WOOVY — PRIVACY POLICY

Last updated: September 2026

Woovy ("the App") is a dating app. This policy explains what personal data we collect, why, the legal basis for it, how long we keep it, who else touches it, and what you can make us do about it.

A dating profile is sensitive by its nature. Some of what you tell Woovy — your sexual orientation, and in some readings your gender identity — is a special category of personal data under Article 9 GDPR. We ask for it because the App cannot match people without it, and we process it only on the basis of your explicit consent, given when you complete onboarding. You can withdraw that consent by deleting your account.

1. WHO WE ARE (DATA CONTROLLER)

The App is operated by DigiLabs, a sole trader (eenmanszaak) established in Belgium. Our full registration and contact details are in section 12.

For the purposes of the EU General Data Protection Regulation (GDPR), DigiLabs is the data controller for personal data processed through the App. We have not appointed a Data Protection Officer, as we are not required to do so.

2. WHAT WE COLLECT

Things you give us

• Account: your email address and name, passed to us by Apple or Google when you sign in. Woovy has no passwords of its own.
• Date of birth. We store the date and calculate your age from it on our servers — your age is never taken from the app, so it cannot be edited by changing a value on your phone.
• Profile: gender, sexual orientation (and whether you want it shown on your profile), who you are looking for, what you are looking for, your interests, and your bio.
• Photos — up to six, taken with the camera or chosen from your library. Nothing is uploaded until you pick it.
• Distance and discovery preferences: your maximum distance, age range, and any filters you set.
• Notification preferences.
• A verification selfie, if you choose to get verified. We ask you to take a photo doing a randomly chosen pose — a peace sign, a thumbs up — so that a person can check the photos on your profile are really you. It is optional, it never appears on your profile, and nobody but our reviewers sees it. We do not run face recognition on it and we do not derive a faceprint or any other biometric template from it: a human being looks at it and makes a decision. It is deleted the moment that decision is made, whether we verify you or not — see section 7.

Things the App produces as you use it

• Location, if you allow it: your position while the App is open, which we store as coordinates and as three progressively coarser map cells (roughly 600 m, 2.4 km and 20 km). The App does not track you in the background, and it only records a new position when you have actually moved.
• Extra locations you choose — if you use Bird Mode or multi-location, the cities you have picked to appear in.
• Swipes — who you passed on, wooed, or crushed on, and when.
• Matches and messages, including whether a conversation has been read.
• Blocks and reports you make, and reports other people make about you.
• Usage counters — how many woos, crushes, boosts and rewinds you have used in the current period.
• Your subscription level, if you have one.
• Your device platform and app version, but only attached to a problem report you choose to send us.

Things we do not collect

Woovy contains no advertising SDK and no analytics or tracking SDK. We do not collect advertising identifiers, your contacts, your calendar, your microphone, or anything from your photo library other than the pictures you deliberately pick. We never see your payment card details — Apple and Google handle payment entirely.

The App asks for permission to send notifications. If you allow it, we store a push token for that device — an identifier issued by Expo's notification service that lets us send a message to that handset. It is not linked to any advertising identifier and it is deleted when you sign out on that device, when the notification service tells us it has stopped working, or when your account is erased.

We send notifications about the standing of your account — a warning, a suspension, the outcome of an appeal or of a verification — and about things you have asked for. Messages about your account are sent regardless of the toggles in Settings, because they are not marketing; you can still silence Woovy entirely from your phone's own settings. Every message we send also appears in the App itself, so nothing is lost if a notification does not arrive.

3. WHY WE PROCESS IT, AND ON WHAT LEGAL BASIS

• Creating your account, showing you people, and delivering matches and messages — performance of our contract with you (Article 6(1)(b)).
• Your sexual orientation, and your gender where it reveals something protected — your explicit consent (Article 9(2)(a)), given at onboarding. Withdraw it by deleting your account.
• Your location, used to show you people near you and to place you in other people's results — your consent (Article 6(1)(a)), which you give in the operating system permission dialog and can withdraw at any time in your device settings. The App works without it; you will simply not have a local deck.
• Managing a subscription and the allowances that come with it — performance of our contract (Article 6(1)(b)).
• Keeping people safe: moderating reports, enforcing blocks, suspending and banning accounts, and rate-limiting abuse — our legitimate interests in running a service people are not harmed on (Article 6(1)(f)), and in some cases a legal obligation (Article 6(1)(c)).
• Answering a request to access, correct or erase your data — legal obligation (Article 6(1)(c)).
• Keeping records that Belgian accounting or tax law requires us to keep — legal obligation (Article 6(1)(c)).

4. WHAT OTHER PEOPLE SEE

This is the part of a dating app that matters most, so it is set out plainly.

• Your name, age, photos, bio and interests are shown to other users in the deck.
• Your distance is shown, rounded — never your coordinates, and never an address.
• Your sexual orientation is hidden unless you choose to show it. It is still used to decide who you are shown to.
• Your exact date of birth is never shown — only the age calculated from it.
• Who has wooed you is not sent to your phone unless your subscription includes seeing it. It is withheld on our servers, not blurred on your device.
• If you block someone, they are not told. They stop appearing to you and you stop appearing to them.
• If you turn on Ghost Mode, you disappear from the deck but people you have already wooed can still see you — otherwise the mode would quietly destroy the matches it promises to keep.

5. WHO ELSE PROCESSES IT (SUBPROCESSORS)

• Hetzner Online GmbH (Germany) — hosting. We run our backend on a virtual server we rent from Hetzner, located in one of their data centres inside the European Union. Your profile, photos, swipes, matches and messages live on that server.
• Convex — the database and backend software. We operate it ourselves on the server above; your data is not sent to Convex's own hosted cloud service.
• Apple and Google — sign-in, app distribution, and payment when you buy a subscription. They tell us your name and email address; what they tell us depends on the choices you make in their sign-in screen, including Apple's option to hide your real address.
• Resend (United States) — transactional email. We use it for two things: sending you the copy of your data when you ask for one, and delivering a problem report you send us to our support inbox.

We do not sell your personal data, and we do not share it with anyone for advertising.

6. INTERNATIONAL TRANSFERS

Your account data — your profile, photos, location records, swipes, matches and messages — is stored on a server we rent from Hetzner Online GmbH inside the European Union, and therefore stays in the EU. Hetzner is established in Germany and processes it on our instructions under a data processing agreement concluded under Article 28 GDPR.

Some of what we rely on sits outside the European Economic Area. Resend is established in the United States, and Apple and Google operate globally. Where personal data is transferred to them, that transfer is made on the basis of the EU–US Data Privacy Framework where the provider is certified, and otherwise under the European Commission's Standard Contractual Clauses.

Resend sees only what an email needs: your address, and — when you ask for a copy of your data — the file itself. It is not given access to the database.

7. HOW LONG WE KEEP IT

• While your account exists, we keep your profile and its data.
• When you delete your account (Settings → delete account), your profile disappears from every deck immediately and your matches and messages stop being reachable. You then have 30 days to change your mind by signing back in. After that a scheduled job permanently erases your profile, your photos, your location records, your usage counters, your swipes, your matches, your messages, the blocks you placed, any support tickets you sent us, and the sign-in record itself — the account we hold for your Apple or Google login, the email address on it, and the sessions it had open. Choosing “start over” instead of restoring brings that erasure forward, and keeps only the login you are signed in with so you can set the account up again.
• Three things deliberately survive that erasure, and you should know which. Reports, because a record of a safety complaint has to outlast the account it is about, and a report you filed about somebody else is not yours to delete. Blocks other people placed against you, because that row is their safety setting rather than your data. And, only if your account was banned or suspended when it was erased, a one-way cryptographic hash of the email address you signed in with, together with what the decision was. We cannot read an address back out of it and we do not use it for anything else; it exists so that an account we removed for harming other people cannot be recreated the same day by deleting it and signing up again. We keep it on the basis of our legitimate interest in the safety of the people using Woovy (Article 6(1)(f)), and you can object to it under section 8 — write to us and we will look at your case.
• A verification selfie is kept only for as long as the review takes. It is destroyed in the same operation that records the decision — approved or refused, there is no difference — and we keep only the outcome: that a person reviewed it, who, and when. If nobody has reviewed it within 30 days it is destroyed anyway and you are asked to try again. Changing the photos on your profile also cancels a review that is still waiting, and destroys the selfie with it, because the check would no longer be about the pictures we are being asked to verify.
• Records of data requests — the fact that you asked for a copy of your data, and when we answered — are kept so we can show that we met the deadline. The address we sent it to is removed when your account is erased.
• Accounting and tax records are kept for the period Belgian law requires.

8. YOUR RIGHTS

Under the GDPR you have the right to access your data, to have it corrected, to have it erased, to restrict or object to how we use it, to receive it in a portable format, and to withdraw consent where our processing relies on it.

Three of those are buttons in the App rather than a request you have to write:

• Access and portability: Settings → privacy & data → download my data. We email you a machine-readable file containing your profile, photos, location records, swipes, conversations, blocks, reports and allowances. It is limited in one respect: we do not name the people who wooed you, because their swipe history is their personal data and not yours (Article 15(4)).
• Rectification: every field on your profile is editable in the App.
• Erasure: Settings → delete account, as described in section 7.

For anything else, write to us at the address in section 12. We answer within one month.

You also have the right to complain to a supervisory authority. The Belgian one is:

Gegevensbeschermingsautoriteit / Autorité de protection des données, Drukpersstraat 35, 1000 Brussels, Belgium — contact@apd-gba.be — www.gegevensbeschermingsautoriteit.be

You may also complain to the authority in the EU country where you live or work.

9. AUTOMATED DECISIONS

Who appears in your deck is decided automatically, from your filters, your distance and the preferences both people have set. That is not a decision with legal or similarly significant effects, so Article 22 GDPR does not apply to it.

One automated measure does affect you directly, and we would rather tell you about it than have you discover it: a report that says an account appears to belong to someone under 18 pauses that account immediately, before a human has looked at it. We do that because the alternative — leaving a possible minor visible for as long as a moderation queue takes — is not a trade we are willing to make. A pause is reversible, it is reviewed by a person, and if it happened to you in error you can contact us and we will restore the account.

10. SECURITY

Traffic between the App and our servers is encrypted. Photos are served from links that expire. Access to the operator tools we use for moderation is a separate credential from any app account — being signed in to Woovy grants no administrative access whatsoever — and every action an operator takes on an account, including simply revealing an email address, is written to an append-only audit log.

No service can promise perfect security. If a breach ever affects your rights, we will notify the supervisory authority within 72 hours and tell you directly where the law requires it.

11. CHILDREN

Woovy is for adults. You must be 18 or over to use it. We do not knowingly hold data about anyone under 18, and an account reported as belonging to a minor is paused on arrival and removed if the report is right. If you believe a minor is using Woovy, report the profile in the App or write to us.

12. CONTACT AND CHANGES

• Trading name: DigiLabs
• Enterprise number (KBO/BCE): BE 1003.912.980
• VAT number: BE 1003.912.980
• Address: De Laar 67, 3581 Beverlo, Belgium
• Email: dlabseu@gmail.com
• Phone: +32 456 65 40 44

For privacy enquiries, use the email address above.

We may update this policy. The "Last updated" date reflects the latest revision, and material changes will be communicated in the App.