Privacy Policy

This Privacy Policy explains how Aira ("we", "us", "our") collects, uses, stores, shares, and protects personal data when you access or use our mobile application, website, and related services (collectively, the "Services"). We operate a freemium dating platform for adults aged 18 and over, offering limited features to free users and additional functionality to paid subscribers. We are committed to transparency and compliance with applicable data protection laws, including the UK General Data Protection Regulation ("UK GDPR") and the Data Protection Act 2018.

1. Who We Are (Data Controller)

Legal name: Aira Match Ltd

Registered address: 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ

Company number: [NUMBER]

Contact email: Support@airamatchme.com

We are the data controller responsible for personal data processed through the Services.

2. Scope, Service Model, and Eligibility

This Privacy Policy applies to:

• free users who create profiles and use limited features;
• paid subscribers who access premium functionality;
• visitors to our website;
• individuals who communicate with us.

Service Model

• Users may create a profile free of charge.
• Free users can view general match compatibility information.
• Free users may receive messages from paid subscribers and reply to those messages.
• Certain features — including initiating conversations, enhanced visibility, and additional app functionality — require a paid subscription.

Eligibility

Our Services are strictly limited to individuals aged 18 or over. We use age-verification measures and reserve the right to request additional verification. Accounts identified as belonging to minors are terminated and associated data handled in accordance with applicable law.

3. Categories of Personal Data We Collect

3.1 Information You Provide Directly

When you create an account or use the Services, we may collect:

• name or display name;
• email address;
• date of birth;
• gender identity and sexual orientation (optional);
• dating preferences, interests, and compatibility inputs;
• profile photos, videos, audio, and written descriptions;
• responses to prompts, questionnaires, or compatibility assessments;
• verification information (such as selfies or identity checks where required);
• customer support communications;
• reports, complaints, appeals, and safety submissions.

Some of this information may constitute special category personal data under UK GDPR.

3.2 User-Generated Content and Communications

We process:

• messages sent between users;
• replies sent by free users to paid subscribers;
• attachments, images, or media shared;
• moderation flags, blocks, and reports;
• records of enforcement actions and investigations.

Messages and content may be analysed using automated tools and reviewed by human moderators for safety, fraud prevention, and policy enforcement.

3.3 Subscription and Payment Data

For users who choose to subscribe, we collect and process:

• subscription tier, pricing, and entitlements;
• subscription start, renewal, and cancellation dates;
• transaction identifiers and receipts;
• billing country, postcode, and currency;
• payment method metadata (e.g. card brand, issuing region);
• refund, dispute, and chargeback records;
• fraud- and risk-related indicators provided by payment partners.

We do not store full payment card numbers or CVV codes.

All payments are processed by PCI-DSS-compliant third-party payment processors. Dating services are commonly categorised as high-risk merchants, requiring enhanced monitoring, record-keeping, and dispute handling.

3.4 Automatically Collected Technical and Usage Data

When you use the Services, we automatically collect:

• IP address and approximate location;
• device identifiers, device type, operating system, and app version;
• login history, timestamps, and session duration;
• interaction data (e.g. views, likes, matches, replies);
• behavioural and security signals relevant to fraud detection and abuse prevention.

4. Special Category Personal Data

Dating services may involve information relating to sexual orientation or sex life, which is classified as special category personal data.

We process such data only where:

• you have provided explicit consent; and/or
• processing is necessary to deliver core dating and compatibility features; and
• appropriate technical and organisational safeguards are applied.

You may modify or remove optional profile information at any time.

5. Lawful Bases for Processing

We process personal data under one or more of the following lawful bases:

• Performance of a contract – to provide free and paid features, manage accounts, enable messaging, and deliver subscriptions;
• Consent – for optional profile information, marketing communications, and special category data;
• Legitimate interests – including service improvement, safety, fraud prevention, chargeback defence, analytics, and enforcement of our terms;
• Legal obligation – to comply with applicable legal, regulatory, and accounting requirements.

6. How and Why We Use Personal Data

We use personal data to:

• create, authenticate, and manage user accounts;
• generate and display compatibility information;
• enable communication between paid subscribers and free users;
• deliver premium subscription features;
• process subscription payments, renewals, and cancellations;
• verify age and identity;
• detect, prevent, and investigate fraud, impersonation, and abuse;
• manage refunds, disputes, and chargebacks;
• moderate content and enforce Community Guidelines;
• protect user safety and platform integrity;
• communicate service updates, security notices, and policy changes;
• comply with legal and regulatory obligations.

7. Fraud Prevention, Risk Management, and Chargebacks

Given the nature of freemium dating platforms with paid messaging features, we process personal data for fraud prevention and payment risk management, including:

• analysing behavioural, device, and transaction patterns;
• monitoring messaging activity for abuse or manipulation;
• retaining transaction, usage, and communication records to contest chargebacks;
• sharing relevant data with payment processors, acquiring banks, card networks, and fraud-prevention partners;
• restricting or terminating accounts associated with suspected fraud, abuse, or policy violations.

This processing is necessary for our legitimate interests, contractual obligations with payment providers, and compliance with financial regulations.

8. Automated Decision-Making

We may use automated systems to:

• detect fraudulent, abusive, or manipulative behaviour;
• assess risk associated with accounts or transactions;
• limit or restrict access to certain features.

Where required by law, users may request human review of certain decisions.

9. Data Sharing and Disclosure

We may share personal data with:

9.1 Service Providers

Including providers of:

• hosting and cloud infrastructure;
• analytics and performance monitoring;
• customer support tools;
• content moderation and safety services;
• identity, age, and fraud-verification services;
• email, SMS, and push-notification delivery.

9.2 Payment and Financial Partners

Including:

• payment processors;
• acquiring banks;
• card schemes;
• chargeback and fraud-monitoring services.

9.3 Legal and Regulatory Authorities

Where required by law, court order, or to protect rights, safety, or property.

9.4 Corporate Transactions

If we are involved in a merger, acquisition, restructuring, or sale of assets, personal data may be transferred subject to appropriate safeguards.

We do not sell personal data.

10. International Data Transfers

Personal data may be transferred to and processed outside the UK.

Where this occurs, we rely on:

• UK adequacy regulations;
• UK-approved Standard Contractual Clauses;
• other lawful transfer mechanisms recognised under UK GDPR.

11. Data Retention

We retain personal data only for as long as necessary, including:

• account and profile data: while the account remains active;
• compatibility and interaction data: to support service functionality and improvement;
• payment and transaction data: as required for accounting, fraud prevention, and chargeback defence;
• moderation and safety records: as necessary to protect users and comply with legal obligations.

Data is securely deleted or anonymised when no longer required.

12. Your Rights

Under UK GDPR, you have the right to:

• access your personal data;
• correct inaccurate or incomplete data;
• request erasure (subject to legal and contractual limitations);
• restrict or object to certain processing;
• request data portability;
• withdraw consent at any time;
• lodge a complaint with the Information Commissioner’s Office (ICO).

Requests can be made via Support@airamatchme.com.

13. Cookies and Similar Technologies

We use cookies and similar technologies to:

• operate and secure the Services;
• remember preferences;
• analyse usage and performance;
• detect fraud and abuse.

You can manage cookie settings via your device or browser.

14. Security Measures

We implement appropriate technical and organisational safeguards, including:

• encryption in transit and at rest;
• access controls and monitoring;
• incident-response and breach-notification procedures.

No system is completely secure; users are responsible for safeguarding their login credentials.

15. Children’s Privacy

Our Services are not intended for individuals under 18. Accounts identified as belonging to minors are terminated and data handled in accordance with applicable law.

16. Third-Party Services

Our Services may include links to third-party websites or services. We are not responsible for their privacy practices.

17. App Store and Platform Compliance

This Privacy Policy is intended to comply with:

• Apple App Store Review Guidelines;
• Google Play User Data and Subscription policies.

It is accessible within the app, on our website, and via app-store listings.

18. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated through the Services or by email.