Privacy Policy

1. Introduction

Welcome to The Transfer Portal (“we,” “us,” or “our”). We are committed to protecting your privacy and ensuring you understand how your personal information is collected, used, and shared when you use our mobile application and related services (collectively, the “Service”).

The Transfer Portal is a dating application for emotionally ready singles, including people who have never married, people who are divorced or separated, and single parents. Given the personal nature of our Service, we take your privacy seriously. This Privacy Policy explains our data practices so you can make informed decisions about using our Service.

By creating an account or using The Transfer Portal, you agree to the collection and use of information in accordance with this Privacy Policy. If you do not agree with our practices, please do not use the Service.

2. Information We Collect

2.1 Information You Provide

Account & Profile Information

When you create an account and build your profile, we collect:

• Name and date of birth
• Email address
• Phone number, if you sign in with one or add it to your account
• Gender identity
• Profile photos (up to 6 images)
• Bio and personal description
• Responses to dating prompts
• Location (city, state, and geographic coordinates)

Relationship & Personal Details

To facilitate meaningful matching, we collect information about your personal circumstances, including:

• Relationship status and divorce timeline
• Whether you have children and their age ranges
• Co-parenting style and custody preferences
• Relationship goals and intentions
• Core values and lifestyle preferences

Emotional Readiness Information

Our Service includes an emotional readiness assessment. We collect:

• Your responses to our readiness questionnaire
• Your resulting readiness score
• Whether you are currently or have previously been in therapy
• Information about your healing journey that you choose to share

Please note: This information is considered sensitive personal data. We use it solely to improve your matching experience and never share individual readiness details with other users beyond a general compatibility indicator.

Lifestyle & Preference Information

• Height, education level, occupation
• Religious and political beliefs
• Exercise frequency and substance use preferences (smoking, drinking, etc.)
• Pet preferences and weekly availability
• Age range and distance preferences for matches
• Deal breakers and must-have qualities

Verification Data

To maintain a safe and authentic community, we may collect:

• Photo verification: A selfie performing a specific pose to confirm your identity
• ID verification (optional): A photo of a government-issued ID (driver's license, passport, or state ID) along with the document type, submission date, and verification status

Communications

• Messages exchanged with other users (text, photos, GIFs, and voice notes), including messages you post in group circles
• Date proposals and venue suggestions
• Reports and feedback you submit

Payment Information

If you purchase a subscription, payment is processed through Apple App Store, Google Play Store, or our payment processor (RevenueCat/Stripe). We store your subscription tier, status, and expiration date but do not store your credit card number or full payment details.

Social Account Links

You may optionally link your Spotify or Instagram accounts. We store only the account identifier or handle you choose to share.

2.2 Information Collected Automatically

Location Data

With your permission, we collect your device's precise location (GPS coordinates) to show you nearby matches and calculate distances. We also derive your city and state through reverse geocoding. If you use our Explore Mode feature, we track which cities you browse.

Device & Technical Information

• Device model, operating system, and version
• App version and build number
• IP address
• Push notification tokens (FCM/APNs)

Usage & Behavioral Data

• Swipe activity (likes, passes, super swipes)
• Match and messaging activity
• Feature usage (Spotlight, Explore Mode, Fan Club, etc.)
• Session frequency and last active timestamps
• Profile views given and received

Analytics & Crash Data

We use Firebase Analytics and Firebase Crashlytics to collect anonymized event data, session information, and crash reports to improve app stability and user experience.

2.3 Information from Third Parties

If you register using Google Sign-In, Apple Sign-In, or Facebook Login, we receive basic profile information (name, email) from those services to create your account.

3. How We Use Your Information

We use your information for the following purposes:

Core Service Delivery

• Create and manage your account and profile
• Display your profile to potential matches based on compatibility
• Calculate emotional readiness compatibility scores
• Enable messaging between matched users
• Facilitate date planning and venue suggestions
• Process and manage subscriptions and premium features

Matching & Discovery

• Show you relevant profiles based on your location, preferences, and readiness level
• Power Explore Mode to help you discover singles in nearby cities
• Recommend matches using compatibility algorithms based on your profile data, preferences, and behavioral patterns

Safety & Integrity

• Verify user identity through photo and ID verification
• Detect and prevent fraud, fake accounts, and policy violations
• Process user reports and enforce community guidelines
• Review messages in group circles and conversations, with or without a report, to keep members safe and enforce our community guidelines. Authorized members of our team may read these messages, and automated checks may scan message text for safety concerns.
• Manage blocking and restricting of users

Communication

• Send push notifications about new matches, messages, and app activity
• Deliver match expiration reminders and engagement prompts
• Communicate service updates and account-related notices

Improvement & Analytics

• Analyze usage patterns to improve features and user experience
• Monitor app performance, diagnose crashes, and fix bugs
• Conduct A/B testing for feature improvements via Firebase Remote Config
• Generate aggregated, anonymized insights about user behavior

Advertising

• We advertise The Transfer Portal on other sites and apps. We do not show ads inside the app
• Count how many installs our ads on Meta bring in, as described in Section 8 under Ad Measurement

4. How We Share Your Information

With Other Users

Your profile information (name, age, photos, bio, prompts, verification status, and general location) is visible to other users as part of the matching experience. Your emotional readiness score is used for matching purposes but is not displayed to other users in its exact form. Other users may see a general compatibility percentage.

With Service Providers

We share information with third-party service providers who help us operate, maintain, and improve the Service. These providers are contractually obligated to protect your data and use it only for the purposes we specify. See Section 5 for details.

For Legal Reasons

We may disclose your information if required to do so by law or in response to valid requests by public authorities (e.g., a court order, government request, or law enforcement inquiry). We may also share information when we believe in good faith that disclosure is necessary to protect our rights, your safety, or the safety of others.

Business Transfers

If The Transfer Portal is involved in a merger, acquisition, or sale of assets, your personal information may be transferred as part of that transaction. We will notify you before your information becomes subject to a different privacy policy.

With Your Consent

We may share your information for other purposes with your explicit consent.

5. Third-Party Services

We integrate with the following third-party services to operate The Transfer Portal:

Each third-party service operates under its own privacy policy. We encourage you to review their respective privacy policies for information on how they handle your data.

6. Data Storage & Security

Where Your Data Is Stored

Your data is stored on Google Cloud Platform servers (via Firebase) located in the United States. Some data may also be processed by third-party services in their respective data centers.

Security Measures

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

• Encryption in transit: All data transmitted between your device and our servers is encrypted using TLS/SSL
• Encryption at rest: Data stored in our databases is encrypted using Google-managed encryption keys
• Access controls: Firestore Security Rules enforce that users can only access their own data, match data for mutual matches, and public profile information
• Firebase App Check: Device verification prevents unauthorized API access
• Sensitive data encryption: Additional client-side encryption is applied to certain sensitive data fields

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

ID Document Security

If you submit a government ID for verification, the image is stored securely in Firebase Storage with restricted access. Only authorized administrators can view ID documents for manual verification purposes. ID images are not shared with other users or third parties.

7. Data Retention

We retain your personal information for as long as your account exists, whether active or deactivated, or as needed to provide you with our Service. Specific retention practices include:

• Profile data: Kept while your account is active or deactivated. A deactivated account keeps its data until you delete it, from the app or from our data deletion page
• Messages: Retained while the associated match or circle exists. You cannot delete a single message after you send it. Deleting your account deletes the messages you sent, and deletes your conversations with your matches
• Verification photos and ID documents: Retained while your account exists, including while it is deactivated, for ongoing verification purposes
• Analytics data: Retained per Firebase Analytics default retention periods (typically 2-14 months depending on data type)
• Crash reports: Retained for up to 90 days
• Location data: Only your most recent location is stored; historical location data is not retained

When you delete your account, we delete your profile, matches, conversations, photos and other personal data from our systems, with three exceptions. First, for 90 days we keep a small record: a one way hash of your email address, a one way hash of your phone number if you gave us one, whether we banned the account, the date you created it, and the state of any subscription when you deleted it. It holds no profile content. We use it to stop banned users from coming back, to spot abuse such as repeated account creation, and to answer billing questions, and we delete it after 90 days. Second, we keep safety reports that involve your account, whether you made them or someone made them about you, for one year after you delete it, then delete them. If the other person in a report deletes their account later, the year starts again from that later date. A report holds the reason and any details the reporter wrote. Some reports also hold the first name of the person reported. A report about a message also holds a copy of that message: its text, the original text if our moderation removed it, and a copy of any photo or voice note in it. We delete those copies with the report. We keep reports so that deleting an account, or our removal of a message, cannot erase what was reported. Third, we keep information the law requires us to keep, for example under a legal hold, and copies in routine backups until those expire. Apple, Google and our subscription provider keep their own payment records under their own policies.

8. Your Rights & Choices

Privacy Controls in the App

The Transfer Portal provides several in-app privacy controls:

• Hide your age: Prevent other users from seeing your age
• Hide your distance: Prevent other users from seeing how far away you are
• Hide last active status: Control whether others can see when you were last online
• Incognito mode: Browse profiles without appearing in other users' views (premium feature)
• Blocking: Block any user to prevent them from seeing your profile or contacting you

Your Data Rights

Depending on your jurisdiction, you may have the following rights regarding your personal information:

• Right to access: Request a copy of the personal data we hold about you
• Right to correction: Request correction of inaccurate personal data
• Right to deletion: Request deletion of your personal data (“right to be forgotten”)
• Right to data portability: Request a machine-readable copy of your data
• Right to restrict processing: Request that we limit how we use your data
• Right to object: Object to certain types of data processing
• Right to opt out of sale: We do not sell your personal information. If this changes, we will provide a clear opt-out mechanism

To exercise any of these rights, please contact us using the information in Section 13.

Account Deactivation

You can deactivate your account at any time from Settings in the app. Deactivating hides your profile from everyone and stops notifications, except any you chose to keep. We delete nothing. Your account and its data stay as they are until you open the app to reactivate it, or until you delete it. Deactivating does not cancel a subscription you bought through the App Store or Google Play. You cancel those in the store.

Account Deletion

You can delete your account at any time through the app's Settings page or by visiting our data deletion page. When you delete your account:

• Your profile is removed from discovery and is no longer visible to other users
• Your matches and conversations are removed
• Your personal data is deleted from our active systems
• Certain data may be retained for a limited period for safety, legal compliance, and fraud prevention purposes as described in Section 7
• Deleting your account does not cancel a subscription you bought through the App Store or Google Play. You cancel those in the store

Push Notifications

You can manage push notification preferences through your device's system settings. Disabling notifications will not affect other functionality of the Service.

Location Permissions

You can revoke location access at any time through your device settings. Note that disabling location services will affect our ability to show you nearby matches and calculate distances.

Ad Measurement

We use Meta as an install measurement partner. When you open the app, it can tell Meta that the app was opened, so Meta can count the installs that came from our ads on Facebook and Instagram. It sends basic device details such as the device model, system version and app version. It sends no advertising ID, and nothing from your profile, messages, matches or purchases. We do not use it to follow you across other companies' apps or websites.

You can turn this off in the app: go to Settings, then Privacy & Safety, then turn off Ad measurement. The change applies the next time the app fully restarts. There are no ads inside the app.

On iPhone, the Facebook software in the app also contacts Meta each time the app starts, even with Ad measurement turned off, to load its own settings. That request carries the app ID, the system and software version, and your IP address. It sends no advertising ID and no record of what you do in the app.

9. Children's Privacy

The Transfer Portal is intended for users aged 18 and older. We do not knowingly collect personal information from anyone under the age of 18. If we learn that we have collected personal information from a user under 18, we will take steps to delete that information as soon as possible. If you believe a user under 18 is using our Service, please contact us immediately.

10. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence, including the United States, where our servers and third-party service providers are located. These countries may have data protection laws that differ from those in your jurisdiction.

Your data is stored on Google Cloud Platform servers located in the United States. For transfers of personal data from the European Economic Area (EEA) and the United Kingdom (UK) to the United States, we rely on the following safeguards:

• EU-US Data Privacy Framework (DPF): Google LLC is certified under the EU-US Data Privacy Framework, providing an adequacy basis for EEA-to-US data transfers under GDPR Article 45.
• Standard Contractual Clauses (SCCs): As a supplementary safeguard, we also rely on Google's Data Processing Addendum, which incorporates SCCs approved by the European Commission under GDPR Article 46(2)(c).
• UK International Data Transfer Agreement (IDTA): For transfers from the UK, we rely on the UK Extension to the EU SCCs, as approved by the UK Information Commissioner's Office (ICO).

When we transfer your data internationally, we take steps to ensure that appropriate safeguards are in place to protect your information, in compliance with applicable data protection laws including the GDPR and UK GDPR.

For a list of third-party sub-processors that may process your personal data on our behalf, please see our Sub-Processors page.

11. Data Breach Notification

In the event of a personal data breach, we will comply with applicable data breach notification laws, including the General Data Protection Regulation (GDPR).

• Supervisory authority notification: Where a breach is likely to result in a risk to the rights and freedoms of individuals, we will notify the relevant supervisory authority without undue delay and, where feasible, within 72 hours of becoming aware of the breach, in accordance with GDPR Article 33.
• User notification: Where a breach is likely to result in a high risk to the rights and freedoms of individuals, we will notify affected users without undue delay, in accordance with GDPR Article 34. Notification will include the nature of the breach, likely consequences, and measures taken or proposed to address it.

If you believe your data has been compromised, please contact us immediately at privacy@thetransferportalapp.com.

12. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements. When we make material changes, we will:

• Update the “Last updated” date at the top of this page
• Notify you through the app or via email for significant changes
• Where required by law, obtain your consent before applying changes

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

13. Contact Us

If you have questions about this Privacy Policy, want to exercise your data rights, or have concerns about how your information is handled, please contact us:

We aim to respond to all data-related requests within 30 days. For users in the European Economic Area, you also have the right to lodge a complaint with your local data protection authority.

Additional Disclosures for California Residents

If you are a California resident, the California Consumer Privacy Act (CCPA) provides you with additional rights regarding your personal information:

• Right to know: You have the right to request information about the categories and specific pieces of personal information we have collected about you, the categories of sources, the business purpose for collecting your data, and the categories of third parties with whom we share it
• Right to delete: You have the right to request deletion of your personal information, subject to certain exceptions
• Right to non-discrimination: We will not discriminate against you for exercising your CCPA rights
• No sale of personal information: We do not sell your personal information as defined under the CCPA

To submit a CCPA request, please contact us at privacy@thetransferportalapp.com.

Additional Disclosures for EEA and UK Residents

If you are located in the European Economic Area (EEA) or the United Kingdom (UK), we process your personal data under the following legal bases:

• Contract: Processing necessary to provide our Service to you (account creation, matching, messaging, subscriptions)
• Consent: Processing based on your opt-in consent (e.g., location access, optional analytics, marketing communications)
• Legitimate interests: Processing for fraud prevention, safety, service improvement, and enforcing our terms, where our interests do not override your fundamental rights
• Legal obligation: Processing necessary to comply with applicable laws

You may withdraw your consent at any time where we rely on consent as our legal basis, without affecting the lawfulness of processing based on consent before its withdrawal.

Data Protection Officer

For any questions or concerns regarding the processing of your personal data under the GDPR, you may contact our Data Protection Officer at privacy@thetransferportalapp.com.

Your Rights Under GDPR (Articles 15–22)

As a data subject in the EEA, you are entitled to the rights set forth in GDPR Articles 15 through 22, including:

• Right of access (Article 15)
• Right to rectification (Article 16)
• Right to erasure / right to be forgotten (Article 17)
• Right to restriction of processing (Article 18)
• Right to data portability (Article 20)
• Right to object (Article 21)
• Right not to be subject to automated individual decision-making, including profiling (Article 22)

Right to Lodge a Complaint

If you believe that our processing of your personal data infringes the GDPR, you have the right to lodge a complaint with your local Data Protection Authority (DPA). A list of EEA DPAs is available on the European Data Protection Board website.