Draft for legal review. This document is a working draft. It has not yet been reviewed by a lawyer and is not yet in force. Details in square brackets, like [DPO email], will be filled in before launch.
The short version
- We collect what we need to run a safe dating app: your phone number or sign-in, your profile and photos, an approximate location, your face verification result if you choose to verify, your matches and messages, and your payments.
- Your exact location is never shown to anyone. The app asks only for your approximate location and rounds it to about 1 kilometre before it leaves your phone, and other members see only a distance in whole kilometres.
- We keep your face verification result and scores, never the video or images.
- We don’t sell your data, and we don’t show ads.
- You can download your data or delete your account at any time, in the app or on the website.
- If you have a question or a complaint, write to our Data Protection Officer at [DPO email]. You can also complain to the Nigeria Data Protection Commission (NDPC).
1. Who we are
Amara is operated by [Company legal name], RC number [RC number], of [Registered address] (“Amara”, “we”, “us”). We are the data controller for the personal data described in this policy. This means we decide how and why it is used, and we are responsible for it under the Nigeria Data Protection Act 2023 (“NDPA”).
Data Protection Officer: [DPO name], [DPO email].
This policy covers the Amara app and the website at amaradating.com. It applies to members and to anyone who visits our website.
2. What we collect
Information you give us
| What | Details |
|---|---|
| Account | Your phone number, or your Google or Apple account ID and the email address it shares with us. If you sign in with Apple, Apple may share your name and may hide your real email. |
| Profile | Your first name, date of birth (others see only your age), gender, who you want to see, what you’re looking for (your intent), bio, prompt answers, interests, and your discovery preferences (age range, distance, and whether to see people a little beyond them once you run out). |
| Optional details | Height, religion, education, job title, languages, drinking, smoking and children. You choose whether to add these. |
| Photos | Between 3 and 6 photos. We remove the location and other hidden data (EXIF) from every photo and delete the original upload once it is processed. |
| Location | Your approximate device location, which the app rounds to about 1 kilometre before sending it to us; we round it again before storing it. We use it to find people near you and to show an approximate distance in kilometres. Nobody ever sees your coordinates. If you use Travel mode (Plus and Gold), we use the centre of the city you pick from our list instead, never a point you drop, and members there see that you’re travelling to that city. |
| Messages | The messages and photos you send in chat, and Rose notes. |
| Activity | Your likes, passes, Super Likes, Roses, matches and blocks. |
| Safety | Reports you make (reason, details you add, and what they are about), appeals you send, and Share My Date plans: the name of the person you’re meeting, the place and time, your contact’s name, and only the last 4 digits of their phone number. |
| Support | What you tell us when you contact us. |
Face verification
Face verification is optional. To verify your face, you take a short live video selfie in the app. Our provider, Amazon Web Services (AWS Rekognition), checks that a live person is in front of the camera and gives us one still frame. We compare that frame with up to 3 of your profile photos to get a match score.
What we keep: the outcome (passed, failed or expired), the liveness score and the face match score, the date, and the provider’s session ID.
What we don’t keep: the video, the still frame, or any face template or faceprint. The frame is used only in memory for the comparison and is not saved to our storage. [Legal review: confirm AWS AI services opt-out is in place so that AWS does not keep or use this content to improve its services.]
Payments
When you pay Amara directly, Paystack processes the payment. When you pay through the App Store or Google Play, Apple or Google does, and RevenueCat tells us what you bought. We never see or store your full card details. We keep a record of what you bought, the amount, currency, VAT, dates, renewal status and the payment provider’s reference. For payments to Amara, we give Paystack a private payment alias in place of your real email address.
Information collected automatically
- Sessions and devices: each signed-in device, its app version and platform, and when it was last used.
- Push notification tokens: so we can send notifications to your device.
- Security and service logs: IP address, request details and error reports, which we use to keep the Service secure and working. Our logs remove phone numbers, emails, tokens and message text.
- Website analytics: only if you agree in our cookie banner. See our Cookie Policy.
- Website forms: a message you send through our support form (your name, email, topic and message, and the phone number or payment reference if you add them), with the first part of your IP address and your browser type, so we can answer and keep the form free of abuse. Cloudflare Turnstile checks the checkout sign-in, account deletion and support forms for bots.
Sensitive information
Some information you share may be sensitive personal data under the NDPA, such as your religion, information about your sex life or sexual orientation (which may be suggested by who you want to see), and the facial data used during verification. Your goal (for example Short-term fun) may also say something about your sex life. It is shown on your profile and decides which Explore categories you appear in. We use this only with your explicit consent, which we ask for in the app, and only for the purposes described here. You can remove optional details at any time, and you can withdraw consent by deleting the information or your account.
3. How we use your information, and why we are allowed to
| Purpose | What we use | Lawful basis under the NDPA |
|---|---|---|
| Create and run your account, sign you in, keep your sessions secure | Account, sessions, devices | Performing our contract with you |
| Show your profile, suggest matches, run likes, matches and chat | Profile, photos, location, intent, activity, messages | Performing our contract with you; explicit consent for sensitive details |
| Face verification | Video selfie (not kept), scores | Explicit consent |
| Keep members safe: photo checks, chat safety checks, reports, moderation, enforcement, appeals, stopping banned people from returning | Profile, photos, messages, reports, ban records | Legitimate interests (keeping our community safe); legal obligation where it applies |
| Share My Date | Plan details, your contact’s phone number (to send the text) | Your request and consent |
| Payments, renewals, receipts and refunds | Purchase records | Performing our contract; legal obligation (tax and accounting) |
| Notifications and service messages | Push tokens, preferences | Performing our contract; you control which notifications you get |
| Fixing bugs and preventing abuse | Logs, error reports | Legitimate interests |
| Website analytics | Cookie data | Consent |
| Responding to legal requests and protecting people’s safety | Whatever is relevant | Legal obligation; vital interests |
Where we rely on legitimate interests, we have balanced them against your rights. You can object (see section 9).
4. Automatic decisions
Some safety decisions are made by computer, so that we can act quickly:
- Face verification passes or fails based on the liveness and face match scores. If it fails, you can try again (up to 5 times a day).
- Photo checks hold back a photo that may break our rules until a moderator looks at it.
- Profile text with phone numbers, links or handles is not accepted.
- Chat checks delay contact details until you have each sent 3 messages, ask “Are you sure?” before an insulting message, and add a warning to messages that ask for money.
- Reports: a profile is hidden from new people while we review it if 3 different verified members report it within 24 hours, or once for “May be under 18”.
Bans, suspensions and restrictions are decided by a person on our moderation team, and you can appeal them. If you think an automatic decision has affected you unfairly, contact us at [DPO email] and a person will review it.
5. Who can see your information
Other members can see your profile once it is visible: your first name, age, photos, intent, bio, prompts, interests, the optional details you add, your verified badge (if you have one), whether you joined in the last two weeks, and an approximate distance. People can find you in Explore categories based on your goal, interests, verified badge and join date. They cannot see your phone number, email, date of birth, exact location or payment details. Your matches see the messages you send them. If you have Gold, you see read receipts; members with Gold see when you have read their messages.
Our team can see your information only when their job needs it. Access is based on role: for example, moderators see conversations only when they have been reported or flagged, and they see contact details masked; our finance team sees billing records but not profiles. Every action our team takes is recorded in an audit log.
The person you choose for Share My Date receives a text with your name, who you’re meeting, where and when.
6. Who we share it with
We don’t sell your personal data and we don’t share it with advertisers. We share it only with:
Service providers (processors)
These companies process data on our behalf, under contracts that require them to protect it and use it only for our instructions.
| Provider | What they do for us |
|---|---|
| MongoDB (MongoDB Atlas) | Database hosting |
| Redis ([provider name]) | Fast temporary storage for sessions, rate limits and queues |
| Amazon Web Services (S3) or a compatible storage provider ([provider name]) | Private storage for photos and chat photos |
| Amazon Web Services (Rekognition) | Face liveness, face match and photo moderation |
| Termii | Text messages: sign-in codes and Share My Date |
| Expo | Push notifications (delivered through Apple Push Notification service and Google Firebase Cloud Messaging) |
| Paystack | Payments made to Amara directly |
| RevenueCat | Records of App Store and Google Play purchases |
| Sentry | Error monitoring |
| PostHog (EU hosting) | Website analytics, only with your consent |
| [Email provider name] | Sending emails |
| [Hosting provider name] | Running our servers and website |
| Cloudflare | Website security, and bot protection on forms (Turnstile) |
Independent companies
Apple and Google (when you sign in with them, download the app, or buy in their stores) and Paystack (for its own legal and fraud-prevention duties) also act as controllers of some of your data under their own privacy policies.
Authorities and legal requests
We may share information with the police, regulators or courts when the law requires it, or when we believe in good faith that it is needed to prevent harm to someone, investigate a crime such as fraud or sextortion, or protect our members. We review every request and share only what is needed.
If Amara changes hands
If Amara is merged with or bought by another company, your data may pass to that company. We will tell you before that happens, and this policy will continue to protect your data.
7. International transfers
Some of our providers store or process data outside Nigeria, for example in the European Union and the United States. [Legal review: confirm hosting regions for the database, storage and AWS Rekognition (currently configured for eu-west-1, Ireland).] When we transfer data out of Nigeria, we do so only as the NDPA allows: to countries with adequate protection, or with appropriate safeguards such as contractual commitments, and we keep a record of the basis for each transfer.
8. How long we keep it
| What | How long |
|---|---|
| Your account and profile | While your account is open. After you ask us to delete it, 30 days, then erased |
| Photos | Until you remove them or your account is erased. The original upload is deleted as soon as it is processed |
| Face verification video and still frame | Not kept |
| Face verification result and scores | Until your account is erased |
| Location | Only your latest rounded location, until it changes or your account is erased |
| Messages and chat photos | While the match lasts. Deleted 30 days after the conversation ends (unmatch, block or expiry). Erased when either person’s account is erased |
| In-app notifications | 90 days |
| Push notification tokens | Until you sign out on that device, or 30 days after they were last refreshed |
| Share My Date plans | 30 days after the date |
| Reports and evidence (including copies of reported conversations) | 2 years after the case is decided. Automatic flags that our team dismisses: 90 days. Evidence is kept even if an account is deleted, so we can protect people |
| Records that stop banned people from signing up again | Protected (keyed hash) versions of the phone number, email and Google or Apple ID, kept for [period to be confirmed] |
| Payment records | As long as tax and accounting law requires. When your account is erased, we remove your identity from them |
| Records of our team’s actions (audit log) | 2 years. When an account is erased, the personal details in these records are removed |
| Security and service logs | About [30] days |
| Messages sent through our support form | 12 months |
| Sign-in and account deletion codes | 5 minutes |
9. Your rights
Under the NDPA, you have the right to:
- be informed about how we use your data (this policy);
- access your data and get a copy;
- correct data that is wrong;
- delete your data;
- restrict how we use it in some cases;
- object to our use of it based on legitimate interests;
- data portability: receive it in a common, machine-readable format;
- withdraw consent at any time, without affecting what we did before;
- not be subject to a decision based only on automatic processing that seriously affects you, and to ask a person to review it;
- complain to the Nigeria Data Protection Commission.
How to use them
- Download your data: in the app, go to Settings → Download my data. You get a file (JSON) with your account, profile, devices, matches and messages, notifications and purchases.
- Correct your data: edit your profile at any time. To change something you can’t edit, such as your date of birth, contact us.
- Delete your account: in the app under Settings → Delete account, or on the website at amaradating.com/account/delete. You are hidden at once and signed out everywhere. If you sign in again within 30 days, your account is restored; after 30 days, we erase your account, profile, photos, matches, messages, verification records and Share My Date plans. We keep only what section 8 says we keep (for example, safety evidence, ban records and anonymised payment records).
- Anything else: email [DPO email]. We may need to confirm it’s really you. We will reply as soon as we can and within the time the law allows.
Complaining to the regulator
If you’re not happy with how we handle your data, please tell us first. You also have the right to complain to the Nigeria Data Protection Commission (NDPC) at ndpc.gov.ng.
10. How we protect your data
- All connections to Amara are encrypted (HTTPS/TLS).
- Photos and media are kept in private storage and shown through links that expire after one hour.
- Data is stored with encryption at rest by our hosting providers. [Legal review: confirm production configuration.]
- Our team signs in with two-step verification, access is based on role, and every team action is recorded.
- Sign-in codes expire after 5 minutes, and signing out a device cuts off its access at once.
No system is perfectly secure. If a personal data breach puts your rights at risk, we will tell the NDPC within 72 hours of becoming aware of it, and we will tell you without undue delay if the risk to you is high.
11. Children
Amara is only for adults aged 18 and over. We check your date of birth when you sign up. If we learn that someone under 18 is using Amara, we remove their account. If you think a member may be under 18, report them in the app with the reason “May be under 18”. We treat these reports as the most urgent.
12. Changes to this policy
We will update this policy when the way we use data changes. If a change is important, we will tell you in the app before it takes effect. The date at the top shows when it last changed.
13. Contact us
Data Protection Officer: [DPO name], [DPO email] General support: [support email] Post: [Company legal name], [Registered address]