Privacy Policy

1. Introduction & Scope

Persona Group ("Persona," "we," "our," or "us") operates the Persona - AI Dating mobile application and the website at persona-us.com (collectively, the "Service"). This Privacy Policy describes how we collect, use, disclose, and safeguard your personal information when you access or use our Service.

By creating an account or using the Service, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with the practices described herein, please do not use the Service.

This Policy applies to all users worldwide. If you reside in a jurisdiction with specific data protection requirements — such as the European Economic Area (EEA), United Kingdom, California, or other U.S. states with comprehensive privacy laws — please also review the jurisdiction-specific sections below.

2. Data Controller

For the purposes of the EU General Data Protection Regulation (GDPR), the UK GDPR, and other applicable data protection legislation, the data controller is:

3. Information We Collect

3.1 Information You Provide Directly

• Account & Registration Data: Name, email address, date of birth, and authentication credentials. If you sign in with Apple, we receive only the identifiers Apple shares (name and email, which may be a private relay address).
• Profile Data: Photos you upload, biography text, gender identity, sexual orientation, relationship goals, interests, education, occupation, and location preferences.
• Personality Quiz Responses: Answers to our structured personality assessment, which are processed on-device to build your OCEAN (Big Five) personality profile. Raw responses are not transmitted to our servers.
• Communications: Messages you send to other users through the in-app chat, voice notes you record, and reports or feedback you submit.
• Payment Information: If you subscribe to Persona Premium, payment is processed by Apple via StoreKit 2. We receive a transaction receipt and entitlement status — we do not receive or store your credit card number, Apple Pay credentials, or banking details.
• Support Inquiries: Emails, in-app support requests, and any attachments you provide when contacting us.

3.2 Information Collected Automatically

• Device Information: Device model, operating system version, unique device identifiers (IDFV), app version, and device language/locale.
• Usage Data: Screens visited, features used, session duration, interaction events (e.g., swipes, taps), and app performance data.
• Log Data: IP address (truncated/anonymized), access timestamps, referral URL (if arriving from the web), and error/crash logs.
• Location Data: With your explicit permission (iOS location prompt), we collect approximate location (city-level) to enable proximity-based matching. We never share your precise location with other users.
• Push Notification Tokens: Apple Push Notification service (APNs) device tokens, stored to deliver notifications. Tokens are removed when you disable notifications or delete your account.

3.3 Information from Third Parties

• Sign in with Apple: If you authenticate using Sign in with Apple, Apple provides your name (if you choose to share it) and email (or a private relay email).
• App Store / StoreKit: Apple provides subscription status, transaction IDs, and entitlement data for in-app purchases.

4. Legal Bases for Processing (GDPR Art. 6)

Where GDPR or equivalent regulation applies, we process your data on the following legal bases:

• Performance of Contract (Art. 6(1)(b)): Processing necessary to provide you with the Service — account creation, profile matching, messaging, and delivering personality insights.
• Consent (Art. 6(1)(a)): Location data collection, push notifications, photo/camera access, microphone access, and optional marketing communications. You may withdraw consent at any time.
• Legitimate Interests (Art. 6(1)(f)): Fraud prevention, security monitoring, analytics to improve our Service, and enforcing our Terms of Service. We have conducted balancing tests to ensure these interests do not override your fundamental rights.
• Legal Obligation (Art. 6(1)(c)): Complying with applicable laws, responding to lawful requests from public authorities, and retaining records as required by financial or tax regulations.
• Vital Interests (Art. 6(1)(d)): In rare cases, processing necessary to protect the vital interests of a user (e.g., emergency safety situations reported through the app).

For special categories of personal data (e.g., sexual orientation, gender identity) that you voluntarily provide in your profile, we rely on your explicit consent (Art. 9(2)(a)). You may remove this data at any time by editing your profile.

5. How We Use Your Information

• Provide the Service: Create and manage your account, generate your personality profile, calculate compatibility scores, facilitate matches and conversations, and process subscriptions.
• Personalization: Tailor your match recommendations based on personality compatibility, preferences, and activity patterns.
• Communications: Send transactional notifications (new matches, messages, connection reveals), account-related emails (password resets, security alerts), and, with your consent, marketing communications.
• Safety & Integrity: Detect and prevent fraud, spam, harassment, and violations of our Terms and Community Guidelines. Review reports submitted by users. Cooperate with law enforcement when legally required.
• Analytics & Improvement: Analyze aggregated, de-identified usage patterns to improve app performance, fix bugs, develop new features, and enhance the matching algorithm.
• Legal Compliance: Fulfill legal obligations, resolve disputes, and enforce our agreements.

6. AI & On-Device Processing

Here is what our on-device AI does:

• Personality Analysis: Processes your quiz responses to compute scores across five personality dimensions (Openness, Conscientiousness, Extraversion, Agreeableness, Neuroticism).
• Compatibility Scoring: Compares your personality profile with potential matches to generate compatibility percentages. The comparison algorithm runs on-device.
• Conversation Insights: Your Wingman AI assistant analyzes conversation patterns locally to provide communication tips.

What is stored on our servers: Only your computed personality dimension scores (numerical values, 0.0–1.0) are synced to our database for matching purposes. Raw quiz responses and the AI model's intermediate computations remain on your device.

Automated Decision-Making (GDPR Art. 22): Our matching algorithm makes automated suggestions but does not produce legal or similarly significant effects. You always decide whom to connect with. You have the right to request human review of any automated matching decision by contacting us.

7. Data Sharing & Disclosure

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

7.1 With Other Users

Your public profile — including your name, photos, bio, age, and personality traits you choose to reveal — is visible to other users for matching purposes. Messages are shared only with the specific user you are chatting with.

7.2 Service Providers

We use a limited number of service providers, each bound by data processing agreements (DPAs):

• Supabase (database & authentication): Hosted on AWS in us-east-1. Provides database storage, authentication, real-time subscriptions, and file storage. Subject to Supabase's DPA and SOC 2 Type II compliance.
• Apple (App Store, StoreKit, APNs, crash reporting): Processes subscription transactions, delivers push notifications, and collects crash reports. Subject to Apple's Privacy Policy and DPA.
• Railway (web hosting): Hosts our static landing page and documentation. Does not process user personal data from the app.

7.3 Legal Requirements

We may disclose your data when we believe in good faith that disclosure is necessary to:

• Comply with a legal obligation, subpoena, court order, or enforceable governmental request;
• Protect the safety of any person, including preventing imminent harm;
• Investigate or prevent fraud, security incidents, or violations of our Terms;
• Protect the rights, property, or safety of Persona Group.

7.4 Business Transfers

If Persona Group is involved in a merger, acquisition, reorganization, or sale of assets, your personal data may be transferred as part of that transaction. We will notify you of any such change in ownership or control via the app or email.

8. Cookies & Tracking Technologies

Mobile App: Persona does not use traditional browser cookies. We use standard iOS storage mechanisms:

• UserDefaults: Stores non-sensitive preferences (notification settings, theme selection, onboarding completion status). Data remains on-device.
• Keychain: Securely stores authentication tokens using Apple's encrypted Keychain Services.
• Core Data / Local Files: Caches data for offline functionality. Cleared when you delete the app.

Website (persona-us.com): Our landing page uses localStorage to remember waitlist sign-up status. We do not use third-party tracking cookies, advertising pixels, or analytics services on our website. For more details, see our Cookie & Data Policy.

App Tracking Transparency (ATT): Persona does not track you across other companies' apps and websites. We do not request ATT permission because we do not engage in cross-app tracking as defined by Apple.

9. Data Storage & Security

We implement industry-standard technical and organizational measures to protect your data:

• Encryption in Transit: All data transmitted between the app and our servers uses TLS 1.3 encryption.
• Encryption at Rest: Database storage on Supabase (AWS) uses AES-256 encryption at rest.
• Row Level Security (RLS): PostgreSQL Row Level Security policies ensure users can only access their own data at the database level.
• Authentication: Secure token-based authentication via Supabase Auth. Tokens are rotated regularly and stored in the iOS Keychain.
• On-Device Encryption: Sensitive local data (biometric lock settings, cached credentials) is protected by Apple's Data Protection framework and AES-GCM encryption.
• Access Controls: Internal access to user data is restricted to essential personnel, with role-based access controls and audit logging.
• Incident Response: We maintain a data breach response plan. In the event of a breach affecting your personal data, we will notify you and relevant authorities within 72 hours as required by GDPR (or sooner if applicable law requires).

10. Data Retention Schedule

We retain your data only as long as necessary for the purposes described in this Policy:

11. Your Rights & Choices

Regardless of where you reside, we provide all users with the following rights:

• Access: Request a copy of the personal data we hold about you.
• Correction: Update or correct inaccurate information through your profile settings or by contacting us.
• Deletion: Delete your account and all associated data via Settings → Delete Account. You may also email us at privacy@persona-us.com.
• Portability: Request a machine-readable export of your data (profile, messages, personality scores).
• Withdraw Consent: Revoke consent for optional data processing (location, notifications, marketing) at any time through iOS Settings or in-app preferences.
• Restrict Processing: Request that we limit how we process your data in certain circumstances.
• Object to Processing: Object to processing based on legitimate interests.
• Non-Discrimination: We will not discriminate against you for exercising any of your privacy rights.

How to exercise your rights: Email privacy@persona-us.com with the subject line "Privacy Rights Request." We will verify your identity and respond within 30 days (or sooner if required by applicable law). You may also submit requests through Settings → Privacy in the app.

12. GDPR — European Users

If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, you have additional rights under the General Data Protection Regulation:

• Right to Lodge a Complaint: You have the right to lodge a complaint with your local Data Protection Authority (DPA). A list of EEA DPAs is available at edpb.europa.eu.
• Right to Object (Art. 21): You may object to processing based on legitimate interests at any time. We will cease processing unless we demonstrate compelling legitimate grounds.
• Right to Erasure (Art. 17): Request deletion of your data, subject to legal retention obligations.
• Automated Decision-Making (Art. 22): You have the right not to be subject to decisions based solely on automated processing that produce legal or similarly significant effects. Our matching algorithm is a recommendation tool — you always make the final decision to connect.
• Data Portability (Art. 20): Receive your personal data in a structured, commonly used, machine-readable format (JSON).

Data Protection Officer: You may contact our DPO at dpo@persona-us.com for any GDPR-related inquiries.

Legal Basis Summary: See Section 4 above. For special categories of data (sexual orientation, gender identity), we rely on your explicit consent per Art. 9(2)(a) GDPR.

13. CCPA / CPRA — California Users

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA):

Categories of Personal Information Collected (Cal. Civ. Code § 1798.100)

• Identifiers: Name, email, IDFV, IP address, APNs token
• Personal Information (§ 1798.80(e)): Name, date of birth, photos
• Characteristics of Protected Classifications: Age, gender identity, sexual orientation (voluntarily provided)
• Internet / Electronic Activity: App usage data, screens visited, session data
• Geolocation Data: Approximate location (with consent)
• Sensory Data: Photos, voice notes (with consent)
• Inferences: Personality profile scores, compatibility scores
• Sensitive Personal Information: Sexual orientation, precise geolocation (both with explicit consent)

Your CCPA/CPRA Rights

• Right to Know: Request the categories and specific pieces of personal information we have collected about you in the preceding 12 months.
• Right to Delete: Request deletion of your personal information, subject to legal exceptions.
• Right to Correct: Request correction of inaccurate personal information.
• Right to Opt-Out of Sale/Sharing: We do not sell your personal information. We do not share your personal information for cross-context behavioral advertising.
• Right to Limit Use of Sensitive Personal Information: You may request that we limit use of sensitive personal information to what is necessary to provide the Service.
• Right to Non-Discrimination: We will not deny services, charge different prices, or provide a different quality of service because you exercise your CCPA/CPRA rights.

Authorized Agents: You may designate an authorized agent to exercise your rights on your behalf. The agent must provide signed written authorization and we may verify your identity directly.

Verification: We will verify your identity by matching information you provide with data in our records. For deletion requests, we may require re-authentication.

Financial Incentives: We do not offer financial incentives for the collection or retention of personal information.

Contact for CCPA requests: privacy@persona-us.com with the subject "CCPA Request." We will respond within 45 days.

14. Other U.S. State Privacy Laws

We also respect privacy rights under comprehensive state privacy laws, including but not limited to:

• Virginia (VCDPA): Virginia residents have rights to access, correct, delete, and obtain a copy of personal data, and to opt out of targeted advertising, sale of personal data, and profiling. Appeal denied requests by emailing privacy@persona-us.com with "VCDPA Appeal."
• Colorado (CPA): Colorado residents have similar rights to access, correct, delete, port data, and opt out of targeted advertising, sale, and profiling.
• Connecticut (CTDPA): Connecticut residents may exercise rights to access, correct, delete, obtain data, and opt out of sale, targeted advertising, and profiling.
• Utah (UCPA): Utah residents have rights to access, delete, and obtain a copy of personal data, and to opt out of the sale of personal data and targeted advertising.
• Texas (TDPSA), Oregon (OCPA), Montana (MCDPA), and others: Residents of states with enacted comprehensive privacy laws may exercise applicable rights by contacting us.

CalOPPA Compliance: In accordance with the California Online Privacy Protection Act, we will notify users of material changes to this policy, honor Do Not Track browser signals to the extent technically feasible, and allow users to review and change personal information by logging into their account.

15. International Data Transfers

Your personal data is primarily stored in the United States (AWS us-east-1 via Supabase). If you are located outside the United States, your data will be transferred to and processed in the US.

For transfers from the EEA/UK/Switzerland to the US, we rely on:

• Standard Contractual Clauses (SCCs): Our data processing agreements with sub-processors include the European Commission's Standard Contractual Clauses (2021 version) as the primary transfer mechanism.
• EU-U.S. Data Privacy Framework: Where applicable, we rely on our service providers' certifications under the EU-U.S. Data Privacy Framework.
• Supplementary Measures: We implement technical safeguards (encryption in transit and at rest, pseudonymization) and organizational measures (access controls, DPAs) to ensure an adequate level of protection.

16. Children's Privacy

Persona is rated 17+ on the App Store and is intended exclusively for adults. We do not knowingly collect, solicit, or maintain personal information from anyone under 17 years of age.

If you are a parent or guardian and believe that your child has provided us with personal information, please contact us immediately at privacy@persona-us.com. We will take prompt steps to delete the information.

COPPA: In compliance with the Children's Online Privacy Protection Act, if we discover that we have inadvertently collected information from a child under 13, we will delete such information without delay.

17. Biometric & Sensitive Data

Biometric Authentication: Persona supports Face ID and Touch ID for optional biometric app locking. This biometric processing is handled entirely by Apple's LocalAuthentication framework on your device. We never receive, store, or transmit your biometric data (facial geometry, fingerprint data). Apple does not share biometric data with any app.

Sensitive Personal Information: If you voluntarily provide sensitive data in your profile (e.g., sexual orientation, gender identity), it is stored in our database solely for matching purposes and displayed only to potential matches. You may remove this data at any time by editing your profile.

Illinois BIPA Compliance: We do not collect, capture, purchase, or otherwise obtain biometric identifiers or biometric information as defined under the Illinois Biometric Information Privacy Act (BIPA).

18. Third-Party Services

Our Service integrates with a limited number of third-party services. Each operates under its own privacy policy:

• Supabase: supabase.com/privacy — Database, authentication, real-time, storage.
• Apple: apple.com/legal/privacy — App Store, StoreKit, APNs, Sign in with Apple, crash reporting.

We do not integrate with third-party advertising networks, social media trackers, or analytics platforms (no Google Analytics, no Facebook SDK, no Firebase, no Amplitude).

19. Changes to This Policy

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

• We will update the "Last Updated" date at the top of this page.
• We will notify you via an in-app notification or email before the changes take effect.
• For material changes to data processing, we will seek your renewed consent where required by law.

We encourage you to review this Policy periodically. Your continued use of the Service after changes are posted constitutes acceptance of the updated Policy.

20. Contact & Data Protection Officer

If you have questions, concerns, or wish to exercise your privacy rights: