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.

b) Information collected automatically:

• Location Data: With your explicit device permission, we collect your precise geolocation to provide distance-based matchmaking and social features.
• Usage Data: Information about how you interact with the app, including game participation and feature usage.

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.

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: Upon deletion request, your profile is hidden immediately. We retain data for a 30-day grace period for safety investigations before permanent deletion.
• 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 Payment gateways (e.g., Stripe).

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.