Introduction

Famylup Sàrl-S ("Famylup", "we", "us", "our") is committed to protecting your personal data and your privacy.

This Privacy Policy explains how we collect, use, process, and protect your data when you use the Famylup platform (the "Platform"), in accordance with the General Data Protection Regulation (EU) 2016/679 ("GDPR").

What Data We Collect

We may collect the following categories of personal data:

a) Account Information

• Name
• Email address
• Date of birth
• Gender
• Profile information (photos, description, preferences)

b) Sensitive Data (Special Categories)

• Biometric data (facial recognition for identity verification)
• Information related to family intentions (e.g. desire to have children, parenting preferences)

c) Usage Data

• App activity and interactions
• Messages within the platform
• Log data (IP address, device type, browser)

d) Location Data

• Approximate location

Purpose of Processing

We process your data to:

• Create and manage your account
• Provide matching services based on your choices
• Enable communication between users
• Ensure platform safety and prevent fraud
• Verify user identity
• Improve the platform and user experience
• Comply with legal obligations

Legal Basis for Processing

We rely on the following legal bases:

• Contractual necessity – to provide the service
• Legitimate interests – to improve and secure the platform
• Explicit consent – for sensitive data (e.g. biometric data)
• Legal obligations – where required

Biometric Data Processing

We process biometric data for identity verification, fraud prevention, detection of duplicate or fake profiles, protection against automated (bot) activity, and to maintain the integrity and safety of the platform for all users.

Processing is based on explicit consent (Art. 9 GDPR).

Sharing of Data

We may share your data with:

a) Service Providers

• Hosting providers
• Identity verification providers (e.g. Veriff or equivalent)
• Analytics tools

b) Legal Authorities

• When required by law

We do not sell your personal data.

International Transfers

If data is transferred outside the European Economic Area (EEA), we ensure appropriate safeguards, such as:

• Standard Contractual Clauses (SCCs)
• GDPR-compliant providers

Data Retention

We retain your data only as long as necessary:

• Account data → while your account is active
• Biometric data → limited to verification purposes
• Legal data → as required by law

You may request deletion at any time.

Your Rights

Under GDPR, you have the right to:

• Access your data
• Rectify inaccurate data
• Request deletion ("right to be forgotten")
• Restrict processing
• Object to processing
• Data portability
• Withdraw consent at any time

Contact: privacy@famylup.com

Data Security

We implement appropriate measures, including:

• Encryption
• Secure servers
• Access controls

However, no system is 100% secure.

User Safety & Moderation

To ensure a trusted environment, we may:

• Monitor activity for fraud or abuse
• Moderate content
• Suspend or remove accounts violating our policies

Children

Famylup is not intended for users under 21 years old.

We do not knowingly collect data from minors.

Cookies & Tracking

We may use cookies or similar technologies to:

• Improve user experience
• Analyse usage

You can manage cookie preferences via your browser or device settings.

Third-Party Links

Our platform may contain links to third-party services or content.

We are not responsible for their privacy practices.

Changes to this Policy

We may update this Privacy Policy from time to time.

Users will be notified of significant changes.

Contact

For any privacy-related questions:

privacy@famylup.com
Famylup Sàrl-S
Luxembourg