Services

Our Service may contain links to third-party websites or services that are not operated by us. We are not responsible for the privacy practices of these third parties. We encourage you to review the privacy policies of any third-party services before providing your personal information.

12. Regional Privacy Rights

European Economic Area (GDPR)

If you are located in the EEA, UK, or Switzerland, you have the rights described in Section 6 above. Our legal bases for processing are: (a) contractual necessity for providing the Service, (b) legitimate interests for safety and improvement, and (c) your consent for optional features and marketing. You have the right to lodge a complaint with your local data protection authority.

California (CCPA/CPRA)

California residents have the right to: know what personal information is collected and how it is used; request deletion of personal information; opt out of the "sale" or "sharing" of personal information. We do not sell or share your personal information as defined under the CCPA/CPRA. To exercise your rights, contact us at admin@charleyhub.com.

Ghana Data Protection Act

Users in Ghana are protected under the Data Protection Act, 2012 (Act 843). We comply with all applicable data protection requirements under Ghanaian law, including obtaining appropriate consent and ensuring data security.

13. Changes to This Privacy 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 notify you by: (a) posting the updated policy on this page with a new "Last Updated" date, (b) sending an in-app notification, and/or (c) sending an email to the address associated with your account. Your continued use of the Service after the effective date of the updated policy constitutes your acceptance of the changes. We encourage you to review this policy periodically.