Privacy Policy

1. Introduction

Welcome to Pairwise. This Privacy Policy explains how Spectrumwise LTD ("we", "us", or "our") collects, uses, and protects your personal information. Under the UK General Data Protection Regulation (UK GDPR), Spectrumwise LTD is the Data Controller of your personal data.

2. Information We Collect

a) Information you provide to us directly:

• Account Registration: Name, Date of Birth (to verify you are over 18), Nationality, and Profession.
• Profile Content: Your personal interests and up to 4 photographs (1 profile picture, 3 account photos) used to facilitate social interactions and gameplay.
• Verification Data: A real-time photo mimicking a specific gesture to verify your identity against your profile pictures.
• Identity Verification Documents: In specific cases where age or identity verification is required to maintain platform safety, we may request a copy of a government-issued ID. This data is strictly used for verification purposes, reviewed securely, and deleted immediately after the validation process is complete, in accordance with our data retention policies.

b) Information collected automatically:

• Location Data: With your explicit device permission, we collect your precise geolocation to provide proximity-based social features and interactive connectivity.
• Usage Data: Information about how you interact with the app, including game participation and feature usage.
• Device & Diagnostic Data:We automatically collect technical information such as your device model, operating system, IP address, and crash reports to identify bugs, ensure platform stability, and improve app performance.

c) Virtual Currency and Transaction Data:

• Balance and Usage: We track your "Stars" balance, including the allocation of Basic, Gift, and Purchased stars.
• Activity Logging: We record your daily logins and participation in promotional events to calculate and award Gift Stars.
• Transaction History: We maintain a ledger of how and when your Stars are spent or expired to resolve disputes and ensure the correct deduction order.

d) Device Permissions & Hardware Data:

• Camera and Microphone: With your explicit permission, we access your device's camera and microphone to enable real-time video and audio calls, as well as voice message recording. Please note that live video and audio streams are processed securely in real-time and are not recorded or stored on our servers. Voice messages are stored securely to deliver them to your chat partner.
• Photo Gallery / Storage: With your permission, we access your device's photo library to allow you to upload profile pictures and send images within chat messages. We only access the specific images you choose to upload.

3. How We Use Your Information

We use your data based on the following legal grounds:

• Contractual Necessity: To provide our service, including account creation, profile display, and interactive modules.
• Legitimate Interest: To ensure platform safety, moderate content, and prevent fraud.
• Consent: For accessing device location services, which you can revoke at any time.

4. Data Retention

We retain your personal information only for as long as necessary:

• Active Accounts: Profile data is kept as long as your account is active.
• Chat Messages: All routine chat messages are automatically and permanently deleted from our servers 3 months after they are created.
• Account Deletion: You can delete your account at any time directly through the app by navigating to your profile settings and selecting the "Delete My Account" button located in the "Danger Zone". Upon initiation, your profile will be hidden immediately. We retain your data for a 30-day grace period, during which you can restore your account by simply logging in again. After this 30-day period, your account and all associated personal data (including photos, messages, and connections) will be permanently erased. Please note that certain transactional records will be retained for 6 years to comply with applicable UK tax laws. If you encounter any issues, you may also request deletion by contacting our support team at support@trypairwise.com
• Legal Compliance: Transactional records are kept for 6 years to comply with UK tax laws.

5. Data Sharing

We do not sell your personal data. We share information only with trusted service providers necessary for operation, such as Cloud hosting providers, App distribution platforms (Apple App Store / Google Play), and authorized payment processors (e.g., CCBill).

6. Your Rights (UK GDPR)

You have the right to access, rectify, or erase your data, and to object to or restrict processing. To exercise these rights, please contact our privacy team.

7. Children's Privacy

Our service is strictly intended for individuals aged 18 and older. We do not knowingly collect personal information from anyone under the age of 18. If we become aware that a user is under 18, we will immediately terminate their account and delete their personal data.