Privacy Policy

1.Scope and who we are

This Privacy Policy applies to nurq, a website and mobile application and related services operated by Happiness Factor, LLC, a limited liability company organized under the laws of the State of New York, United States. Happiness Factor, LLC is the controller responsible for your personal information.

By using the Service, you agree to this Privacy Policy and to our Terms & Conditions.

2.Information we collect

During the pre-launch waitlist phase, the only information we collect is your email address and the date you joined. Once the app launches, we collect the following categories of personal information:

Information you provide to us

Information collected automatically

Information from third parties

3.Sources of information

We collect personal information from the following sources:

• Directly from you when you join the waitlist, create an account, complete your profile, message other users, submit AI prompts, or contact support.
• Automatically from your device when you use the Service.
• From service providers such as Supabase (our database and storage provider), RevenueCat (subscription management), and Apple (authentication and payments).

4.How we use information

We use personal information for the following business purposes:

• Operate the waitlist. Notify you when nurq launches and send occasional pre-launch updates.
• Provide the Service. Create and manage your account, show you potential matches, deliver messages, process likes and super likes.
• Match compatibility. Compare your values, life goals, and preferences with other users to surface people you may be compatible with. See Section 5 for details.
• Process subscriptions. Determine whether you have access to paid features and manage your subscription state.
• Operate AI-powered features. Generate responses to prompts you submit and provide context-relevant reflections (see Section 10 for details).
• Community safety. Detect, investigate, and prevent fraud, abuse, harassment, spam, and Terms & Conditions violations. Handle reports and block/unmatch requests.
• Communicate with you. Send account, service, safety, and support messages. If you opt in, send you marketing or product updates.
• Improve the Service. Understand how users use nurq to fix bugs, improve features, and build new ones. We use aggregated or de-identified information where practical.
• Comply with law. Respond to legal requests, enforce our Terms, and protect our and others' rights, safety, and property.

5.Matching, recommendations, and profiling

We use profile information, preferences, activity, and compatibility signals to recommend profiles, rank potential matches, and personalize the Service.

We do not use these signals to make legal, financial, employment, housing, credit, immigration, healthcare, or other similarly significant decisions about you.

Recommendations, compatibility signals, prompts, rankings, or suggested next steps are not determinations of a person's character, safety, honesty, or suitability. See our Terms & Conditions for related limits on relying on AI or compatibility outputs.

6.Sensitive personal information

Because nurq is a matching and life-planning platform, some information you provide or that we may infer can be considered sensitive under privacy laws such as the California Consumer Privacy Act and, in the EU/UK, "special category" data under the GDPR. Depending on what you choose to share, this may include:

• Gender identity.
• Information from which sexual orientation or partnership preferences may be inferred.
• Religious or philosophical beliefs.
• Cultural or ethnic identity.
• Family-planning preferences and relationship goals.
• Photos that reveal your identity or physical characteristics.
• Approximate location.

We use sensitive personal information only for the purposes described in this Policy, including operating the matching Service, keeping the community safe, and complying with law. We do not use or disclose sensitive personal information for purposes that require the right to limit under California law. Where the GDPR applies, we process special category data that you make part of your profile on the basis of your explicit consent, which you give by choosing to add it, and which you may withdraw at any time by editing your profile or deleting your account.

7.Information visible to other users

nurq is a social product. Some of what you share is visible to other users by design:

• Your profile, including display name, age, pronouns, photos, prompt answers, values, and location at the neighborhood/city level.
• Any messages, likes, notes, or content you send to other users.
• Whether you're currently active or recently active on the platform.

Your profile and photos are visible only to other authenticated members who are entitled to see them — members eligible to discover you, and members you have matched with. Your photos are stored privately and are not publicly accessible. A member loses this access if you block them or they block you, if either of you ends the match, or if their account is suspended or removed. Because a member may already have loaded a photo before access is withdrawn, we cannot guarantee the removal of images already displayed on someone's device.

Assume that anything you put on your profile could be viewed, screenshotted, or shared by another user. Be thoughtful about what you choose to include, especially about sensitive topics like religion, family plans, immigration status, or finances.

We cannot control what other users do with information you choose to share with them.

8.How we share information

We share personal information only in the ways described below.

With other users

See Section 7. Your profile and messages are visible to users you interact with or who see your profile in Discover, Likes, or Cherry Picks.

With service providers

We share personal information with vendors and service providers who help us operate the Service. Current providers include:

These providers are contractually required to protect personal information and use it only to provide services to us. We do not give service providers permission to use your personal information for their own marketing or unrelated purposes. AI-powered features may involve additional third-party providers; see Section 10.

For safety and legal reasons

We may share information when we believe it is reasonably necessary to comply with law, respond to legal process, enforce our Terms, protect users from harm, investigate fraud, or protect our rights, property, or safety.

If you report another user, we may review your report, relevant profile information, messages, photos, account activity, and related metadata to investigate the report and enforce our rules.

In connection with a business transaction

If we're involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of assets, personal information may be transferred as part of that transaction. We will use reasonable efforts to notify you of any material change to how your information is handled.

With your consent

We may share information in other ways with your explicit consent.

9.Advertising and analytics

We do not sell personal information for money and we do not share personal information for cross-context behavioral advertising.

Before adding analytics, advertising, attribution, or crash-reporting providers that would receive personal information, we will update this Policy to describe those providers and the categories of information they receive.

10.AI features and your content

nurq may offer AI-powered features that help users reflect on compatibility, communication, life planning, and related topics. Because those features can process content you share, we explain how they work below.

What AI features process

When you use an AI feature we offer:

• The feature may process content you provide during the interaction, such as prompts, questions, or conversational input.
• The feature may also use context from your profile or activity to make responses relevant to you.

Please do not submit information to AI features that you do not want processed for the purposes described in this Policy.

Third-party AI providers

AI features may be powered by third-party AI service providers (for example, large language model providers). When we route content through a third-party provider, we do so under contracts that require the provider to:

• Process content only to provide the feature we requested;
• Not use content submitted through nurq to train or improve the provider's own general models, where the provider offers that setting and we have selected it;
• Maintain appropriate security and confidentiality safeguards.

AI providers may process data in facilities located outside your state or country, subject to their agreements with us. We will identify current AI providers in this Section as our stack evolves.

Training and model improvement

We do not currently use your personal information, messages, profile answers, or AI prompts to train AI models that nurq owns or controls.

If we introduce features in the future that would use your content to train nurq-owned models, we will:

• Update this Privacy Policy;
• Provide meaningful notice before the change takes effect; and
• Where required by law, obtain your consent or offer an opt-out.

Human review

We may review AI-generated content or user reports about AI outputs to investigate abuse, improve safety, or comply with law. Human review is limited to what is reasonably necessary for those purposes.

Data minimization

Where practical, we minimize the personal information we pass to AI providers and avoid sending sensitive identifiers that are not needed for the feature to work.

Reminder on reliance

AI outputs are for reflection and general information. See our Terms & Conditions for important limitations on relying on AI-generated content.

11.Retention

We retain personal information for as long as we need it to operate the Service, comply with our legal obligations, resolve disputes, and enforce our agreements. Approximate retention periods:

• Waitlist email: retained until nurq launches and you have had a reasonable opportunity to create an account, or until you ask us to remove it — whichever comes first. You can request removal at any time by emailing [email protected].
• Account and profile information: retained while your account is active. After account deletion, we generally delete or de-identify account and profile information within 60 days, unless we need to retain certain information for legal, safety, fraud-prevention, billing, dispute, or security reasons.
• Messages and likes: retained while your account is active. Messages may remain visible to recipients after you delete your account, but your profile may no longer be associated with them, unless retention is required for safety, legal, or abuse-prevention reasons.
• Subscription and billing records: retained as required for tax, accounting, and audit purposes (typically 7 years).
• Safety and abuse records: retained as long as reasonably necessary to prevent repeat abuse, investigate reports, and comply with law.
• Log data: retained approximately 90 days for troubleshooting and security, unless a longer period is needed to investigate an incident.
• AI prompts and inputs (ephemeral processing): prompts you submit to AI features are retained only as long as needed to generate the AI response and provide the feature, and in any case no longer than 90 days, unless a longer retention period is required for safety, moderation, legal, or debugging purposes.
• Saved AI content (if offered): if we introduce features that allow you to explicitly save AI-generated content to a nurq-managed history, reflections, or notes area, that saved content is separate from ephemeral prompt processing and is retained according to that feature's settings, which we will describe in this Policy at the time the feature launches.

12.Security

We use commercially reasonable administrative, technical, and physical safeguards to protect personal information. These include encrypted connections, access controls, authentication, and vetted service providers with their own security programs.

No system is perfectly secure. If we become aware of a data breach affecting your personal information, we will notify you as required by applicable law.

You can help protect your account by using a strong, unique password, keeping your device's OS updated, and reporting suspicious activity to us at [email protected].

13.Your privacy rights

Depending on where you live, you may have some or all of the following rights regarding your personal information:

• Access. Request a copy of the personal information we hold about you.
• Correction. Ask us to correct inaccurate personal information.
• Deletion. Ask us to delete your personal information, subject to certain exceptions (for example, information we need to keep to prevent fraud or comply with law).
• Portability. Request a copy of your personal information in a portable format.
• Opt out of sale or sharing. Direct us not to sell or share your personal information (though as noted above, we do not sell or share for cross-context behavioral advertising).
• Limit use of sensitive personal information. In some cases, direct us to limit our use of your sensitive personal information.
• Withdraw consent. Where we rely on your consent, withdraw it at any time (this does not affect processing already carried out).
• Non-discrimination. Not be discriminated against for exercising your privacy rights.

Residents of the EU/UK have additional rights described in Section 16.

How to submit a request

If you're on the waitlist, you can have your email removed by emailing us. Once the app launches, you can delete your account directly in the nurq app from the Profile or Settings screen. You can also email us at [email protected] with the subject line "Privacy Rights Request" and include the email address associated with your nurq account and a description of what you're asking for. We may need to verify your identity before we can respond.

Authorized agents

If you are a California resident, you may use an authorized agent to submit a request on your behalf. We may require the agent to provide proof of your authorization and may still ask you to verify your identity.

14.California-specific disclosures

If you are a California resident, the California Consumer Privacy Act, as amended ("CCPA"), provides you with additional rights and requires us to make additional disclosures.

Categories of personal information we collect and share

In the past 12 months (or, if we've been in operation for less time, since we started operating), we have collected the following CCPA categories of personal information:

• Identifiers (email, account ID, device identifiers)
• Customer records information (profile information, photos)
• Characteristics of protected classifications (age, gender identity)
• Commercial information (subscription status, purchase history via app store)
• Internet or other electronic network activity information (usage data, app interactions)
• Geolocation data (approximate location; we do not collect precise GPS location)
• Audiovisual information (photos you upload)
• Inferences (compatibility signals derived from your profile and activity)
• Sensitive personal information (see Section 6)

We collect these categories from the sources described in Section 3 and use them for the purposes described in Sections 4, 5, and 10.

We disclose these categories to the service providers listed in Sections 8 and 10.

No sale or sharing for cross-context behavioral advertising

We do not sell personal information and do not share personal information for cross-context behavioral advertising.

Right to know, delete, correct, and limit

California residents have the rights described in Section 13. To exercise a right, email [email protected] with the subject line "Privacy Rights Request."

Shine the Light

California's "Shine the Light" law entitles California residents to request certain information about our disclosures of personal information for direct marketing purposes. We do not currently share personal information with third parties for their direct marketing purposes.

15.Other U.S. state privacy rights

Depending on where you live, including in certain U.S. states with comprehensive privacy laws (such as Virginia, Colorado, Connecticut, Utah, Texas, Oregon, and others), you may have rights similar to those described in Section 13, including the right to access, correct, delete, obtain a portable copy of your personal information, and opt out of targeted advertising, sale of personal information, and certain profiling.

To exercise these rights, email [email protected]. If we deny your request, you may have the right to appeal — email us and we will describe the appeal process.

16.EU, UK, and other international users (GDPR)

nurq is offered worldwide. Happiness Factor, LLC is based in the United States, and your personal information is transferred to, stored, and processed in the United States and in other countries where our service providers operate. Privacy laws in those countries may differ from the laws where you live.

Our legal bases for processing (EU/UK GDPR)

If you are in the European Economic Area, the United Kingdom, or Switzerland, we process your personal information on the following legal bases:

• Performance of a contract — to provide the Service you sign up for, including creating your account and delivering matches and messages.
• Consent — to add you to our waitlist and send you pre-launch updates, to process any special-category data you choose to put in your profile (see Section 6), and for other processing where we ask for your consent. You can withdraw consent at any time.
• Legitimate interests — to keep the community safe, prevent fraud and abuse, secure and improve the Service, and run our business, provided those interests are not overridden by your rights.
• Legal obligation — to comply with applicable laws and respond to lawful requests.

Your GDPR rights

Subject to applicable law, you have the right to access, rectify, erase, restrict, or object to our processing of your personal information; to data portability; and to withdraw consent. You also have the right to lodge a complaint with your local data protection authority (in the UK, the Information Commissioner's Office).

International data transfers

When we transfer personal information out of the EEA, UK, or Switzerland, we rely on appropriate safeguards where required, such as the European Commission's Standard Contractual Clauses (and the UK Addendum), or another lawful transfer mechanism.

How to exercise these rights

Email [email protected]. We will respond within the timeframes required by applicable law.

17.Children's privacy

nurq is intended for adults age 18 and older. We do not knowingly collect personal information from anyone under 18.

If you believe we have collected personal information from a person under 18, please contact us at [email protected] and we will take steps to delete the information.

18.Third-party links and services

The Service may contain links to third-party websites, apps, or services that are not operated by us. This Policy does not apply to those third parties. We encourage you to review the privacy policies of any third parties whose services you use.

19.Changes to this Policy

We may update this Privacy Policy from time to time. If we make material changes, we will provide notice through the app, by email, or by another reasonable method before the changes take effect.

The updated Policy will be effective as of the "Last updated" date shown above unless otherwise stated. Your continued use of the Service after changes become effective means you accept the updated Policy.

20.Contact us

If you have questions or requests related to this Privacy Policy or your personal information, contact us at: