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 designed for divorced and separated singles. 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
• 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)
• 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
• Voice and video call metadata (duration, type, initiation time - not call content)

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, voice calls, and video calls 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
• 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

• Display ads to free-tier users through Google AdMob
• Measure ad performance and attribution

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 is active or as needed to provide you with our Service. Specific retention practices include:

• Profile data: Retained while your account is active and deleted upon account deletion request
• Messages: Retained while the associated match exists. Individual messages can be deleted by users
• Verification photos and ID documents: Retained while your account is active 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

After you delete your account, we may retain certain information for a limited period as necessary to comply with legal obligations, resolve disputes, enforce our agreements, or for legitimate safety and moderation purposes (e.g., preventing banned users from creating new accounts).

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)
• Call settings: Choose whether to allow voice calls, video calls, or require call approval
• 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 12.

Account Deletion

You can delete your account at any time through the app's Settings 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

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 Preferences

You can manage ad personalization through your device's advertising settings (e.g., “Limit Ad Tracking” on iOS or “Opt Out of Ads Personalization” on Android). You may also subscribe to a premium plan to remove ads entirely.

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.

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.

11. 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.

12. 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@thetransferportal.com.

Additional Disclosures for EEA Residents

If you are located in the European Economic Area (EEA), 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.