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    Privacy Policy.

    Privacy Policy

    FiftyTwo, Inc.

    Effective Date: January 1, 2026 Last Updated: January 1, 2026

    Thank You for joining the FiftyTwo, Inc. ("FiftyTwo," "We," "Our," or "Us") Community. Your privacy is important to Us. This Privacy Policy explains how Our websites ("Sites"), mobile application ("App"), and Your access to and use of features, widgets, plug-ins, applications, content, downloads, coaching services and/or other services that We own and/or control and/or make available, and/or where a link to this Privacy Policy or the Terms is provided (collectively, the "Services") collect, use, store, share and safeguard Your personal information.

    This Privacy Policy complies with the General Data Protection Regulation (GDPR), India's Digital Personal Data Protection Act (DPDPA), California Consumer Privacy Act (CCPA), Colorado Privacy Act (CPA), New York SHIELD Act, Denmark's Data Protection Act, Israel's Privacy Protection Regulations, and other applicable privacy laws in the United States, India, Denmark, and Israel.

    1. Information We Collect and Why

    We collect the following types of information to provide, enhance, and secure the Services:

    1.1 Personal Information

    Personal Information is collected to create and manage Your Account, personalize matches, and facilitate communication. We collect Your:

    • Name
    • Email address
    • Phone number
    • Date of birth
    • Gender
    • Location data (optional)
    • Photos and profile information
    • Payment details (if applicable)
    • Employment information (optional, for profile enhancement)
    • Education details (optional, for profile enhancement)

    1.2 Sensitive Data

    We value Your privacy and are committed to protecting Your personal information. As part of Our commitment, FiftyTwo does not request, collect, or store sensitive personal information from Subscribers. This includes but is not limited to:

    • Social Security numbers
    • Government-issued identification numbers
    • Financial account details
    • Health or medical records
    • Biometric data
    • Religious beliefs
    • Political affiliations
    • Sexual orientation (beyond Subscriber-selected profile preferences)
    • Race or ethnic background

    You are advised not to share sensitive information on Your profile, in messages, or in any other interactions within the App or using the Services. The App is designed to facilitate healthy relationships while prioritizing Subscriber safety and privacy. If You encounter any request for sensitive information, please report it to Our support team immediately.

    1.3 Automatically Collected Data

    The following data may be collected automatically when You access the Services:

    • IP address
    • Device information
    • Browser type
    • Cookies and tracking technologies (see Our Cookie Policy)
    • Geo-location data (if permitted by the Subscriber)
    • Audio recordings (if voice-based features are used)

    1.4 When You Contact Customer Support

    When You contact Our Customer Support team via Our Feedback Page, We will collect Your email address, track Your IP address, and retain the details of Your inquiry. This helps Us resolve issues efficiently and enhance customer service. We maintain records of all communications, including complaints submitted by or against Subscribers, for a maximum of six years after account deletion or such longer period required by applicable law. This retention period is in line with Our legal compliance requirements and fraud prevention efforts.

    1.5 Device and Photos Information

    We may collect information about Your device when You use the App, including the unique device identifier, device model, and operating system, for purposes such as troubleshooting, fraud prevention, security enhancements, and improving Subscriber experience. If You grant permission, the App may access Your device's address book solely to facilitate the addition of contacts to Your account. Photo verification may also be requested to confirm identity and prevent fraudulent accounts. If You opt for photo verification, the Services may use facial recognition technology to compare Your submitted photo with Your profile picture to confirm identity. We may also collect metadata related to Your uploaded photos, including engagement patterns, lighting conditions, and clarity, to optimize the presentation of Your profile pictures. This feature is designed to enhance Subscriber interactions and can be disabled at any time through the App's settings.

    1.6 Verification

    For safety, security, and to provide the best possible Subscriber experience, We require Subscribers to verify their accounts. This may include verification through phone number authentication and, in some instances, photo verification. This helps prevent fake profiles and ensures a safer environment. Verification photos are not displayed on profiles and are retained for fraud prevention and record-keeping purposes. These verification scans are securely stored and deleted after three years or when no longer required for security purposes or to comply with applicable law.

    1.7 Links

    We may track how You interact with links available when using the Services, including third-party services, by redirecting clicks or utilizing tracking mechanisms. This allows Us to generate aggregate statistics, such as how often a particular link is clicked.

    1.8 Messages

    To enhance Subscriber experience and improve the Services, We may analyze trends, sentiments, and topics in messages sent within the App. Before conducting this analysis, We take steps to remove personally identifying information. We do not share the content of Subscriber messages or insights derived from them with any third parties. Our analysis remains internal to improve safety, content moderation, and Subscriber experience in compliance with applicable privacy laws.

    1.9 User Contributions and Surveys

    From time to time, We may conduct surveys and may reach out to Subscribers to participate in research studies or provide feedback, testimonials, or marketing contributions. If You find a successful match through the Services, We may ask if You'd like to be featured in marketing campaigns. Participation in these activities is entirely voluntary, and Subscribers may opt out by contacting Our Customer Support Team through Our Feedback Page.

    1.10 Cookies and Similar Technologies

    1.10.1 Collection. When You access the Services and/or use Our App, We may collect personal data automatically through cookies or similar tracking technologies. A cookie is a small file stored on Your device or browser that allows Us to recognize and remember You.

    1.10.2 Cookie Policy. We use cookies and similar tracking technologies to enhance Your experience, improve security, and analyze platform usage. Our cookies fall into the following categories:

    • Essential Cookies: Necessary for the operation of the Services, enabling core functionality such as security, authentication, and accessibility.
    • Performance Cookies: Help Us understand how Subscribers interact with the Service to improve performance and optimize Subscriber experience.
    • Functionality Cookies: Allow Us to remember Your preferences and provide personalized content.
    • Advertising Cookies: Used to deliver relevant advertisements and track ad performance.
    • Analytical Cookies: Assist in analyzing traffic patterns and Subscriber behavior to enhance Service functionality.

    1.10.3 Managing Cookies. Users can manage their cookie preferences through browser settings. Most browsers allow You to block or delete cookies. However, restricting cookies may impact the functionality of the Services. Additionally, You can opt out of targeted advertising by visiting the Digital Advertising Alliance's (DAA) opt-out page or the Network Advertising Initiative (NAI) opt-out page.

    For more details on Our cookie usage and how You can manage them, please refer to Our Cookie Policy.

    1.11 Retention

    We retain Your personal data as long as necessary for the purposes stated in this policy. Security measures include encryption, firewalls, and access controls to protect Your data. For Subscribers in India, We comply with DPDPA requirements regarding secure processing, retention, and disposal of personal data.

    2. How We Use Your Information

    We use Your information to:

    • Provide, operate, and improve the Services
    • Personalize Your experience
    • Facilitate communication with other Subscribers
    • Enhance security and prevent fraud
    • Process payments (if applicable)
    • Verify authenticity of Subscribers through photographs
    • Conduct research and analytics about Subscriber behavior and interactions with the Services
    • Monitor Subscriber activity for policy violations and compliance with Our Terms
    • Develop new features and improve existing functionalities based on usage patterns
    • Provide customer support and respond to inquiries
    • Comply with legal obligations

    3. How We Share Your Information

    We do not sell Your personal data. However, We may share it with:

    • Other Subscribers: Information in Your profile is shared with other Subscribers as per Your settings.
    • Service providers and partners: Assisting in service operation, customer support, data analysis, payment processing, fraud prevention, and marketing.
    • Legal authorities: If required to comply with legal obligations, enforce terms of service, or protect rights, property, or safety.
    • Business transfers: If involved in a merger, acquisition, or asset sale, Your data may be transferred.
    • Marketing and analytics services: We may share anonymized data for improving service quality and marketing insights.
    • Research partners: We may use aggregated and de-identified data for academic or commercial research purposes.

    For residents of California, Colorado, Denmark, Israel, and other covered jurisdictions, You may request to opt out of certain data-sharing practices per applicable privacy laws.

    4. Moderation

    We use a combination of automated systems and human moderation to monitor and review accounts (including photos and any other information uploaded onto Subscriber profiles) and messages for content that indicates breaches or violations of Our Terms. If an Account or message meets certain criteria that demonstrate that the Terms are likely to have been breached or violated, the relevant Account may be subject to a warning and/or the Subscriber's access may be immediately restricted and/or blocked. Affected Subscribers can contact Us to appeal the decision.

    Our moderation practices may include:

    • Automated Filtering: Our automated systems scan content for inappropriate material, spam, or violations of Our Terms.
    • Manual Review: Human moderation manually reviews flagged or reported content to ensure compliance with Our Terms.
    • User Reporting: Users can report inappropriate behavior or content, which We will review.
    • Proactive Checks: Intermittent checks on newly uploaded images and profile information help prevent fraudulent activity and inappropriate content.
    • Enforcement Actions: Depending on the severity of a violation, enforcement actions may include warnings, content removal, account restrictions, suspensions, or permanent bans.
    • Appeals Process: Users who believe their account was unfairly restricted or removed can appeal the decision by contacting Customer Support at info@fiftytwo.co.

    If You post anything that is inconsistent with Our Terms, We reserve the right to terminate or restrict access to Your Account.

    5. Legal Basis for Processing

    Our goal is to provide meaningful and systems for the development of healthy relationships.

    5.1 United States

    We collect and process Your personal information based on Your consent, Our legitimate business interests, contractual necessity, and compliance with legal obligations. By using the Services, You consent to the collection, use, and sharing of Your information to enhance Subscriber experience, and ensure security of the Services. We process data to fulfill our contractual obligations, prevent fraud, and comply with applicable U.S. laws, including the California Consumer Privacy Act (CCPA) and other relevant regulations. You have the right to manage Your privacy preferences and request access, modification, or deletion of Your data as permitted by law.

    5.2 European Union

    We process Your personal information in accordance with the General Data Protection Regulation (GDPR) based on one or more legal grounds: Your consent (e.g., when You create a profile or share preferences), contractual necessity (to provide Our matchmaking services), legitimate interests (such as improving our platform and ensuring security), and legal compliance (to meet regulatory obligations). You have rights under GDPR, including access, rectification, deletion, and objection to certain processing. You may withdraw consent at any time without affecting the lawfulness of prior processing.

    5.3 India - DPDPA Compliance

    We process Your personal information in compliance with applicable Indian laws, including the Digital Personal Data Protection Act, 2023 (DPDP Act). Our legal basis includes Your consent (when you create a profile and share information), contractual necessity, legitimate business interests (such as improving platform security and Subscriber experience), and legal compliance (to fulfill regulatory obligations). You have rights under Indian law, including access, correction, and withdrawal of consent. By using the Services, You agree to our data processing practices.

    5.4 Denmark and Israel

    For Danish and Israeli Subscribers, processing and transfer of personal data are done in compliance with Denmark's Data Protection Act and Israel's Privacy Protection Regulations, ensuring lawful, fair, and transparent data handling practices.

    6. Your Rights Under GDPR, DPDPA, Denmark's Data Protection Act, Israel's Privacy Protection Regulations & U.S. State Privacy Laws

    We recognize Your rights regarding Your personal data and are committed to ensuring transparency and compliance with global privacy regulations as set forth below.

    6.1 United States - State Privacy Law Compliance – General

    • Right to Know: Understand what personal data is collected and how it is used.
    • Right to Access: Request a copy of Your personal data held by Us.
    • Right to Opt-Out: Choose to opt out of the sale or sharing of personal data.
    • Right to Correction: Request changes to inaccurate or outdated information.
    • Right to Deletion: Request the removal of personal data under applicable laws.
    • Right to Non-Discrimination: Exercise privacy rights without facing unfair treatment or restrictions on services.

    6.1.1 California (CCPA & CPRA)

    • Right to Access: Users can request copies of their data.
    • Right to Deletion: Users can request data removal.
    • Right to Opt-Out: Users can opt out of the sale of personal data.
    • Right to Correct Inaccuracies: Users can request corrections.
    • Right to Non-Discrimination: No penalties for exercising privacy rights.

    6.1.2 Colorado (CPA)

    • Right to Data Portability: Users can request their data in a structured format.
    • Right to Correction and Deletion: Users may correct or delete their data.
    • Right to Opt-Out: Users may opt-out of Targeted Advertising and Profiling.

    6.1.3 New York, North Carolina, Illinois, Ohio, Arizona, Connecticut, Iowa, Minnesota, New Jersey, Rhode Island, Wisconsin

    • Right to Know: Users may request details about data collection.
    • Right to Opt-Out: Users may opt-out of Targeted Advertising and Profiling.
    • Right to Restrict Processing: Limit certain uses of personal data.

    6.2 European Economic Area (GDPR Compliance)

    Residents of the EEA have the following rights under the General Data Protection Regulation (GDPR):

    • Right to Access: Request a copy of Your personal data.
    • Right to Rectification: Correct inaccurate or incomplete data.
    • Right to Erasure: Request deletion of Your personal data under certain conditions.
    • Right to Restrict Processing: Limit how Your personal data is used.
    • Right to Data Portability: Transfer Your personal data to another service provider.
    • Right to Object: Opt out of certain types of data processing, such as marketing.
    • Right to Withdraw Consent: Revoke consent for processing personal data at any time.

    6.3 Denmark (Denmark's Data Protection Act Compliance)

    Residents of Denmark have rights similar to those under GDPR, including:

    • Right to Be Informed: Understand how personal data is collected and used.
    • Right to Data Portability: Transfer data between service providers.
    • Right to Lodge a Complaint: File complaints with Denmark's Data Protection Agency.

    6.4 India (DPDPA Compliance)

    Residents of India are entitled to the following rights under the Digital Personal Data Protection Act (DPDPA):

    • Right to Access: Obtain details of data collected and processed.
    • Right to Correction and Erasure: Request correction or deletion of inaccurate or unnecessary data, subject to legal retention.
    • Right to Consent Management: Withdraw consent for data processing at any time.
    • Right to Grievance Redressal: File complaints regarding misuse or breach of personal data.
    • Restriction: Limit processing if disputed or unlawful.
    • Portability: Receive Your data in a structured, machine-readable format (DPDP Act-specific).
    • Objection: Opt out of marketing or profiling-based processing.
    • Right to Nominate a Representative: Appoint someone to exercise rights in case of incapacity.

    6.5 Israel (Privacy Protection Regulations Compliance)

    Residents of Israel have rights including:

    • Right to Review Information: Request access to personal data held by an organization.
    • Right to Correction: Request rectification of inaccurate personal data.
    • Right to Data Security: Expect appropriate measures for safeguarding personal data.
    • Right to Consent Management: Withdraw consent for data processing at any time.

    6.6 Rights Under Denmark's Data Protection Act (Danish Residents)

    • Right to Be Informed: Receive details on how Your data is collected, processed, and stored.
    • Right to Data Portability: Obtain a digital copy of Your data and transfer it as needed.
    • Right to Lodge a Complaint: Report violations to the Danish Data Protection Agency.
    • Right to Automated Decision-Making Protection: Challenge automated decisions made without human oversight that may impact Your rights.

    To exercise any of these rights, please contact Us at info@fiftytwo.com. We will respond to Your request within the timeframes required by applicable laws and regulations.

    7. International & State-Specific Data Transfers

    As a U.S. based company, We may transfer Your data outside the EEA and India. We ensure appropriate safeguards, such as Standard Contractual Clauses (SCCs) and compliance with DPDPA's cross-border transfer requirements for data protection. For residents of California, Colorado, and other applicable states, We ensure compliance with state-specific data transfer and retention requirements.

    8. Children's Privacy

    The Services are intended for individuals 18 and older. We do not knowingly collect data from minors.

    9. Changes to This Policy

    We may update this policy from time to time. We will notify You of significant changes.

    10. Contact Us

    If You have any questions about this Privacy Policy or Your data rights, contact Us at: info@fiftytwo.co.