Privacy Policy
1. Welcome
Penpal ("we", "us", "our") helps adults who are new to a city make friends: through a weekly Penpal and group, through activities on a map, and through chats. This Privacy Policy explains what we collect, why, who sees it, how long we keep it, and the choices you have. Words we don't define here mean the same as in our Terms and Conditions.
The short version:
- You must be 18 or older.
- We never sell your data, and we don't show ads or share your data with advertisers.
- People are never shown on the map. Other Penpals only see an approximate distance, rounded to whole miles and never less than 2 miles.
- Your gender, birthdate, friend age range and Girls Rule setting are private. Other people never see them.
- You can delete your account at any time in Settings.
2. Information we collect
Information you give us
- Account details: your email address and password (we never see your password in readable form), or the sign in details Apple gives us if you use Sign in with Apple.
- Profile details: your first name, birthdate (we show only your age), the city you are in, gender, interests, languages, an About Me, and an optional Instagram handle.
- Private settings: your gender, the age range of friends you would like to meet, your Girls Rule setting (if you are a girl and turn it on), and your notification, snooze, messaging and Instagram visibility choices. These are never shown to other people.
- Photos: up to three profile photos. Before a photo is saved, your phone strips hidden location and camera details from it.
- Content: messages and photos in chats, activities you create (title, type, time, meeting spot, who can join), and requests to join.
- Friends, blocks and reports: who you add as a friend, who you block, and reports you file about people or problems.
- Messages to us: reports, emails and anything you send to support.
Information collected automatically
- Approximate location (only if you allow it). See section 3.
- Which profiles you open. This lets people who have Penpal Plus see who viewed their profile.
- Device and technical information: your device type, operating system, app version, language, IP address and error records. Our hosting provider keeps these for security and reliability.
- A push notification token, if you turn on notifications, so we can send notifications to your phone.
- Purchase information: whether you have Penpal Plus and the plan you bought. Payments are handled by Apple. We never see your card details.
- Recent activity counts (for example how many messages or requests your account made in the last day), kept for about two days to stop spam and abuse.
Information from others
- Reports and blocks that other people make about you.
- Friend requests, join requests and messages other people send you.
3. Location
If you allow it, Penpal uses your phone's location while the app is open, for two things:
- Your city. Your phone turns your position into a city name (for example "Madison") with Apple's location lookup service, which receives your coordinates to do this. We store the city name.
- Your approximate location. Your phone rounds your position to about a kilometre (never your exact spot) and sends it to us. We keep only your most recent approximate position, in a private place that nothing in the app can read back. We use it to tell you about new activities within the distance you choose, and to work out roughly how far other Penpals are from you. We keep no history of where you have been.
What other people see:
- They never see where you are on a map, and people are never shown on the map. The only places on the map are meeting spots chosen by the person who created each activity.
- In a list of nearby Penpals they may see an approximate distance such as "2 mi away". It is rounded to whole miles and never less than 2 miles. Even so, in quiet areas a distance can hint at where someone is, so you can turn on Snooze mode in Settings to hide yourself from the list.
- Treat activity meeting spots as public. Anyone who can see an activity can see its spot.
Your choices: turn off "Use my approximate location" in Settings and we delete the saved position straight away. You can also turn off location access in iOS Settings. If you do, nearby alerts and distances won't work.
4. How we use your information
We use your information to:
- Create and run your account and keep you signed in.
- Show your profile to other people as you have set it up, and let you chat, make friends, create and join activities, and see this week's Penpals.
- Choose your weekly Penpals and group. We match people in the same city, using shared interests, how close your ages are, and the friend age range you set, and we avoid repeating people you met recently. People who block each other, and Girls Rule members, are never matched with someone who shouldn't be (see section 5).
- Alert you about new activities near you, new messages, friend requests, join requests and new matches, if you allow notifications.
- Show you how far other Penpals are and sort nearby Penpals, with the limits in section 3.
- Provide Penpal Plus: show who viewed your profile, unlock full nearby lists and other benefits you bought.
- Keep Penpal safe: check photos, look at reports, spot spam, prevent fraud and enforce our Terms and Community Guidelines.
- Respond to your messages and requests, and keep the app working and secure.
- Meet our legal duties, and respond to lawful requests from authorities.
We do not use your messages or photos to train AI models, and we do not use your information for advertising.
5. Gender, Girls Rule and age preferences
We ask your gender so we can offer safety features for girls, such as Girls Rule and girls-only activities. Your gender and your Girls Rule setting are stored privately and never appear on your profile, in any list, or to any other person. Gender can't be changed later in the app. You can choose "Prefer not to say".
The friend age range you choose in onboarding and Settings is also private. It only affects who we match you with.
6. How we check and moderate content
To keep Penpal safe we use a mix of automated tools and people:
- Photos. When you upload a profile photo it is checked before it appears on your profile. The check may use an automated image-checking service, which receives the photo (and nothing that identifies you) for this purpose only. It does not identify who you are and does not create face templates. A moderator may look at a photo that is flagged or reported.
- Reports and issues. If someone reports you or something you did, or you report a problem, authorized moderators may look at the relevant profile, messages and account activity. We do not routinely read private messages. We look only at what is flagged, reported, or needed to investigate a safety, security, legal or policy concern.
- Limits. We limit how often an account can do things like message or send requests, to stop spam and abuse.
- Enforcement. We may remove content, limit features, suspend or permanently remove accounts. You can appeal by contacting us at [SUPPORT EMAIL].
- Child safety. We have zero tolerance for child sexual abuse material. If we find or are told of it, we are required by law to keep the content and report it to the National Center for Missing & Exploited Children (NCMEC) and the authorities.
7. Who we share information with
We share information:
- With other people, as you set it up. Other Penpals can see your profile (name, age, photos, About Me, interests, languages, your city, and your Instagram handle if your Instagram setting allows it) and your messages in chats you are in. Members of an activity can see who else is going.
- With our service providers, who only handle information to do their job for us and under contract:
- Supabase: hosting, our database, sign in, file storage and live updates for chats. Your data is stored on servers in the United States.
- Apple: Apple Maps and MapKit (the map and place search), Apple's location lookup, the App Store and subscription payments, and Apple Push Notification service. If notifications are on, the text of a notification (such as a new message) passes through Apple.
- RevenueCat: subscription management for Penpal Plus. It receives your Penpal account ID, what you bought and when, and technical details such as device type and IP address.
- An image-checking service for photo checks, described in section 6.
- For legal and safety reasons: to follow the law, respond to lawful requests, protect people's safety, and enforce our rights and our Terms.
- In a business change such as a merger or sale, where the new owner must honor this policy.
We do not sell your personal information. We do not share it for advertising. Nobody gets a list of our users. The app currently has no analytics or advertising tools. If we ever add any, we will update this policy first and ask for your permission where the law requires it.
8. How long we keep information
- Your profile, photos, messages, friends and settings: until you delete your account (or remove the item yourself).
- Approximate location: only your latest position, deleted when you turn sharing off or delete your account.
- Push token: deleted when you log out or delete your account. Queued notifications are removed within about a week.
- Activity counts used to stop spam: about two days.
- Activities: they leave the map 24 hours after their time. Their chat stays available to members.
- Reports, moderation records and ban records: as long as reasonably needed to keep people safe, prevent abuse, follow the law and defend claims, even if you delete your account. Where possible we remove the underlying content.
- Anything we are legally required to keep, such as content we must preserve and report for child safety.
- Backups: deleted data may remain in backups for up to [NUMBER] days.
- If you sign in but never finish setting up, or you don't pass the age check, we delete the sign in record within one day.
9. Your choices and rights
In the app you can:
- Edit your profile, photos, interests and Instagram handle, and choose who can see your Instagram.
- Turn Snooze mode on to hide yourself from the nearby list, and choose who can message you.
- Turn off location sharing, nearby activity alerts, or notifications.
- Block and report people, and see and undo your blocks.
- Delete your account in Settings > Delete Account. This deletes your profile, birthdate, photos, messages, friends and blocks.
Depending on where you live (for example the EU, the UK, California and other US states, or Brazil), you may also have the right to access a copy of your information, correct it, delete it, receive it in a portable format, object to or restrict some uses, and withdraw consent you gave. To use these rights, email [SUPPORT EMAIL]. We may need to confirm it is you, and we'll respond within the time the law requires (generally 30 to 45 days). You can use an authorized agent, and you can appeal a refusal by replying to our response. We will not treat you differently for using your rights. You also have the right to complain to your local data protection authority.
10. Legal bases (EU, UK and similar laws)
Where the law asks for a basis, we rely on:
- Contract: to provide the app and your account, profile, chats, matching, activities and Penpal Plus.
- Consent: for your approximate location, notifications, and where required, optional features. You can withdraw consent in Settings or your phone's settings.
- Legitimate interests: to keep Penpal safe and secure, prevent fraud and abuse, enforce our Terms, improve and protect the service, and respond to support requests. We balance these against your rights.
- Legal obligation: to meet our legal duties, such as child safety reporting, tax and responding to lawful requests.
11. California and other US state privacy laws
This section applies to residents of California and other states with privacy laws.
- We collect these kinds of information: identifiers (name, email, user ID, IP address, device token), profile and contact details, age and gender, photos, messages and other content you create, activity on the app (profiles you open, activity counts), approximate location, and purchase status.
- We use it for the purposes in section 4, and we disclose it only to the providers and in the situations in section 7.
- We do not sell personal information and we do not share it for cross-context behavioral advertising, so there is nothing to opt out of.
- Approximate location is the only information we collect that may count as sensitive. We use it only to provide the features you ask for, so we don't offer a separate "limit use" control. You can turn it off any time in Settings.
- You can ask to know, access, correct or delete your information, and can appeal a refusal, as described in section 9.
12. Children
Penpal is only for people 18 or older. We ask for your birthdate with a neutral date picker and don't collect anything else from anyone who isn't 18 or older. If we learn that someone under 18 is using Penpal, we remove the account and delete the information. If you think someone is under 18, use Report on their profile.
13. Security
We use encryption in transit, strict access controls on our database (each person can only reach their own private information), and limits that slow down abuse. No system is perfectly secure, so please use a strong, unique password and keep your phone locked.
14. International transfers
We run Penpal from the United States and your information is stored and processed there. If you use Penpal from outside the US, your information is transferred to the US. Where the law requires it, we use approved safeguards such as standard contractual clauses.
15. Changes to this policy
We may update this policy. We'll post the new version in the app and on our website and change the date at the top. For important changes we'll also tell you in the app or by email. If you keep using Penpal after a change, you accept the update where the law allows.
16. Contact us
Questions, requests or concerns about your privacy:
- Email: [SUPPORT EMAIL]
- Mail: [COMPANY NAME], [STREET ADDRESS], [CITY, STATE, ZIP], United States
- For users in the EU, EEA, UK and Switzerland: [COMPANY NAME] is the controller of your information. [If required, add the name and contact details of the EU and UK data protection representative here.]