PRIVACY POLICY

Effective Date: January 3, 2025

Friending, Inc. (“Friending,” “we,” “us,” or “our”) respects your privacy and is committed to protecting your personal data.

This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use the Friending mobile application, website, and related services (collectively, the “Service”).

By using Friending, you agree to this Privacy Policy.

1. Who We Are

Friending, Inc.
A Delaware corporation
📍 2109 Gardenbrook Drive, Raleigh, NC 27606
📧 hello@friending.com

Friending is the data controller for purposes of GDPR.

2. Information We Collect

2.1 Information You Provide

When you register or use Friending, we may collect:

  • Full name

  • Email address

  • Phone number

  • Profile photos and selfies

  • Date of birth

  • Location (approximate, based on device or settings)

  • Interests, activities, and preferences

  • Messages and content you share in the app

  • Customer support communications

2.2 Identity Verification Data (Persona)

To maintain a safe and trusted community, Friending uses Persona for ID and selfie verification.

Persona may process:

  • Government-issued ID images

  • Biometric selfie data

  • Verification metadata

👉 Friending does not store raw government ID images.
Verification data is processed by Persona in accordance with their privacy practices.

2.3 SMS Verification (Twilio)

We use Twilio to send one-time passcodes (OTP) for phone number verification.

  • You may receive a single SMS message for sign-in or sign-up verification

  • Message and data rates may apply

Opt-out:
You can unsubscribe from SMS messages at any time by replying “STOP”.
To get help, reply “HELP” or contact hello@friending.com.

Carriers are not liable for delayed or undelivered messages.

2.4 Automatically Collected Information

We may automatically collect:

  • Device information (OS, model, app version)

  • IP address

  • Log data and usage events

  • Approximate location

  • Crash and performance data

3. How We Use Your Information

We use personal data to:

  • Create and manage user accounts

  • Verify identity and prevent fraud

  • Enable friend discovery and activities

  • Send verification and security messages

  • Provide customer support

  • Improve and optimize the Service

  • Enforce our Terms of Service

  • Comply with legal obligations

4. Legal Bases for Processing (GDPR)

For users in the EEA/UK, we process personal data under the following legal bases:

  • Contractual necessity – to provide the Service

  • Consent – where required (e.g. SMS, marketing)

  • Legitimate interests – safety, fraud prevention, service improvement

  • Legal obligation – compliance with laws

5. Data Sharing & Third Parties

We may share data with trusted service providers, including:

  • Google Cloud Platform – hosting, databases, APIs

  • Persona – identity verification

  • Twilio – SMS verification

  • Apple & Google – app distribution and subscriptions

  • Analytics and crash reporting providers

We do not sell personal data.

6. International Data Transfers

Your data may be transferred to and processed in the United States and other countries.

Where required by GDPR, we rely on:

  • Standard Contractual Clauses (SCCs)

  • Appropriate safeguards

7. Data Retention

We retain personal data only as long as necessary to:

  • Provide the Service

  • Comply with legal obligations

  • Resolve disputes

  • Enforce agreements

You may request deletion of your account at any time.

8. Your Privacy Rights

8.1 GDPR Rights (EEA / UK Users)

You have the right to:

  • Access your data

  • Correct inaccurate data

  • Request deletion

  • Restrict processing

  • Object to processing

  • Data portability

You may also lodge a complaint with your local data protection authority.

8.2 US Privacy Rights (California & Others)

Depending on your state, you may have rights to:

  • Know what personal data we collect

  • Request deletion

  • Opt out of certain data uses

Requests can be sent to: hello@friending.com

9. Security

We use reasonable administrative, technical, and organizational safeguards to protect your data, including encryption and secure cloud infrastructure.

However, no system is 100% secure.

10. Children’s Privacy

Friending is not intended for users under 18.
We do not knowingly collect data from minors.

If we become aware of such data, we will delete it.

11. Communications

We may send:

  • Service-related emails

  • Security notifications

  • Verification messages

You may opt out of non-essential communications where applicable.

12. Changes to This Policy

We may update this Privacy Policy from time to time.

Material changes will be communicated through the Service or via email.

Continued use constitutes acceptance.

13. Contact Us

For privacy-related questions or requests:

📧 hello@friending.com