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Privacy Policy

Effective Date: October 13th, 2025

Operator: Tulpa, Inc. (Delaware, USA)

Contact: [email protected]

Introduction

This Privacy Policy explains how Tulpa, Inc. ("Tulpa," "we," "us") collects, uses, and shares information when you use the Preswipe mobile application and related services (collectively, the "Service"). Preswipe is intended for adults 18+ and permits only SFW (safe-for-work) content. By using the Service, you agree to this Policy.

Information We Collect

a) Information you provide

  • Account & profile: phone number, display name, country code, identity, interests, and app settings.
  • User content: photos you upload (and any associated captions/metadata).
  • Support & moderation: information you send to us (reports, support requests).

b) Information collected automatically

  • Usage & device: app/device identifiers, device/OS, app version, language, IP address, timestamps, and in-app events used to operate the Service and generate aggregate analytics.
  • Diagnostics: crash and performance data.
  • Push tokens: device tokens to deliver notifications you enable.
  • Engagement: swipe events, impression counts, and counters.

c) Purchases

Purchases/subscriptions are processed by Apple App Store/Google Play and managed in-app via RevenueCat. We receive non-sensitive purchase metadata (product, status/entitlements) but not full payment card details.

d) Sensitive categories

Depending on jurisdiction, your selected identity and interests may be treated as "sensitive." We process them only to provide matching/filtering and to operate and improve the Service.

e) What we do not collect

  • No precise GPS location; we rely on a country-code signal (e.g., from phone number or device settings).
  • No third-party advertising SDKs and no cross-app tracking; we do not request IDFA/ATT permission.

How We Use Information

  • Provide and operate the Service (e.g., log-in, eligibility filters, showing photos, recording swipes, awarding credits, subscriptions).
  • Safety, moderation, and enforcement of our Terms (e.g., SFW standards, abuse prevention, fraud mitigation).
  • Improve and develop features and performance (aggregate analytics, diagnostics, quality signals, duplicate-prevention).
  • Communicate with you (service emails, support, push notifications you enable).
  • Comply with legal obligations and protect the rights and safety of users and the Service.

We do not run third-party advertising and do not sell personal information.

How We Share Information

We share information with service providers acting on our behalf under agreements that restrict their use of the data:

  • Firebase (Authentication, Firestore, Storage, Cloud Functions, Analytics, Crashlytics)
  • RevenueCat (subscription and entitlement management)
  • Apple/Google (app store and device services) and Expo (push infrastructure)

We may disclose information if required by law, in response to lawful requests, to protect users and the public, to enforce our Terms, or as part of a corporate transaction (e.g., merger/acquisition) consistent with this Policy.

Legal Bases (EEA/UK)

Where the GDPR/UK GDPR applies, we rely on:

  • Contract — to provide the Service you request.
  • Legitimate interests — service security, fraud prevention, analytics, product improvement (balanced against your rights).
  • Consent — for optional features (e.g., notifications, marketing) where required; you may withdraw consent at any time.
  • Legal obligation — to comply with applicable law.

International Transfers

We are based in the United States and may process information in the U.S. and other countries where our providers operate. Where required, we use appropriate safeguards (such as the EU Standard Contractual Clauses and the UK IDTA).

Retention

We retain personal information only as long as reasonably necessary to provide the Service and for legitimate business or legal purposes (e.g., security, fraud prevention, accounting). When no longer needed, we delete or de-identify data. Backup copies may persist for a limited period before being overwritten.

Security

We use industry-standard safeguards (encryption in transit and at rest provided by our cloud providers, access controls, monitoring). No method of transmission or storage is perfectly secure; please keep your device and credentials safe.

Your Choices & Rights

  • Access/Correction/Deletion: contact [email protected].
  • Notifications: manage push permissions in device settings.
  • EEA/UK/Other jurisdictions: you may have additional rights (e.g., portability, objection, restriction). We will respond in accordance with applicable law.

Account Deletion (in-app)

You can initiate account deletion from within the app (for example: Settings → Delete Account). Once you confirm deletion, we will permanently delete or anonymize your personal data within 30 days of the request, except that we may retain limited information where we are legally required to do so or where retention is necessary for fraud prevention, security, or record-keeping (e.g., purchase records). Content is removed from public view promptly upon deletion. Backup copies may persist for a limited period before being overwritten.

California & Other U.S. State Privacy Notices

  • Categories collected: identifiers (account/device IDs), contact information, user content (photos, swipes), usage data, diagnostics, and sensitive categories (identity/interests you choose).
  • Sources: you/your device; app stores and RevenueCat for purchase status.
  • Business purposes: to provide/improve the Service, security, debugging, internal analytics, and compliance.
  • Disclosures for business purposes: processors listed above and as otherwise described in this Policy.
  • "Sale"/"Sharing": we do not sell personal information and do not share it for cross-context behavioral advertising.
  • Sensitive information: used only to provide requested features; not used for purposes that would trigger a right to limit under California law.
  • State rights: access, deletion, correction, portability (subject to verification and applicable limits). Submit requests to [email protected].

Children

Preswipe is for individuals 18 years and older. We do not knowingly collect data from minors. If you believe a minor is using the Service, contact us and we will take appropriate steps.

Changes to this Policy

We may update this Policy from time to time. If changes are material, we will provide reasonable notice (e.g., in-app notice or email). Your continued use of the Service after the effective date constitutes acceptance of the updated Policy.

How to Contact Us

Email: [email protected]

This Policy is intended to be clear and concise and does not waive any rights or obligations under applicable law.