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PRIVACY POLICY

Last updated: 1 May 2025

1. Introduction

Truecrush Pte. Ltd. (“Truecrush”, “we”, “us” or “our”) is a Singapore-incorporated company that operates a global AI-powered dating and content subscription platform (the “Service” or “platform”). We respect your privacy and are committed to protecting your personal data. This Privacy Policy explains what information we collect from you, how we use and safeguard it, the choices and rights you have, and how you can contact us with questions. We’ve written this policy in plain English so it’s easy to understand, while ensuring it remains legally accurate and comprehensive.

Applicability: This Privacy Policy applies to all users of Truecrush’s website and services worldwide, including users in Singapore, the United States, the European Union, and elsewhere. By using Truecrush, you agree to the collection and use of your information in accordance with this Policy. This Policy forms part of our Terms of Service. Our Service is intended only for adults (18 years and older). We do not knowingly collect data from anyone under 18. If you are under 18, please do not use the Service. If we learn that a person under 18 has provided personal data, we will delete such data.

2. Information We Collect

We collect various types of personal data from and about you when you use Truecrush. Some information is provided by you directly, and some is collected automatically through your use of the platform or from third parties. In all cases, we only collect information necessary for the purposes described in this Policy.

2.1 Information You Provide

When you interact with Truecrush, you may choose to give us personal information, including:

  • Account Registration Data: When you create a Truecrush account, we ask for basic details such as your full name, email address, phone number (if you choose to provide it), username, password, date of birth, and gender. These are necessary to set up and secure your account and to verify that you meet our age requirement.

  • Profile Information: You have the option to complete a user profile with information like a profile photo, biography or description, interests, and preferences (for example, the types of people or content you’re looking for). You may also share sensitive personal details in your profile at your discretion, such as your sexual orientation, relationship status, or other personal traits. These fields are voluntary. If you choose to provide this information, you consent to our processing of it for the purposes described in this Policy, as it may be considered sensitive or “special category” data under certain laws.

  • Content and Communications: We collect the content you create on the platform. This includes photographs, videos, posts, comments, and other content you upload or share, as well as direct messages or communications you exchange with others on Truecrush. For example, if you send messages to matches or subscribers, those messages (and any attachments like images) are collected and stored. Please be mindful that any content you post or share may reveal personal information about you.

  • Payment and Financial Information: Truecrush is a content subscription platform as well as a dating service. If you make purchases or subscribe to paid content, or if you earn money as a content creator on Truecrush, we (or our third-party payment processors) collect payment-related information. For subscribers and purchasers, this may include your payment card details (credit/debit card number, expiration, billing address) or other payment account details (such as PayPal or other payment service ID). For content creators who earn through the platform, we may collect payout information such as your bank account details, tax identification number, and (if required for verification or tax purposes) supporting documents like a copy of your government-issued ID or tax forms. Note: Truecrush itself does not store full payment card numbers; payments are processed securely by accredited third-party payment providers in compliance with applicable standards (e.g., PCI-DSS).

  • Identity Verification Data: In order to maintain a safe platform, we may ask certain users to verify their identity or age. For example, if you apply to be a paid content creator or if required by law in your jurisdiction, we might request a government-issued ID, a photograph of you (“selfie”) for liveness or face matching, or other verification information. We only use this data to confirm identity/age and for compliance with legal obligations (such as preventing underage access, fraud prevention, and KYC requirements).

  • Location Information (User-Provided): In some cases, you might share your location or address with us. For instance, you might fill in your city or country on your profile, or provide a location as part of your bio. If you choose to disclose this information on your profile, it will be visible to others as part of your profile data.

2.2 Information We Collect Automatically

When you use Truecrush’s website or app, our systems and analytics providers automatically collect certain information about your device and how you interact with the Service. This includes:

  • Usage and Browsing Data: We collect details of your activities on Truecrush. For example, dates and times of log-ins, the features or sections you use (such as which profiles or creator pages you view, content you “like” or subscribe to, search queries you perform), clicks and page views, the content of ads or links you click on, and the referring webpage or app from which you arrived at Truecrush. We also log interactions with other users (for example, the fact that you matched with someone, the number of messages exchanged, or subscription transactions between a fan and a creator). This helps us understand how our service is used and helps with features like recommending profiles or content you might like.

  • Device and Technical Information: We receive data about the devices and software you use to access Truecrush. This may include the IP address of your computer or mobile device, device identifiers (such as a mobile device ID, advertising ID (IDFA/GAID) or unique device token), device type and model, browser type and version, operating system, language settings, and mobile network information. We also collect information about your device’s attributes (e.g., screen size), and if our app crashes or has errors, we collect crash logs and error reports.

  • Geolocation Data: If you enable location services or grant the Truecrush app permission to access your location, we may collect precise geolocation data (GPS coordinates) from your device. For example, a dating feature might use your location to show you nearby matches. We will only collect precise location if you expressly consent (such as by enabling location sharing in the app). If you decline, we may infer general location from your IP address (for example, your city or country) but not your exact coordinates. You can always control location sharing via your device settings.

  • Cookies and Similar Technologies: Like most online services, we use cookies, pixels, and similar tracking technologies to operate and improve our Service. These technologies help us recognize you, remember your preferences, keep you logged in, and understand your interactions. For example, we use cookies to remember your session login, and we use tracking pixels to measure the effectiveness of our outreach or marketing (such as a Facebook Pixel to know if you visited our sign-up page from an ad). For detailed information on how we use cookies and how you can control them, please see our Cookie Policy below.

  • Analytics Data: We partner with third-party analytics providers (such as Google Analytics) that use cookies and device identifiers to help us analyze usage of the platform. These providers collect information such as what pages you visit, how long you stay, how you got to our site, and what you click on. This analytics data helps us understand user engagement and improve our Service design and content. All analytics data is typically collected in aggregate form, but it may be linked to your user ID or device ID for internal analysis. Google Analytics may also collect certain demographic and interest information if available from your Google advertising settings; however, we receive this data as statistical trends, not as personal identifiers.

  • Log Files: Our servers automatically record certain information (“log data”) including your IP address, browser type, internet service provider, referring/exit pages, operating system, date/time stamps, and clickstream data. These logs are primarily used for troubleshooting, security monitoring, and compiling usage statistics.

2.3 Information From Third Parties

On occasion, we might receive information about you from other sources:

  • Third-Party Social Accounts: If you choose to link or log in to Truecrush via a third-party account (for example, signing up with your Google, Apple, or Facebook account), we will receive certain information from that third-party with your permission. This may include your name, email, and public profile information from that account. We only receive what you agree to share via the third-party’s OAuth or permissions interface. We use this information to simplify account creation and login for you.

  • Other Users: Other users might provide information about you as they use the Service. For example, a user could mention you in a message or report some issue involving you. If a user you interacted with contacts our support or provides feedback, we might process information about that communication.

  • Service Providers and Partners: We may receive data from service providers that support our business. For example, if payments are processed by a payment provider, they might confirm your payment and provide us with limited information (like payment confirmation or partial card details). If we run promotional campaigns or advertising, our marketing partners might provide performance data (e.g., how you interacted with an email or ad).

  • Public Sources: To the extent permitted by law, we might also collect information from public databases or social media (for instance, to verify information you provided or to address fraud concerns).

We treat any information obtained from third parties according to the practices described in this Privacy Policy, plus any additional restrictions imposed by the source of the data.

3. How We Use Your Information

Truecrush collects and uses personal data for the following purposes, all in accordance with applicable law:

  • Providing and Maintaining the Service: We use your information to create and manage your account, provide you with the features of our dating and content platform, and enable core functionality. For example, we use your profile information and preferences to introduce you to other users, match you with potential dates or show you relevant content creators, and we use your content (posts, messages) to deliver it to the intended recipients. If you are a paying subscriber or a content creator, we use your information to process your subscriptions, payments, and payouts.

  • Improving and Personalizing the Service: Your data helps us understand how users interact with Truecrush, so we can improve our platform and develop new features. We analyze usage patterns to fix bugs, optimize user experience, and refine our matchmaking and content recommendation algorithms. We also may personalize your experience - for instance, using your browsing behavior and profile info to suggest potential matches, or showing you content and user recommendations tailored to your interests. This may include automated decision-making or profiling; for example, our AI-powered matching system might use your profile and activity to rank and present match suggestions. We do not make any decisions that produce legal or similarly significant effects on you without human review (e.g., purely automated account termination decisions will not be made without manual oversight).

  • Safety and Trust & Safety Monitoring: We are dedicated to keeping Truecrush safe, welcoming, and compliant. We use personal data to monitor for and prevent fraud, abuse, and other harmful or illegal activities. For example, we may review communications on the platform for violations of our community guidelines (such as harassment or explicit illegal content). We use automated tools and moderators to detect possible sexual exploitation, non-consensual content, or other misuse. If we detect potentially problematic behavior, we may investigate and take appropriate action (which could include warning users, removing content, or suspending accounts). We also use your information to verify your identity/age where appropriate (to prevent minors from accessing the service or to comply with regulations), and to authenticate accounts and detect bots.

  • Communication with You: We use contact information (like your email address or phone number) to communicate with you about your account and our services. This includes sending service-related announcements and transactional messages (e.g., account verification emails, password reset texts, subscription confirmations, billing receipts, or important alerts about account or security issues). We may also send you informational or promotional content about new features, updates, or offers that we think you’d be interested in. You can opt-out of marketing emails at any time by clicking the unsubscribe link in those emails or adjusting your account settings. (Note: You will still receive essential account and transactional communications even if you opt out of marketing.)

  • Analytics and Service Optimization: We use data (including cookies and similar tech) to generate aggregate analytics about our user base and Service performance. This helps us understand trends, like which features are popular or how users navigate through our site, so we can make informed decisions about how to improve Truecrush. Sometimes we may use third-party analytics tools (like Google Analytics as mentioned) to assist with this analysis. These insights are generally in aggregate form and do not identify you personally, but may use your data in the processing.

  • Advertising and Marketing Measurement: Truecrush itself does not display third-party ads on our platform (we are not sharing your data with advertisers for their independent use). However, we may use your data to market Truecrush on other platforms. For example, we might use Facebook Pixel or Google Ads conversion tracking to understand how effective our advertising is and to reach people who might be interested in Truecrush. This means if you’re a user, a third-party like Facebook could receive some data (via the pixel) that you visited or took an action on our site, which can help us (for instance, by allowing us to show you our own ads on Facebook or measure if an ad led you to sign up). We ensure any such third-party tracking is done in compliance with privacy laws (seeking consent where required). You can control or disable many of these trackers as described in our Cookie Policy.

  • Compliance with Legal Obligations: We may process your personal information to comply with applicable laws, regulations, and legal processes. This includes retaining and disclosing certain data as required by law or court order, responding to legitimate requests by government or law enforcement (after verifying the request meets legal standards), and fulfilling obligations under financial, anti-fraud, and sanctions regulations. For example, as a Singapore company, we adhere to the Singapore Personal Data Protection Act (PDPA) and other laws; if required, we might retain transaction records for audits or tax purposes, or disclose information if we receive a valid legal request concerning criminal investigations.

  • Enforcing Terms and Exercising Rights: We use data to enforce our Terms of Service, Community Guidelines, and other agreements. If necessary, we will use personal information to investigate and address violations, and to resolve or defend any legal claims or disputes. For instance, if there is a dispute between users or a user violates intellectual property rights, we may review relevant data to resolve the issue. We may also use data to establish or exercise our legal rights or defend against legal claims.

  • Other Purposes with Consent: If we intend to use your data in ways not covered by the above, we will explain it at the point of collection and, if required, seek your consent. For example, if we ever wish to use your photo or profile in promotional materials, we would ask for your permission. You have the right to withdraw consent at any time for any processing that is based on your consent (with future effect). Withdrawing consent won’t affect the lawfulness of any processing we already performed.

Legal Bases (for EU users): If you are in the European Economic Area (EEA) or United Kingdom, we process your personal data only when we have a valid legal basis. The legal bases we rely on are typically: (a) Contract - processing is necessary to provide the Service and fulfill our contract with you (for example, using your data to create your account, match you with others, or process a subscription you requested); (b) Legitimate Interests - for purposes like improving the service, ensuring security, and providing customer support, we balance our interests against your privacy rights (we do not use legitimate interest where overridden by your interests or fundamental rights); (c) Consent - where you have given consent, for instance for optional sensitive data in your profile, for receiving marketing communications, or for enabling location-based features and certain cookies; and (d) Legal Obligation - when we need to comply with laws (such as retaining transaction records for tax, or responding to lawful requests). If you have questions about the legal basis of particular processing, you can contact us for more information.

4. Cookies and Tracking Technologies

We use cookies and similar technologies as described briefly above to collect and use information. For a full explanation of how Truecrush uses cookies, please see the Cookie Policy section of this document. It describes the types of cookies (e.g., necessary, functional, analytics, advertising) we and our partners use, and your choices regarding cookies (including how to adjust your preferences or opt out). If you adjust your cookie settings on our site, those preferences will be honored. Also note, some browsers offer “Do Not Track” signals; currently, industry standards for DNT are not uniform, so we may not respond to DNT signals. Instead, we provide the controls outlined in the Cookie Policy for you to manage tracking.

5. How We Share Your Information

Protecting your privacy is extremely important to us. We do not sell your personal data to third parties. We also do not share your personal information with third-party companies for their own direct marketing or advertising purposes. That means, for example, we’re not handing over your email or profile details to advertisers or “affiliates” to spam you with offers.

However, we do share some information with trusted third parties in the following situations, in order to run Truecrush effectively and lawfully:

  • Service Providers (Processors): We share personal data with third-party companies and individuals who perform services on our behalf and under our instructions. These include, for example, payment processors (to securely handle credit card transactions and payouts), cloud storage and hosting providers (to store data and keep the website/app running), analytics providers (to analyze usage data as described above), email/SMS services (to send verification codes or notifications), and customer support tools. These service providers are bound by confidentiality and data protection obligations (through contracts like Data Processing Agreements under GDPR) and may only use your data for the specific purposes we dictate, not for their own benefit.

  • Facebook Pixel and Analytics Tools: As mentioned, we use certain third-party tools like Facebook Pixel and Google Analytics. When we use these tools, some data about your browsing or app usage is automatically collected by those third-party providers. For example, the Facebook Pixel on our site may enable Facebook to collect or receive certain information (such as that a particular browser visited a specific page or performed an action) which can be used to measure ad performance or deliver ads (we use it to measure and improve our marketing campaigns for Truecrush). Similarly, Google Analytics will collect data about your device and interactions. These third parties process data under their own privacy policies. We do not provide them with your name, contact, or any direct personal identifiers—rather, the tracking operates via pseudonymous cookie or device IDs. However, because these tools involve transferring data to third parties, we treat this as a form of data sharing for which we will obtain any required consent. You can opt out of Google Analytics by using the Google Analytics Opt-out Browser Add-on, and you can control cookies including advertising pixels via our Cookie consent tool or your browser settings (see Cookie Policy below).

  • Other Truecrush Users: Some of your information will be visible to or shared with other users by your own actions on the platform. For example, when you create a dating profile, other members can see the information you’ve made public on your profile (such as your photos, first name, age, location if you provided it, interests, etc.). If you are a content creator, your subscribers (“fans”) can see the content you post for them and any information you include in that content or on your creator profile. When you communicate with other users (such as sending a direct message or a photo), the content of those communications is obviously shared with the recipient. We cannot control (and are not responsible for) how other users you share information with will use that information, so please only share with others what you’re comfortable being public or known to that person.

  • Legal Requirements and Safety: We may disclose personal information if we have a good-faith belief that such disclosure is necessary to: (a) comply with a law, regulation, legal process, or governmental request (for example, responding to a court order or a lawful subpoena); (b) enforce our Terms of Service or other agreements, or investigate potential violations thereof; (c) detect, prevent, or address fraud, security, or technical issues; or (d) protect the rights, property, or safety of Truecrush, our users, or the public. This could include sharing information with law enforcement or regulatory authorities (consistent with applicable law) or with other companies and organizations for fraud protection (for instance, sharing data about malicious accounts with relevant platforms if legally permissible). We will notify users of legal demands when appropriate, unless prohibited by law or when the request is an emergency.

  • Business Transfers: If Truecrush undergoes a business transaction such as a merger, acquisition by another company, reorganization, or sale of all or part of our assets, your personal data may be among the assets transferred. We will ensure the acquiring organization is bound to respect your personal data in a way that is consistent with this Privacy Policy. We will provide notice to you (for example, via email or a notice on our website) of any such deal and outline your choices, such as the ability to delete your account if you do not wish to continue under the new ownership.

  • Aggregated or De-Identified Information: We may share information that has been aggregated (combined with data of other users) or de-identified (stripped of personal identifiers) such that it cannot reasonably be used to identify you. For example, we might publish usage statistics or share generalized insights with partners (e.g., “X% of our users are from Europe” or “Average daily messages per user”), as long as this information does not identify any individual. This kind of data is no longer considered personal data under many privacy laws and may be used or shared for any legitimate purpose.

No Sharing with Advertisers or Unaffiliated Marketers: To reiterate, we do not share your personal details with third-party advertising networks or social media companies for their own marketing, except through the controlled mechanisms described (like pixels which you can opt out of). You will not find us selling your data to data brokers or sending your contact info to other companies to advertise their products to you. If in the future we ever consider expanding how we share data, we will update this Policy and, if required by law, seek your consent.

6. International Data Transfers

Truecrush is a global service. By using our platform, you understand that your personal data may be transferred to and stored in Singapore and other countries, which may have data protection rules different from those in your country. We primarily store and process data on secure servers in Singapore, but we may also use cloud services or service providers located in the United States or other jurisdictions. For example, if we use an American cloud hosting provider or an EU-based analytics service, your data will be transferred to those locations for processing.

Regardless of where your data is processed, we handle it with the same level of security and care described in this Policy. If you are located in the EU, UK, or another region with laws governing data collection and use, we will ensure that your information is transferred in compliance with those laws. In practice, this means:

  • Adequacy and Safeguards: When transferring personal data out of Singapore or your country, we take steps to ensure appropriate safeguards. For EU/EEA users, if your data is transferred to a country not deemed “adequate” by the European Commission (Singapore currently is not on the EC’s adequacy list), we rely on approved mechanisms such as Standard Contractual Clauses (SCCs) or an equivalent legal transfer mechanism to ensure your data is protected. These are contractual commitments between our entities or between us and our service providers that require all parties to protect personal data according to EU privacy standards. Similarly, for UK transfers we may use the UK’s International Data Transfer Agreement or Addendum.

  • Consent for Cross-Border Transfer: By using Truecrush or by providing us your information, you explicitly consent that we may transfer and store your data on servers located in Singapore and other jurisdictions as needed to provide the service. We will take all necessary measures to protect your privacy in line with this Policy. If applicable law requires your consent for international transfers, we will obtain that consent separately.

  • PDPA Compliance: As a Singapore company, any transfer of personal data overseas will also be done in accordance with Singapore’s PDPA requirements. This means we will ensure that the recipients of the personal data are bound by legally enforceable obligations to provide a standard of protection comparable to the PDPA (for instance, through data transfer agreements with our service providers).

Please note that different countries have different laws and requirements on access to data by authorities. While data is in another jurisdiction, it may be accessed by the courts, law enforcement, and national security authorities of that jurisdiction, in accordance with their laws. Subject to such lawful requests, we remain committed to the privacy protections described in this Policy wherever your data is processed.

7. Data Retention

We will retain your personal data only for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. In practical terms:

  • Active Account: If you have an active Truecrush account, we retain the information you have provided for as long as your account exists, so that we can operate the Service for you. This includes your profile information, content, and usage data.

  • Account Deactivation or Deletion: You have the right to delete your account at any time (see “Your Rights” below on how to do this). If you delete your account, it will be scheduled for deactivation. We will retain your data for a brief period in case you decide to reactivate (to avoid immediate loss of information). After that grace period, we will begin the process of deleting or anonymizing your personal data. Complete removal from our active systems will generally occur within [30 days] of the deletion request, except as noted below. Please note that removal from backup systems might take additional time but we will not restore personal data from backups into active service except as required for disaster recovery.

  • Content Removal: If you remove or delete specific content (for example, you delete a photo or message), that content will no longer be visible to other users. However, copies of it may remain in our backup archives for a limited period or as required to be retained for legal reasons (we outline those below).

  • Retention for Legal/Legitimate Reasons: We may need to retain certain information even after account deletion for reasons such as:

    • Legal Compliance: If we are required by law to keep records (for example, financial transaction records for tax/regulatory compliance, or records of communications if mandated by online safety laws), we will retain the necessary data for the period mandated by law.
    • Dispute Resolution and Enforcement: If there is an unresolved issue, dispute, or claim (for example, an outstanding credit on your account, a dispute regarding a ban, or a claim in process regarding content you posted), we may retain relevant information until the issue is resolved. We may also retain data as necessary to enforce our agreements, or to protect our rights or the rights of others (e.g., information involved in a DMCA takedown or in an abuse investigation) - in such cases, we would retain only the data necessary for the specific purpose and for no longer than necessary.
  • Anonymized Data: In some cases, rather than fully deleting data, we may anonymize it (irreversibly strip all personal identifiers) so that it no longer can be associated with you. For example, we might convert detailed usage logs into aggregated statistics. We retain anonymized data with no personal identifiers indefinitely for research and to improve the Service, since it no longer constitutes personal data.

When determining retention periods, we consider the amount, nature, and sensitivity of the data, the potential risk of harm from unauthorized use or disclosure, the purposes of processing, whether those purposes can be achieved by other means, and all applicable legal requirements. Once the retention period expires, we will securely destroy or delete your personal data, or anonymize it, as applicable.

8. Your Rights and Choices

We want you to have control over your personal information. Depending on your jurisdiction, you have various rights regarding your personal data. Truecrush is committed to honoring these rights and providing you with easy ways to exercise them:

8.1 Account Controls and General Choices

  • Accessing and Updating Profile Data: You can access and update much of your personal information directly through your account profile settings. For example, you can edit your profile details, update your contact information, or change your preferences at any time. We encourage you to keep your information up-to-date.

  • Content Visibility and Sharing: You have control over what you share on Truecrush. You can choose what personal details to include on your public profile. You can also control your interactions: for example, you can block or report users if needed, and you can adjust privacy settings (if available) to manage who can see your content or send you messages.

  • Marketing Communications: If you have subscribed to receive marketing emails or newsletters from us, you can opt out at any time. Just click the “unsubscribe” link in any promotional email, or adjust your email preferences in your account settings. (Note that even if you opt out of marketing, we will still send essential service and account emails.)

  • Cookies Preferences: Through our cookie consent tool on the website, you can choose which non-essential cookies to accept or reject (see the Cookie Policy section for more details). You can also use your browser settings to delete or block cookies. Keep in mind some parts of the Service might not function properly if you disable certain cookies.

  • Device Permissions: On the mobile app, you can control what permissions you grant (e.g., location, camera, contacts). You can revoke any granted permission at any time in your device’s settings. Note that disabling certain permissions (like location or camera access) might limit functionality (e.g. you won’t be able to use location-based matching or upload photos).

8.2 Privacy Rights Under Various Laws

  • Access and Portability (GDPR/PDPA/CCPA): You have the right to request a copy of the personal data we hold about you and to obtain it in a commonly used, machine-readable format. This is often called the “right of access” or “data portability.” For example, EU and Singapore users can request we confirm if we process their personal data and get a copy of that data. California residents have a similar right to know the specific pieces of personal information we have collected about them in the past 12 months.

  • Correction (GDPR/PDPA/CPRA): If any of your personal data is inaccurate or incomplete, you have the right to ask us to correct or update it. In many cases, you can make changes yourself via your profile or settings (as noted above). If you need assistance with updating data you cannot correct yourself, contact us and we will address it. Singapore’s PDPA and various U.S. state laws (like the CPRA in California) also provide the right to correction of personal information.

  • Deletion and Erasure (GDPR/CCPA): You may request that we delete your personal data. This is sometimes called the “right to erasure” or “right to deletion.” For EU users, we will comply with such requests unless an exemption applies (for instance, if we need to keep certain data for legal compliance). For California residents, you have the right to request deletion of the personal information we collected from you (again, subject to certain exceptions under CCPA, such as if the information is needed to complete a transaction or for legal purposes). If you request deletion, we will remove your personal data from our records (and direct our service providers to do the same) except for information we are permitted or required to retain. The easiest way to delete most of your data is by deleting your Truecrush account in settings; this triggers the process described in the Data Retention section above.

  • Withdrawal of Consent (PDPA/GDPR): If we process your personal data based on your consent, you have the right to withdraw that consent at any time. For example, if you gave us consent to use your precise location or to process data you provided in a survey, you can change your mind and withdraw consent by changing your settings or contacting us. Once you withdraw consent, we will stop the processing for which consent was given, unless we have another legal basis to continue (e.g., we might still process your data if required by law). Withdrawal of consent does not affect any processing that has already occurred, and note that if you withdraw consent for essential data (like the data needed to operate your account), you may need to delete your account or some services might not be available.

  • Objection to Processing (GDPR): In certain circumstances, you have the right to object to our processing of your personal data. You can object at any time to the use of your data for direct marketing purposes - and we will honor that (as noted, you can unsubscribe from marketing communications easily). If our processing is based on legitimate interests, you also have a right to object if you have grounds relating to your particular situation. For example, if you believe our profiling for match suggestions significantly impacts you and you object, we will consider your request and stop or adjust processing unless we have compelling legitimate grounds to continue or it’s needed for legal reasons.

  • Restriction of Processing (GDPR): You can request that we restrict processing of your personal data in certain cases, such as while we address a correction request or an objection request, or if you believe our processing is unlawful but you prefer restriction over deletion. While restricted, your data will just be stored and not otherwise processed until the restriction is lifted (for example, until the issue is resolved).

  • Non-Discrimination (CCPA/US State Laws): We will not discriminate against you for exercising any privacy rights. For instance, if you are a California consumer and you exercise your rights under the CCPA (like requesting deletion or opting out of sale/sharing of your data), we will not deny you our services, charge you different prices, or provide you a lesser quality of service because of your choices. (However, please note that deleting data essential to the service may result in closure of your account since we cannot provide the service without that data - but that is a consequence of the choice, not an unlawful discrimination).

  • Right to Opt-Out of “Sale” or “Sharing” (CCPA/CPRA): Important: Truecrush does not sell your personal information for money. We also do not share personal information with third parties for their own cross-context behavioral advertising, as those terms are defined under California law. This means we haven’t disclosed or sold personal info to data brokers or advertisers in the conventional sense. If that ever changes, we will provide a “Do Not Sell or Share My Personal Information” link on our site and honor any opt-out preferences. Even though we do not sell data, California law broadly defines “sharing” to include some uses of advertising cookies and pixels. If you are concerned about this, you can disable advertising cookies and pixels in our cookie settings (see Cookie Policy) or use the Global Privacy Control (GPC) signal via your browser (we will treat a GPC signal as a valid opt-out of any “sharing” of personal data for analytics/advertising if applicable under law).

  • Other State Privacy Rights: If you are a resident of certain U.S. states (such as Virginia, Colorado, Connecticut, or Utah), you may have similar rights under new state privacy laws. These can include the right to confirm if we process your data, the right to access and delete personal data, the right to correct inaccuracies, the right to opt-out of targeted advertising or profiling, and the right to appeal a decision we make regarding a privacy request. Truecrush will honor those rights for residents of those states in a manner consistent with the descriptions above. If you want to exercise any specific state law right, please contact us as described below.

8.3 How to Exercise Your Rights

If you wish to exercise any of the rights described above, you can do so by:

  • Using in-app or website features: For example, to delete your account or update info, go to your account Settings and follow the instructions.

  • Contacting us: You can email our privacy team at [email protected] with your request, including the nature of your request (e.g., “Right of Access - Requesting my data” or “Deletion Request”) and verifying details of your account so we can locate your information. For security, we may need to verify your identity before processing certain requests (especially for access, portability, or deletion of sensitive data). We may ask for information like your login email and some verification information to ensure you are the account owner. If someone (like an authorized agent) is making the request on your behalf, we will require proof of authorization and verification of identity.

We will respond to your request within a reasonable timeframe as required by law. For example, under GDPR we typically have one month to respond (which can be extended in complex cases), and under CCPA we aim to respond within 45 days (with an extension of another 45 days if needed, with notice to you). There is generally no fee for making a request, but if requests become excessive or unfounded, we reserve the right (where permitted by law) to charge a reasonable fee or refuse the request.

If we cannot fulfill your request fully (due to legal exceptions or because it conflicts with other rights or legitimate interests), we will explain this in our response. For instance, we might reject a deletion request if we must retain certain data to comply with a legal obligation, or we might decline an access request if it would violate another user’s privacy or if your account has been involved in legal issues that are pending. We will, however, always comply with the law and provide an explanation.

8.4 Complaints

If you believe your privacy rights have been violated or you are not satisfied with our handling of your data or requests, you have the right to complain to a data protection authority.

  • EU/UK: You can lodge a complaint with the supervisory authority in the EU member state where you reside, where you work, or where the alleged infringement occurred. For example, if you’re in France, you could contact the CNIL; if in the UK, the ICO. We will cooperate fully with any such authority.

  • Singapore: You can file a complaint with the Personal Data Protection Commission (PDPC) in Singapore if you believe we are in breach of the PDPA.

  • California/US: While the U.S. does not have a central authority for privacy complaints, California residents have the right to contact the California Attorney General if they have concerns about how we handle their personal information. Other states may designate officials for complaints as well.

We encourage you to contact us first at [email protected] so we have the opportunity to address your concerns directly before you approach a regulator or authority. Your satisfaction is extremely important to us, and we will do our best to resolve any issues.

9. Security Measures

Truecrush takes the security of your personal data very seriously. We employ a range of technical and organizational security measures to protect your information from unauthorized access, alteration, disclosure, or destruction. These measures include:

  • Encryption: Our website is secured via industry-standard SSL/TLS encryption. This means data transmitted between your device and our servers (such as when you log in or send messages) is encrypted in transit. We also encrypt sensitive data at rest in our databases where feasible. For example, passwords are stored using strong hashing algorithms and never in plain text.

  • Access Controls: We restrict access to personal data to authorized employees, contractors, and service providers who need that information to perform their duties. All such persons are subject to strict confidentiality obligations. Within Truecrush, staff access to user data is limited based on role and is monitored. Administrative access to systems requires authentication and follows the principle of least privilege.

  • Secure Data Centers: We use reputable cloud and hosting providers that implement robust security practices (such as Amazon Web Services or similar, which maintain high security standards including firewalls, intrusion detection, and physical security controls at data center facilities).

  • Monitoring and Testing: We monitor our systems for possible vulnerabilities and attacks. Our technical team regularly updates software and infrastructure to address security issues. We use firewalls and may employ intrusion detection systems to guard our network. We also run periodic security audits and penetration testing through internal and/or external experts to test the strength of our safeguards.

  • Backup and Recovery: We routinely back up critical data to prevent data loss and have disaster recovery plans in place. Backups are encrypted and stored securely. In the event of a security incident, we have an incident response plan to promptly address and mitigate harm.

  • Payment Security: Any payment transactions are handled through PCI-compliant third-party processors. We do not store your full payment card details on our systems. Our partners apply robust security to protect financial information.

  • User Responsibilities: While we take many measures to safeguard data, it is also important for users to take steps for their own security. Choose a strong, unique password and keep your account credentials confidential. Be careful about sharing personal information in your profile or with others on the platform. If you suspect any unauthorized access to your account, please notify us immediately.

Despite all our efforts, please note that no method of transmission over the internet or method of electronic storage is 100% secure. While we strive to protect your personal data, we cannot guarantee its absolute security. In the unfortunate event of a data breach that affects your personal information, we will notify you and relevant authorities as required by law and work to mitigate any effects.

10. Children’s Privacy

As noted, Truecrush is strictly for users 18 years of age or older. We do not knowingly collect or solicit personal information from minors (children under 18). Our platform, content, and services are not directed to minors. If you are under 18, you are not allowed to use Truecrush or provide any information to us. If we discover that we have inadvertently collected personal data from a minor, we will promptly delete such information from our records. If you are a parent or guardian and believe your child (under 18) has provided personal information to us, please contact us immediately at [email protected] so that we can take appropriate action.

11. Changes to this Privacy Policy

We may update or revise this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. When we make significant changes to the way we handle your personal data, we will provide you with notice in appropriate ways. We may notify you by email (sent to the address associated with your account) or by posting a prominent notice on our website (for example, via a banner or modal). The “Last updated” date at the top of this Policy will always indicate when the latest changes were made.

We encourage you to review this Privacy Policy periodically to stay informed about our data practices and the ways you can protect your privacy. If you continue to use Truecrush after a revised Privacy Policy has been posted, it means you accept the changes. If you do not agree with the Policy or any updates to it, you should discontinue use of the Service and may delete your account at any time.

12. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or how Truecrush handles your personal data, please do not hesitate to contact us:

  • By Email: You can reach our data protection team at [email protected] . We will endeavor to respond promptly to any inquiries.

  • By Mail: You may also write to us at the following address:
    Truecrush Pte. Ltd.
    10 Anson Road, #10-11 International Plaza
    Singapore 079903
    Attn: Privacy Officer/Data Protection Officer

We are here to help and we take your privacy inquiries seriously. If you contact us to exercise a privacy right, please see Section 7.3 above for information we might need. For general questions about this Policy or our privacy practices, we will do our best to provide you with the information you need.

13. Governing Law and Dispute Resolution

As a Singapore-incorporated company, Truecrush operates under the laws of Singapore. This Privacy Policy, and any disputes arising from it or your use of our Service, shall be governed by Singapore law. We hope to resolve any privacy-related concerns in good faith through our support team. However, if a dispute arises relating to this Privacy Policy or our handling of personal data that cannot be resolved informally or through a regulator as outlined in Section 7.4, it shall be resolved through binding arbitration rather than in court, to the extent permitted by applicable law.

Arbitration Process: You and Truecrush agree that any dispute, claim, or controversy arising out of or relating to this Privacy Policy or our privacy practices will be settled by arbitration in Singapore, administered by an established arbitration body (such as the Singapore International Arbitration Centre) under its rules. The arbitration will be conducted in English by a single arbitrator. Each party will bear its own costs, and the arbitrator may award reasonable attorney’s fees to the prevailing party if appropriate. The arbitrator’s decision will be final and binding, and judgment on the award may be entered in any court having jurisdiction.

No Class Actions: You agree to resolve disputes with Truecrush on an individual basis. Neither you nor Truecrush will bring or participate in any class or representative action against the other party.

Exceptions: Notwithstanding the above, either party may bring issues to the attention of governmental agencies (for example, you can report issues to data protection authorities, as mentioned), and if the dispute involves a violation of intellectual property rights or unauthorized access (hacking) it may be brought to courts as appropriate. Also, if arbitration is not permitted by law for your dispute (for instance, some countries’ laws might not allow arbitration of certain privacy claims), then the disputes will be resolved by the competent courts in Singapore, and you agree to submit to the personal jurisdiction of such courts.

By using our Service, you acknowledge that you have read, understood, and agreed to this Privacy Policy, including the dispute resolution and arbitration provisions. We truly appreciate your trust in Truecrush and are committed to honoring that trust by keeping your information secure and private.

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