BLUNDER Privacy Policy

Effective date: 6 November 2026 Data controller (Data Fiduciary): DONEBRO Media, (registered address to be published) ("we", "us") Contact / privacy requests: support@donebro.in Grievance Officer (India IT Rules 2021 / DPDP Act 2023): (name to be published), Grievance Officer · grievance@donebro.in (see our Grievance Redressal policy)

BLUNDER is a dating app for adults aged 18 and over. This policy explains what personal data we collect, why, who we share it with, and the rights you have. By creating an account you confirm you are at least 18.

1. Data we collect

Category	Examples	Source
Account data	Google account ID, email address, name, profile photo URL (via Google Sign-In; we never see your Google password)	You / Google
Profile data	Display name, date of birth, gender, who you want to meet, bio, prompts, interests, languages, height, lifestyle flags, relationship intent	You
Sensitive profile data	Gender identity, sexual orientation / who you are interested in, relationship intent. You choose whether to provide these.	You
Photos and verification	Profile photos, selfie for photo verification, verification result	You
Voice	Voice intro (up to 15 seconds) and voice notes in chat	You
Messages	Chat text, images, voice notes, read receipts, reactions	You
Approximate location	Coarse location (about a 500 m grid, never exact GPS) used for distance, discovery and "Crossed Paths". We do not request background location.	Your device (with permission)
Usage and interaction	Likes, passes, matches, swipes, profile views, streaks, filters, in-app settings	App
Purchase data	Subscription tier, purchase tokens, order IDs, product IDs, status. We do not receive your card details; Google Play processes payment.	Google Play
Device and technical	Device model, OS version, app version, language, IP address, advertising ID (if consent given), crash logs, push notification token	Device / SDKs
Safety data	Reports, blocks, moderation decisions, content flagged by automated or manual review	Users / us
Support data	Messages you send to support	You

2. Why we use your data and our legal bases

Purpose	Legal basis (GDPR / UK GDPR)
Create and run your account, show your profile, match you, deliver chat	Contract
Coarse-location discovery and Crossed Paths	Consent (device permission; withdraw any time)
Process subscriptions and consumables, prevent purchase fraud	Contract; legitimate interests
Photo/selfie verification, safety, moderation, fraud and abuse prevention, enforcing our Terms	Legitimate interests; legal obligation; for sensitive data, substantial public interest where applicable or explicit consent
Sensitive data (e.g., sexual orientation, interest preferences)	Explicit consent, given when you choose to provide it
Push notifications	Consent (OS permission) / legitimate interests for service notices
Analytics and crash reporting (Firebase)	Legitimate interests (service quality); consent where required by local law
Personalised or non-personalised ads (free tier)	Consent (via our consent prompt; see Cookie and Ads Consent)
Legal compliance, responding to authorities, child-safety reporting	Legal obligation; legitimate interests
Communicating service and policy changes	Contract; legitimate interests

We do not sell your personal data for money. We do not use your messages, photos or voice to train third-party AI models. We do not make decisions with legal effect about you solely by automated means; automated tools help flag content, and humans review enforcement decisions on request.

3. Who we share data with

Other users: your profile (name, age, photos, bio, approximate distance, prompts, verification badge) is visible to other users as your settings allow. Chat content is visible to the other participant.

Service providers (processors):

Provider	Purpose	Data
Google LLC / Google Ireland Ltd — Google Sign-In	Authentication	Google ID, email, name
Google — Firebase Cloud Messaging	Push notifications	Push token, device ID, message metadata
Google — Firebase Analytics	Usage analytics	App instance ID, events, device info
Google — Firebase Crashlytics	Crash reports	Crash logs, device info, installation ID
Google Play (Play Billing, Play Developer API)	Payments, purchase verification	Purchase tokens, order IDs, product IDs
Google AdMob	Ads on the free tier	Advertising ID, IP address, device info, ad interactions
Meta Platforms, Inc. / Meta Platforms Ireland Ltd — Audience Network (via AdMob mediation)	Ads on the free tier	Advertising ID, IP address, device info, ad interactions
Our web hosting provider	Hosting our servers, database, and media storage	All data we store
Our email provider	Support and grievance communications	Messages you send us

Ad partners act as independent controllers for their own ad purposes under their own policies. Where ads are personalised, this happens only with your consent in regions that require it.

Legal and safety: we may disclose data to law enforcement, regulators or courts where legally required, to protect someone's safety, or to report child sexual abuse and exploitation (CSAE) to authorities such as NCMEC or the competent local authority.

Business transfers: if we merge or are acquired, data may transfer under this policy's protections.

We do not share your messages or precise personal details with advertisers.

4. Retention

Data	Retention
Active account data	While your account is active
Deleted account: profile, photos, voice, messages, matches	Removed from live systems within 30 days of deletion; removed from backups within 90 days
Selfie verification image	Deleted after verification is decided, or within 30 days; the verified/not-verified result is kept while your account is active
Reports, blocks, safety and ban records	Up to 3 years after deletion to prevent ban evasion and protect users; longer if legally required or needed for an investigation
Purchase and tax records	As required by tax and accounting law (typically 7 years)
Server logs and IP addresses	Up to 90 days
Analytics and crash data	Per Google Firebase retention settings (14 months for analytics, 90 days for crash data)
Coarse location	Last known coarse location is kept only while your account is active; Crossed Paths records are deleted after 30 days

5. Your rights

Depending on where you live you may have the right to: access your data; correct it; delete it; restrict or object to processing; data portability; withdraw consent at any time; not be subject to solely automated decisions; and lodge a complaint with a regulator.

• EU / EEA / UK (GDPR, UK GDPR): all rights above. Complain to your local supervisory authority (in the UK, the ICO).
• California (CCPA/CPRA): rights to know, delete, correct, and opt out of "sale" or "sharing" for cross-context behavioural advertising, and to limit use of sensitive personal information. We do not sell data for money; ad SDKs may count as "sharing" for targeted ads under California law — you can opt out in Settings > Privacy > Ad choices. We will not discriminate against you for exercising rights. Categories collected in the last 12 months are listed in section 1; disclosed to the recipients in section 3.
• India (DPDP Act 2023): rights to access information, correct and erase data, nominate a person to exercise rights on death or incapacity, and grievance redressal. Contact our Grievance Officer at grievance@donebro.in (acknowledged within 24 hours, resolved within 15 days); if unresolved, you may approach the Data Protection Board of India.
• Brazil (LGPD): confirmation of processing, access, correction, anonymisation/blocking/deletion, portability, information on sharing, and revocation of consent. Contact our data protection contact above or the ANPD.

How to exercise rights: use in-app Settings > Privacy and Settings > Delete account, or email support@donebro.in. We may verify your identity and respond within 30 days (45 days under CCPA, extendable where law permits).

6. International transfers

We and our providers operate globally. Your data may be transferred to and processed in countries including India, the United States and Ireland/EU. Where required, we rely on safeguards such as Standard Contractual Clauses, the UK International Data Transfer Addendum, adequacy decisions, or the EU-US Data Privacy Framework (where the provider is certified). For India and Brazil, transfers are made in line with the DPDP Act and LGPD.

7. Security

Data in transit is encrypted with HTTPS/TLS. We use access controls, hashed/limited-lifetime tokens, rate limiting, and admin audit logs. No system is perfectly secure; tell us about concerns at support@donebro.in. We will notify you and regulators of breaches as required by law.

8. Children

BLUNDER is only for people aged 18 or older. We collect date of birth at sign-up and block under-18s. We do not knowingly collect data from anyone under 18. If we learn that an account belongs to a minor we will delete it. If you believe a minor is using BLUNDER, report it in-app or email support@donebro.in. See our Child Safety Standards.

9. Cookies and similar technologies

The app uses device identifiers and SDKs (not browser cookies) for ads, analytics and crash reporting. The website uses only essential cookies. See Cookie and Ads Consent.

10. Changes

We will post changes here and, for material changes, notify you in-app before they take effect.

11. Contact

DONEBRO Media is the data controller for BLUNDER.

• Registered address: (registered address to be published)
• Support and privacy requests: support@donebro.in
• Grievance Officer: (name to be published), Grievance Officer · grievance@donebro.in
• Business enquiries: media@donebro.in
• Website: https://donebro.in