Privacy Policy for U-Turnity

1. Information We Collect

We collect several types of information to provide and improve our Service:

a. Information You Provide Directly

• Account Registration Details: Name, email address, phone number (for verification), username, and password.
• Profile Information: Profile photos, bio, age, gender, and personal preferences or interest tags.
• Content You Upload: Text, photos, videos, comments, and messages sent within the app.
• User Reports & Feedback: Information provided when contacting support, reporting another user, or submitting safety feedback.

b. Location Data (Real-Time & Background)

Because U-Turnity is designed to facilitate spontaneous real-world encounters, location data is core to our Service:

• Precise GPS Location: With your permission, we collect your precise geographical location (GPS coordinates) while the app is in use (foreground).
• Background Location: If explicitly enabled in your device settings, we may collect location data in the background to alert you to nearby spontaneous encounters.
• Location Visibility: Nearby users will see your approximate distance or general vicinity (e.g., "500 meters away").

c. Information Collected Automatically

• Device & Technical Information: Device model, operating system version, unique device identifiers, IP address, mobile network information, and crash reports.
• Usage Data: Interactions within the app, features used, profiles viewed, encounter requests sent/accepted, and timestamps.
• Cookies and Tracking Technologies: Technologies used for session management and app analytics.

2. How We Use Your Information and Legal Bases (GDPR)

We process your personal data under the following legal bases:

3. Sharing Your Information

We do not sell your personal data. We only share information in the following circumstances:

• Other Users: Profile information, uploaded content, and approximate distance are visible to other users as part of the normal social networking functions.
• Service Providers & Sub-processors: We engage trusted third-party providers to assist with operations:
  • Hosting & Cloud Infrastructure: Cloud servers (e.g., Google Cloud / iCloud) for data storage and backups.
  • Authentication: SMS verification services (e.g., for EU/US phone verification).
  • Analytics & Performance: Analytics tools to measure app stability.
  • Content Safety & Moderation: Automated and human safety tech (including US-based providers) to scan for abusive or unsafe content.
• Third-Party Integrations: Optional in-app integrations (such as YouTube or map services) may receive necessary technical data (e.g., IP address, search queries) when you use those features.
• Law Enforcement & Legal Requests: We may disclose your information if required by law, subpoena, or government request, or to protect the rights, property, and physical safety of our users or the public.
• Business Transfers: In the event of a merger, acquisition, restructuring, or sale of assets, user data may be transferred as part of the transaction.

4. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes outlined in this policy, unless a longer retention period is required by law:

• Account Data: Retained for as long as your account is active. Upon account deletion, your profile data is permanently deleted or anonymized within 30 days.
• Real-Time Location History: Raw precise location logs are automatically overwritten or deleted after 72 hours, except where needed to investigate a reported safety incident.
• Communication Logs: Support requests and feedback are retained for up to 12 months after closure.

5. Your Rights and Choices (GDPR & Privacy Rights)

Depending on your jurisdiction (including the European Economic Area / UK), you have the following rights regarding your personal data:

• Right of Access: Request a copy of the personal data we hold about you.
• Right to Rectification: Request correction of inaccurate or incomplete data.
• Right to Erasure ("Right to be Forgotten"): Request the deletion of your account and associated personal data.
• Right to Restrict or Object to Processing: Object to processing based on legitimate interests or request processing restrictions.
• Right to Data Portability: Request a copy of your data in a structured, machine-readable format.
• Right to Withdraw Consent: Where processing is based on consent (e.g., location permissions, direct marketing), you may withdraw consent at any time through your device settings or app controls.

To exercise any of these rights, please contact us at hello@u-uturnity.com. You also have the right to lodge a complaint with your local Data Protection Authority.

6. Security & User Moderation

We implement appropriate technical and organizational safeguards (including encryption in transit and at rest, secure servers, and access controls) to protect your personal data.

Because U-Turnity facilitates physical real-world interactions:

• We employ both automated safety technology and human moderation to monitor and enforce our Community Guidelines.
• Users who engage in harassment, fake profiles, or unsafe behavior may be permanently banned.

Note: While we maintain strict technical safeguards, no internet transmission or electronic storage method is 100% secure, and absolute security cannot be guaranteed.

7. Age Requirement (Children's Privacy)

U-Turnity is strictly intended for individuals aged 18 and older. We do not knowingly collect or solicit personal information from anyone under the age of 18.

If we learn that we have inadvertently collected personal data from an individual under 18 years of age, we will immediately delete that information and terminate the associated account. If you believe a minor is using the app, please notify us immediately at hello@u-uturnity.com.

8. International Data Transfers

Your information may be transferred to, stored, and processed in countries outside your country of residence (including the United States and countries within the EU/EEA), where our cloud servers and third-party service providers operate.

When transferring data outside the European Economic Area (EEA), we ensure appropriate safeguards are in place, such as EU Standard Contractual Clauses (SCCs) or adequacy decisions, to ensure your data receives an equivalent level of protection.

9. Language and Governing Version

This Privacy Policy is provided in English. Where local laws require or for convenience, translated versions may be provided. In the event of any conflict or inconsistency between the English version and a translated version, the English version shall prevail to the extent permitted by applicable law.

10. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal obligations. We will notify you of any material changes by posting the updated policy within the app and updating the "Effective Date" at the top. Your continued use of the Service following such updates constitutes your acceptance of the revised policy.

11. Contact Us & Data Controller Information

The Data Controller responsible for processing your personal data is:

U-Turnity (Sole Proprietorship / Eenmanszaak)
Contact Email: hello@u-uturnity.com
Enterprise / Tax Number: 0696671816
Country of Establishment: Belgium

If you have questions, concerns, or requests regarding this Privacy Policy or your personal data, please reach out to us at the email address above.