This privacy policy applies to the Polar Social mobile application (the "Application"). We provide the Application as a free service. It is intended for use "AS IS".

We are Polar Social, LLC, the data controller for personal data processed through the Application. Our principal business address is 411 Walnut Street, Suite 23921, Green Cove Springs, FL 32043, United States.

The Application collects information when you download and use it. This information may include information such as:

• Your device's Internet Protocol address (e.g. IP address)
• The pages of the Application that you visit, the time and date of your visit, the time spent on those pages
• The time spent on the Application
• The operating system you use on your mobile device

The Application collects your device's location, which helps us determine your approximate geographical location and make use of it in the following ways:

• Geolocation Services: We utilize location data to provide features such as personalized content, relevant recommendations, and location-based services.
• Legal Compliance: We also use IP geolocation to determine your approximate location for the purpose of identifying and complying with applicable legal requirements, data protection laws, and regional regulations that may apply to your use of the Application.
• Analytics and Improvements: Aggregated and anonymized location data helps us analyze user behavior, identify trends, and improve the overall performance and functionality of the Application.
• Third-Party Services: Periodically, we may transmit anonymized location data to external services. Those services may help us enhance the Application and optimize our offerings.

We may use the information you provided to contact you from time to time to provide you with important information, required notices and marketing promotions.

For a better experience, while using the Application, we may require you to provide certain personally identifiable information, including but not limited to birthdate, sex, sexual preference, location, city, personal images. The information we request will be retained by us and used as described in this privacy policy.

Certain information is required to provide the core service (such as profile information needed for matching). If you do not provide this required information, we may not be able to offer you the full functionality of the Application. Other information, such as marketing preferences, is voluntary. You may choose not to provide voluntary information without affecting your ability to use the core features of the Application.

We process your personal data only where we have a valid legal basis under applicable law. Depending on the activity, this may include: your consent (for example profile details and preferences you choose to provide, analytics preferences where we ask whether usage data may be linked to your account, and marketing where applicable); performance of a contract or steps at your request (providing the service, account, matching, messaging); legitimate interests (for example security, fraud prevention, service improvement, and anonymous product analytics and error reporting); and legal obligation where we must process data to comply with the law. The summary table below lists typical processing activities and our usual bases; see also the Sensitive Data section for special categories.

The following overview describes typical purposes, categories of personal data involved, and our usual legal bases. Specific processing may vary depending on how you use the Application.

We use PostHog to collect product analytics and error reporting to understand how the Application is used, diagnose issues, and improve performance and features. This collection occurs whenever you use the Application.

When you enable analytics in the Application (for example during onboarding or in the Privacy Center), usage and diagnostic data may be associated with your account. Enabling analytics is not required to create an account or use the core features of the Application. When you disable analytics or do not enable it, we continue to collect similar data but in an anonymous or de-identified form: we do not link events to your account, and we remove or omit identifiers such as user IDs from event data before it is sent.

Error reporting is included in this collection and follows the same identified vs. anonymous treatment based on your analytics preference. You can change this preference at any time in the Privacy Center section of the Application.

Certain information we collect—such as sexual orientation or sex life-related preferences, and face data if you use photo verification—may qualify as special categories of personal data under the EU and UK GDPR (Article 9) and as sensitive or biometric personal data under other laws that may apply where you live. Face data is described in Photo Verification below. Where we rely on consent for these categories in the EEA or UK, we ask for explicit consent at collection where required. You provide some of this information voluntarily in connection with matching; it is used for the Application's core social and matching functionality and is protected with appropriate technical and organizational safeguards. In other jurisdictions we may rely on comparable explicit consent or other permitted grounds as described in applicable law.

Photo verification is optional. It lets you show other users that you are the person in your profile photos. It only starts after you agree to it in the Application, and you can use the Application without it.

How it works. The Application uses your device's front camera and asks you to make a few head movements and blink. These movements are checked on your device. The Application then sends one photo of your face (the "verification selfie") to us. From it, we create face data: a set of numbers that describes your face. We compare your face data with the photos currently in your profile, and photos that match receive a verified badge that other users can see. Photos you add later are not checked; to verify them, run photo verification again.

What we keep. We do not store the verification selfie or your face data. Both are processed in memory for this one comparison and discarded as soon as it is done. If at least one of your profile photos matches, we store, for each photo, whether it is verified, when it was verified, the name of the face model used, and a match score. If none of your photos match, we store nothing. Other users only see the verified badge; they never see match scores.

Device checks. To confirm that the verification selfie comes from the genuine Application on a real device, the Application creates a security proof using your device's built-in attestation feature (Apple App Attest on iOS, Android Key Attestation on Android). The proof contains a fingerprint (hash) of the selfie, not the selfie itself. On iOS, creating the proof involves Apple's servers. The face detection that follows your head movements uses Google ML Kit, which runs on your device; camera images are not sent to Google for it.

Where it is processed. Your face data is created and compared by our own face-matching service, hosted on Google Cloud in the United States. The verification status of your photos is stored in our database with your account.

Legal basis and use. Face data used to recognize you is biometric data. It is a special category of personal data under the GDPR and UK GDPR, and biometric privacy laws in some US states also apply to it. We process it only with your explicit consent (Article 9(2)(a) GDPR), which you give in the Application before verification starts. We use your face data only to verify your profile photos. We do not sell it, use it for advertising, or share it with other users or with third parties other than the hosting providers that process it on our behalf.

Retention and deletion. We keep no face data, so there is none to retain or delete. The verification status of a photo is kept with that photo: it is removed when you delete the photo or erase your account, and you can ask us to remove it at any time at support@polarsocial.app. It is included when you export your data.

When you upload content to the Application, including but not limited to profile information, images, messages, and other user-generated content, you acknowledge and agree that such content may be shared publicly with other users of the platform. This sharing is necessary for the Application to function as a social platform and provide the intended user experience.

By uploading content, you grant us a license to display, distribute, and make such content available to other users as part of the Application's normal operation. You retain ownership of your content, but understand that once shared, other users may view, interact with, and potentially share your content within the platform.

You are responsible for ensuring that any content you upload complies with the Application's terms of service and does not violate the rights of others. We reserve the right to remove content that violates these terms or applicable laws.

We may share information with third parties as described in this privacy statement. Depending on the feature, this may include content or data you provide where we use processors for certain features or for moderation and safety, as well as aggregated or anonymized data for analytics and improvements. We use OpenAI only for image moderation; images may be submitted to OpenAI for that purpose in accordance with OpenAI’s privacy policy.

Your data may be transferred to and processed in countries outside your country of residence, including the United States. Where we transfer personal data from the EEA, UK, or other jurisdictions with transfer rules, we implement appropriate safeguards such as Standard Contractual Clauses (EU Commission-approved), the UK International Data Transfer Addendum or equivalent UK-approved mechanisms where applicable, Data Processing Addenda with processors, and other lawful transfer tools. For users in the EEA or UK, reliance on these safeguards (not merely consent) is the primary basis for transfers where required by law. We may also rely on consent where appropriate and valid under applicable law. The categories of processors and sub-processors we use are reflected in the third-party list above; sub-processors may change over time as we update our service providers.

We may disclose User Provided and Automatically Collected Information:

• as required by law, such as to comply with a subpoena, or similar legal process;
• when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
• with trusted service providers who work on our behalf, do not have an independent use of the information we disclose to them, and have agreed to adhere to the rules set forth in this privacy statement.

If you are located in the European Economic Area (EEA) or the United Kingdom, the following applies to you in addition to the rest of this Privacy Policy.

Controller. For personal data covered by the GDPR (EEA) or the UK GDPR (UK), the controller is Polar Social, LLC at the address stated above. Polar Social, LLC is established in the United States.

EU/EEA and UK representatives (Article 27). If you are located in the EU, EEA, or UK and have questions or concerns regarding your personal data, you may contact our appointed GDPR representatives:

EU Representative:
Euverify Ltd (Ireland)
Unit 3D North Point House, North Point Business Park, New Mallow Road
Cork, T23 AT2P, Ireland
Email: gdpr@euverify.com

UK Representative:
Euverify Ltd (UK)
3rd Floor, 86-90 Paul Street
London, EC2A 4NE, United Kingdom
Email: gdpr@euverify.com

To submit a data subject access request, data deletion request, or other GDPR-related inquiry, you may use our secure portal at gdpr.euverify.com. Requests submitted through this portal are logged and tracked to help ensure a timely response.

Legal bases and special categories. We process personal data as described in Summary of processing activities and Legal Basis for Processing, including on the basis of consent (Article 6(1)(a)), performance of a contract (Article 6(1)(b)), legitimate interests (Article 6(1)(f)), and legal obligation (Article 6(1)(c)) where applicable. Special categories of personal data are processed as described under Sensitive Data, including on the basis of explicit consent (Article 9(2)(a)) where we rely on consent.

Your rights. Subject to applicable law, you may have the right to: access; rectification; erasure; restriction of processing; data portability; object to processing based on legitimate interests (including certain profiling) and to direct marketing; withdraw consent where processing is based on consent; and lodge a complaint with a supervisory authority. You may exercise these rights as set out in Your Data Rights, by contacting support@polarsocial.app, or (if you are in the EU, EEA, or UK) through our GDPR representative portal. In the EEA, you may lodge a complaint with a supervisory authority in the Member State of your habitual residence, place of work, or of the alleged infringement. In the UK, you may lodge a complaint with the Information Commissioner's Office (ICO).

Transfers from the EEA and UK. Where we transfer personal data from the EEA or UK to countries not subject to an adequacy decision, we use appropriate safeguards such as Standard Contractual Clauses and, for UK transfers, the UK Addendum or other approved mechanisms, as described under International Data Transfers.

Automated decision-making. We do not use solely automated decision-making, including profiling, that produces legal effects concerning you or similarly significantly affects you within the meaning of Article 22 GDPR / UK GDPR. Features such as matching and recommendations may involve automated processing, but are not limited to solely automated decisions of that type.

If you are in Australia, this section applies to you in addition to the rest of this Privacy Policy. We handle personal information in line with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs), including APP 1 (open and transparent management), APP 3 (collection of solicited personal information), APP 5 (notification), APP 6 (use or disclosure), APP 8 (cross-border disclosure of personal information), APP 11 (security), and APP 12 and 13 (access and correction).

Where we disclose personal information to overseas recipients (including in the United States), we take steps that are reasonable in the circumstances to ensure that overseas recipients handle your information in accordance with the APPs, such as contractual safeguards, unless an exception under the Privacy Act applies.

If you have a complaint about how we manage your personal information, contact us at support@polarsocial.app. If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au.

Where the Notifiable Data Breaches scheme applies to us, we will assess eligible data breaches and, when required, notify affected individuals and the OAIC in accordance with Australian law.

You can disable linking analytics to your account in the Privacy Center section of the Application. When analytics is disabled, we continue to collect anonymous product analytics and error reporting as described under Product Analytics and Error Reporting above.

You can stop all collection of information by the Application by uninstalling it. You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network.

You have the following rights regarding your personal data. Response times depend on applicable law in your jurisdiction. For example, under the GDPR and UK GDPR we typically respond within one month, which may be extended by up to two further months in complex cases as permitted by law. Other laws (such as Australian privacy law or other statutes that apply where you live) may set different timeframes; we will comply with the timeframe that applies to your request.

• Access: You may request a copy of the personal data we hold about you by contacting us or using the data export feature in the Privacy Center section of the Application. We will email the export to the address on your account.
• Data Portability: You have the right to receive your personal data in a structured, machine-readable format where applicable. You can request your data from the Privacy Center section of the Application; the export is emailed to you and includes app and database data plus identified product analytics events we hold in PostHog when analytics is linked to your account.
• Rectification: You have the right to correct inaccurate or incomplete personal data. You can update most of your information directly in the Application through your profile and account settings. For data you cannot edit in-app, contact us at support@polarsocial.app.
• Deletion: You may request that we erase your personal data where applicable. Use the erase account function in the Privacy Center section of the Application as the primary way to erase your data, or contact us at support@polarsocial.app for assistance.
• Restriction: Where applicable law provides a right to restrict processing, you may ask us to restrict processing of your personal data in certain circumstances (for example if you contest accuracy or lawfulness). Contact support@polarsocial.app.
• Object: Where applicable, you may object to processing based on legitimate interests (including certain profiling) and to direct marketing. You can adjust marketing preferences where offered in the Application and contact support@polarsocial.app for other requests.
• Supervisory authority / regulator complaints: Where applicable law in your jurisdiction gives you the right to lodge a complaint with a data protection, privacy, or consumer protection authority, you may do so. If you are in the EEA or UK, see the European Economic Area and United Kingdom section above for details.
• Consent Withdrawal: Where we rely on your consent to process your data, you may withdraw that consent at any time (for example, disabling analytics so usage data is no longer linked to your account). You can also stop using the Application or contact us at support@polarsocial.app. Withdrawal does not affect the lawfulness of processing before withdrawal.

We retain your personal data indefinitely while your account exists. If you erase your account, we remove personal data that is no longer required to operate the Application or meet our legal obligations. Face data from photo verification is not retained at all, as described in Photo Verification. To erase your account, use the erase account function in the Privacy Center section of the Application as the primary method, or contact us at support@polarsocial.app. We will respond in accordance with the timeframes set out in the Your Data Rights section above.

The Application (Polar Social: Match & Date, package name com.polarsocial.polar) has zero tolerance for child sexual abuse and exploitation (CSAE), including child sexual abuse material (CSAM). This section sets out how the Application keeps minors out, what is prohibited, how to report a concern, and how we respond. Our designated child safety point of contact can be reached at support@polarsocial.app and is prepared to discuss our CSAM prevention practices and compliance with these standards.

Age Requirement. The Application is only for adults aged 18 and over, and we do not market it to or knowingly collect personal information from anyone under 18. On supported devices, the Application uses platform age signals to block account creation by users identified as under 18. If we learn that an account belongs to a minor, we remove the account and delete its personal information. If you are a parent or guardian and believe your child has used the Application, contact us at support@polarsocial.app.

Prohibited Content and Conduct. You may not use the Application for any of the following:

• Creating, uploading, sharing, requesting, or linking to CSAM
• Content that sexualizes minors, including drawn, animated, or AI-generated content
• Grooming, enticement, or any attempt to contact or meet a minor for sexual purposes
• Sextortion or trafficking of minors
• Anything else that normalizes, promotes, or facilitates CSAE

Reporting a Concern. You can report any profile, photo, or chat message from within the Application, including with the underage user and child abuse report reasons, and you can block any user at any time. You can also email us at support@polarsocial.app. Our moderation team reviews every report and handles reports involving the safety of a minor first. If a child is in immediate danger, contact your local law enforcement. You can also report child sexual exploitation directly to the National Center for Missing & Exploited Children (NCMEC) at report.cybertip.org.

How We Respond. When we become aware of CSAE or apparent CSAM on the Application, we:

• Remove the content and permanently ban the account(s) involved
• Report it to NCMEC through the CyberTipline, as required by 18 U.S.C. § 2258A, and to other law enforcement authorities where appropriate
• Preserve relevant information as required by law and cooperate with law enforcement investigations

We comply with all applicable child safety laws and regulations.

We are concerned about safeguarding the confidentiality of your information. We provide physical, electronic, and procedural safeguards to protect information we process and maintain.

In the event of a data breach that may pose a risk to your rights and freedoms, we will notify the relevant supervisory authority within 72 hours of discovery where required by applicable law (for example under the EU GDPR or comparable national requirements), assess and notify under Australia's Notifiable Data Breaches scheme where applicable, and will inform affected users when the breach is likely to result in high risk to their rights.

This Privacy Policy may be updated from time to time. We will post the updated policy on this page and update the effective date below. Where required by applicable law, we will provide additional notice (for example in-app) for material changes. We encourage you to review this Privacy Policy periodically. Continued use of the Application after an update may be subject to additional requirements under your local law; nothing in this policy is intended to override mandatory rights.

Where we rely on consent for processing (for example certain optional features or special category data where required), we will obtain that consent in a clear and specific way, such as through in-app controls or checkboxes. Other processing is carried out on other legal bases described above (such as contract or legitimate interests). Using the Application does not by itself replace any consent requirements that apply under your local law.

If you have any questions regarding privacy while using the Application, or have questions about the practices, please contact Polar Social, LLC via email at support@polarsocial.app. For data protection matters, including requests related to your data rights, you may contact us at the same email. If you are in the EU, EEA, or UK, you may also contact our GDPR representatives as described under European Economic Area and United Kingdom above. Postal mail may be sent to: Polar Social, LLC, 411 Walnut Street, Suite 23921, Green Cove Springs, FL 32043, United States.

This privacy policy is effective as of 2026-10-27