Privacy Policy

1. Overview

This Privacy Policy explains how Trivmo ("we," "us," "our"), operated by QNeesh, LLC, a Delaware limited liability company, collects, uses, shares, retains, and protects your personal information when you use our mobile applications, website, and services (collectively, the "Services"). This Policy applies to all users worldwide.

We are committed to protecting your privacy and handling your data in compliance with applicable data protection laws, including the EU General Data Protection Regulation (GDPR), UK GDPR, California Consumer Privacy Act / California Privacy Rights Act (CCPA/CPRA), Brazil's Lei Geral de Proteção de Dados (LGPD), and other applicable privacy regulations.

Data Controller: QNeesh, LLC is the data controller responsible for your personal data. For privacy inquiries, contact us at privacy@trivmo.com.

2. Information We Collect

2.1 Information You Provide

• Account & Profile Data: Name, email address, phone number, date of birth, gender, sexual orientation, relationship preferences, religion (if provided), ethnicity (if provided), photos, bio, interests, and other profile details you choose to share.
• Verification Data: Photos, selfies, or videos submitted for identity or photo verification, which may include facial geometry and biometric identifiers.
• Communications: Messages you send to other users through the Services, and messages, reports, or feedback you send to us.
• Payment Information: Processed by third-party payment providers (Apple, Google, Stripe). We receive limited billing metadata (subscription status, transaction IDs, purchase dates) but do not store full credit card numbers.
• Survey & Research Data: Responses to optional surveys, questionnaires, or research programs you choose to participate in.

2.2 Information Collected Automatically

• Device Information: Device type, operating system, unique device identifiers (e.g., advertising ID, device ID), app version, language settings, and mobile carrier.
• Usage Data: Features used, actions taken, timestamps, frequency and duration of activity, search queries, and interaction patterns.
• Log Data: IP address, access dates and times, browser type (for web), referring URLs, pages viewed, and crash reports.
• Location Data: With your permission, we collect approximate location (city-level or neighborhood-level) for proximity-based matching. We do not share your exact GPS coordinates with other users. You may disable location services at any time through your device settings.
• Cookies & Similar Technologies: On our website, we use cookies, pixels, and similar tracking technologies. See Section 12 (Cookies & Tracking Technologies) for details.

2.3 Information from Third Parties

• Social Login: If you register or log in using a third-party service (e.g., Apple, Google, Facebook), we receive basic profile information as authorized by you and that service.
• App Store Data: Transaction and subscription data from Apple App Store and Google Play Store.
• Analytics Providers: Aggregated and anonymized analytics data from third-party analytics services.

3. Special Category / Sensitive Data

Some information we collect may be considered "special category data" or "sensitive personal information" under applicable law, including:

• Sexual orientation and relationship preferences
• Religious beliefs (if you choose to provide them)
• Racial or ethnic origin (if you choose to provide them)
• Biometric data (facial geometry from photo verification)

Legal Basis (GDPR Article 9): We process special category data based on your explicit consent, which you provide when you voluntarily add this information to your profile or use verification features. You may withdraw this consent at any time (see Section 7).

We use this data solely to provide core Service features (matching, discovery, verification) and never for purposes incompatible with those stated here.

4. Legal Basis for Processing (GDPR / UK GDPR)

We process your personal data on the following legal bases:

Purpose	Legal Basis
Creating and managing your account	Performance of a contract (Terms of Service)
Providing matching and discovery features	Performance of a contract
Processing sexual orientation, religion, ethnicity	Explicit consent (GDPR Article 9(2)(a))
Biometric / photo verification	Explicit consent (GDPR Article 9(2)(a))
Location-based matching	Consent (revocable via device settings)
Platform safety, fraud prevention, abuse detection	Legitimate interest
Improving and developing the Services	Legitimate interest
Analytics (aggregated/anonymized)	Legitimate interest
Marketing communications	Consent (where required) or legitimate interest
Compliance with legal obligations	Legal obligation
Responding to law enforcement requests	Legal obligation or legitimate interest

Where we rely on legitimate interest, we have conducted a balancing test to ensure our interests do not override your fundamental rights and freedoms. You may request details of these assessments by contacting privacy@trivmo.com.

5. How We Use Your Information

• Provide the Services: Create your account, display your profile, provide matching and discovery features, facilitate messaging, and process transactions.
• Personalize Your Experience: Customize suggestions, content, and recommendations based on your preferences, activity, and interactions.
• Safety & Security: Detect, prevent, and investigate fraud, abuse, harassment, policy violations, and safety risks. Verify user identity through photo verification.
• Communications: Send you service-related messages (security alerts, account notifications, support responses), and, where you have opted in, marketing communications.
• Analytics & Improvement: Analyze usage patterns (in aggregated and anonymized form) to improve the Services, develop new features, and fix bugs.
• Legal Compliance: Comply with applicable laws, regulations, legal processes, and law enforcement requests.

6. Automated Decision-Making & Profiling

We use algorithms and automated systems to:

• Match suggestions: Our matching algorithm analyzes your preferences, activity, location, and profile information to suggest compatible users.
• Content moderation: Automated tools may flag or remove content that violates our Terms, including inappropriate photos or messages.
• Fraud & safety detection: Automated systems may flag accounts or behaviors that indicate fraud, spam, or abuse.

These automated processes may produce legal or similarly significant effects (e.g., account suspension). Under GDPR Article 22, you have the right to:

• Request human review of any significant automated decision affecting you.
• Express your point of view and contest the decision.
• Obtain an explanation of the logic involved (to the extent possible without compromising platform security).

To exercise these rights, contact privacy@trivmo.com.

7. Your Rights

Depending on your location, you may have the following rights regarding your personal data:

7.1 Rights for All Users

• Access: Request a copy of the personal data we hold about you.
• Correction: Update or correct inaccurate personal data via your profile settings or by contacting us.
• Deletion: Request deletion of your account and personal data. You can initiate this through account settings or by contacting support@trivmo.com.
• Opt-out of Marketing: Unsubscribe from marketing emails via the link in each email, or adjust notification preferences in the app.
• Withdraw Consent: Where processing is based on consent, you may withdraw it at any time. Withdrawal does not affect the lawfulness of prior processing.

7.2 Additional Rights Under GDPR / UK GDPR (EU/EEA/UK Users)

• Right to Restriction: Request that we restrict processing of your data in certain circumstances.
• Right to Data Portability: Receive your personal data in a structured, commonly used, machine-readable format and transmit it to another controller.
• Right to Object: Object to processing based on legitimate interests, including profiling. We will cease processing unless we demonstrate compelling legitimate grounds.
• Right Regarding Automated Decisions: Not be subject to decisions based solely on automated processing that produce legal or significant effects (see Section 6).
• Right to Lodge a Complaint: Lodge a complaint with your local data protection supervisory authority. For the UK, this is the Information Commissioner's Office (ICO) at ico.org.uk.

7.3 Additional Rights Under CCPA / CPRA (California Residents)

• Right to Know: Request disclosure of the categories and specific pieces of personal information we have collected, the sources, the business purposes, and the categories of third parties with whom we share it.
• Right to Delete: Request deletion of your personal information, subject to certain 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 share limited data with analytics providers in aggregated/anonymized form. If this changes, we will provide a "Do Not Sell or Share My Personal Information" link and update this Policy.
• Right to Non-Discrimination: We will not discriminate against you for exercising your CCPA/CPRA rights.
• Right to Limit Use of Sensitive Personal Information: You may request that we limit our use of sensitive personal information to what is necessary to provide the Services.
• Authorized Agent: You may designate an authorized agent to submit requests on your behalf, subject to verification.

Categories of Personal Information Collected (CCPA): Identifiers; personal information under Cal. Civ. Code 1798.80(e); characteristics of protected classifications; commercial information; internet or electronic network activity; geolocation data; sensory data (photos/videos); inferences drawn from the above. We collect these categories for the purposes described in Section 5.

7.4 Additional Rights Under LGPD (Brazil)

• Confirmation of the existence of processing.
• Access to your data.
• Correction of incomplete, inaccurate, or outdated data.
• Anonymization, blocking, or deletion of unnecessary or excessive data.
• Data portability to another service provider.
• Deletion of personal data processed with your consent.
• Information about public and private entities with which we have shared data.
• Information about the possibility of denying consent and the consequences thereof.
• Revocation of consent.

7.5 How to Exercise Your Rights

To exercise any of these rights, contact us at privacy@trivmo.com. We will respond within the timeframes required by applicable law (generally 30 days for GDPR, 45 days for CCPA). We may need to verify your identity before processing your request.

8. Sharing & Disclosure

• With Other Users: Profile information you choose to share (name, photos, bio, age, preferences). We never share your exact location, email address, phone number, or payment details with other users unless you voluntarily disclose them.
• Service Providers: Cloud hosting (e.g., AWS, Google Cloud), analytics providers, customer support tools, payment processors, email/notification services, and content moderation services. All service providers are bound by contractual obligations that provide at least the same level of data protection as this Policy, including Data Processing Agreements (DPAs) where required by GDPR.
• Safety & Compliance: To investigate and address abuse, fraud, safety risks, or violations of our Terms; and as required by applicable law, regulation, legal process, or enforceable governmental request.
• Business Transfers: In connection with a merger, acquisition, reorganization, bankruptcy, or sale of all or substantially all of our assets, your data may be transferred to the successor entity, subject to this Policy. We will notify you of any such transfer.
• With Your Consent: We may share your information for purposes not described here only with your explicit consent.

We do not sell your personal information. We share limited, aggregated, and anonymized data with analytics providers solely to improve the Services.

9. International Data Transfers

QNeesh, LLC is based in the United States. Your personal data may be transferred to and processed in the United States and other countries where our service providers operate, which may have data protection laws that differ from your country of residence.

For transfers of personal data from the EU/EEA, UK, or other jurisdictions that require transfer safeguards, we use the following mechanisms:

• Standard Contractual Clauses (SCCs): We use the European Commission's Standard Contractual Clauses (and the UK International Data Transfer Addendum, where applicable) in our agreements with service providers located outside the EU/EEA/UK.
• Adequacy Decisions: Where applicable, we may rely on adequacy decisions issued by the European Commission or UK Secretary of State.
• Supplementary Measures: We implement additional technical and organizational measures (encryption, access controls, data minimization) to ensure an adequate level of protection.

You may request a copy of the safeguards we use by contacting privacy@trivmo.com.

10. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes described in this Policy or as required by law. Specific retention periods:

Data Type	Retention Period
Account & profile data	Duration of account + 30 days after deletion request
Messages	Duration of account + 30 days after deletion request
Biometric / verification data	Up to 3 years after last interaction or until account deletion (within 30 days), whichever is sooner
Usage & log data	90 days (anonymized/aggregated data may be retained longer)
Device identifiers	Duration of account + 30 days after deletion request
Payment metadata	As required by tax and financial regulations (typically 7 years)
Safety & fraud records	Up to 5 years after account termination (for banned accounts and fraud prevention)
Legal hold data	Duration of legal proceeding or investigation

After the applicable retention period, data is permanently deleted or irreversibly anonymized.

11. Security

We implement robust technical and organizational measures to protect your personal data, including:

• Encryption of data in transit (TLS/SSL) and at rest (AES-256 or equivalent).
• Access controls and authentication for internal systems (principle of least privilege).
• Regular security assessments, penetration testing, and vulnerability scanning.
• Employee training on data protection and security best practices.
• Monitoring and logging of access to personal data.
• Incident response procedures for detecting, reporting, and responding to data breaches.

No system is 100% secure. While we strive to protect your data, we cannot guarantee absolute security. Please use strong passwords and exercise caution when sharing personal information.

12. Cookies & Tracking Technologies

Our website uses cookies and similar technologies to enhance your experience and analyze usage. Types of cookies we use:

• Strictly Necessary Cookies: Required for the website to function (e.g., session management, security). These cannot be disabled.
• Analytics Cookies: Help us understand how visitors use our website by collecting aggregated, anonymized data (e.g., pages visited, time on site). We use these to improve our Services.
• Functional Cookies: Remember your preferences (e.g., language, region) to provide a personalized experience.

We do not use advertising or targeted marketing cookies.

Your Choices: You can manage cookie preferences through your browser settings. Disabling certain cookies may affect the functionality of our website. For users in the EU/EEA/UK, we will obtain your consent before setting non-essential cookies, in compliance with the ePrivacy Directive.

13. Data Breach Notification

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will:

• Notify the relevant supervisory authority within 72 hours of becoming aware of the breach, as required by GDPR Article 33.
• Notify affected users without undue delay where the breach is likely to result in a high risk to your rights and freedoms, as required by GDPR Article 34.
• Comply with all applicable data breach notification laws in your jurisdiction, including U.S. state breach notification laws.
• Provide you with information about the nature of the breach, the data affected, the likely consequences, and the measures taken or proposed to address the breach.

14. Children's Privacy

The Services are strictly for users aged 18 and older (or the age of majority in your jurisdiction, whichever is higher). We do not knowingly collect personal data from anyone under the age of 18.

If you believe that a person under 18 is using the Services or that we have inadvertently collected data from a minor, please contact us immediately at support@trivmo.com. We will take prompt steps to delete such data and terminate the account.

15. Third-Party Services

The Services may contain links to or integrate with third-party services (e.g., social media platforms, payment processors, analytics providers). This Privacy Policy does not apply to third-party services. We encourage you to review the privacy policies of any third-party services you interact with.

We are not responsible for the privacy practices, content, or security of third-party services.

16. Sub-Processors

We use the following categories of sub-processors to provide the Services:

• Cloud Infrastructure: Hosting and data storage services.
• Analytics: Aggregated and anonymized usage analytics.
• Payment Processing: Subscription and transaction processing via Apple, Google, and other payment providers.
• Communication: Email delivery, push notifications, and in-app messaging infrastructure.
• Customer Support: Helpdesk and support ticket management.
• Content Moderation: Automated and manual review of user content for safety and policy compliance.

A detailed, up-to-date list of sub-processors is available upon request by contacting privacy@trivmo.com. We will notify you of any material changes to our sub-processor list where required by applicable law or our contractual commitments.

17. Region-Specific Disclosures

17.1 European Union / European Economic Area / United Kingdom

If you are located in the EU, EEA, or UK:

• The data controller is QNeesh, LLC. Contact: privacy@trivmo.com.
• Your rights under GDPR / UK GDPR are described in Section 7.2.
• International data transfers are conducted using Standard Contractual Clauses and supplementary measures (see Section 9).
• You have the right to lodge a complaint with your local data protection supervisory authority. For the UK, this is the Information Commissioner's Office (ICO) at ico.org.uk.

17.2 California (CCPA / CPRA)

If you are a California resident:

• Your rights under CCPA/CPRA are described in Section 7.3.
• We do not sell or share your personal information for cross-context behavioral advertising.
• In the preceding 12 months, we have collected the categories of personal information described in Section 2 for the purposes described in Section 5.
• To submit a verifiable consumer request, contact privacy@trivmo.com or use the in-app settings.
• Financial Incentives: We do not offer financial incentives or price differences in exchange for the retention or sale of personal information. Premium subscribers receive additional features as described in our Terms; these features are not conditioned on the disclosure of personal information beyond what is necessary to provide the Services.

17.3 Brazil (LGPD)

If you are located in Brazil:

• Your rights under the LGPD are described in Section 7.4.
• Our designated person responsible for data processing (encarregado) can be reached at privacy@trivmo.com.
• You may lodge a complaint with the Autoridade Nacional de Proteção de Dados (ANPD).

17.4 Other Jurisdictions

If you are located in a jurisdiction with specific data protection requirements not listed above (e.g., Australia, Canada, South Korea, Japan, India), we will comply with all applicable local privacy laws. Contact privacy@trivmo.com for information about how we address specific local requirements.

18. Changes to This Policy

We may update this Privacy Policy from time to time. When we make material changes, we will:

• Post the updated Policy on our website with a revised "Last updated" date.
• Notify you through the app, via email, or through a prominent notice on our website.
• Where required by applicable law (e.g., EU/EEA), obtain your consent before material changes take effect.

Your continued use of the Services after the effective date of an updated Policy constitutes your acceptance of the changes. If you do not agree, you should stop using the Services and delete your account.

19. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or your personal data, contact us at:

QNeesh, LLC (operating as Trivmo)
Privacy Inquiries: privacy@trivmo.com
Legal Inquiries: legal@trivmo.com
General Support: support@trivmo.com

We will acknowledge your inquiry within five (5) business days and respond within the timeframes required by applicable law.