Privacy Policy

Effective Date: January 10, 2026
Last Updated: January 10, 2026

Introduction

Welcome to CruiseMates ("we," "our," or "us"). We are committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, store, and protect your data when you use our mobile application and services (collectively, the "Service").

By using CruiseMates, you agree to the collection and use of information in accordance with this policy. If you do not agree with our policies and practices, please do not use our Service.

Age Requirement

CruiseMates is intended for users who are 18 years of age or older. We do not knowingly collect personal information from individuals under 18. If we discover that a user under 18 has provided us with personal information, we will promptly delete such information from our systems.

Information We Collect

1. Information You Provide Directly

Account Information:

• Email address or phone number (for authentication)
• Display name
• Date of birth (to verify you are 18+)
• Profile photos

Profile Information:

• Bio/description
• Height
• Location (city and country)
• Occupation and education
• Languages spoken
• Interests and hobbies
• Gender identity and pronouns
• Sexual orientation
• Relationship style preferences
• What you're looking for (dating, friends, etc.)
• Body type (optional)

Cruise Information:

• Cruise line and ship details
• Voyage dates and itinerary
• Cabin number
• Port visit information

User Preferences:

• Age range preferences (18-99)
• Gender identity preferences
• Sexual orientation preferences
• Relationship style preferences
• Maximum distance preferences

Communications:

• Messages you send through our chat feature
• Reports and feedback you submit

Payment and Subscription Information:

• Premium pass purchases and transaction history
• Transaction IDs from Apple App Store or Google Play Store
• Purchase receipts (encrypted)
• Pass type, duration, and expiration dates
• Premium feature usage data
• Refund and cancellation history
• Payment processor information (we do not store credit card details)

2. Information Collected Automatically

Usage Data:

• Device information (type, operating system, unique device identifiers)
• IP address
• App usage patterns and interactions
• Log data (access times, pages viewed, app crashes)
• Last seen timestamp

Location Data:

• We collect location data based on the cruise ports and voyages you add to your profile
• We do not track your real-time GPS location

Device Tokens:

• Push notification tokens for iOS and Android devices

How We Use Your Information

We use the collected information for the following purposes:

Service Delivery

• Create and manage your account
• Enable profile creation and customization
• Facilitate matching with other users on the same or overlapping cruises
• Enable messaging between matched users
• Show you potential matches based on your preferences and cruise itinerary
• Send push notifications about matches, messages, and app updates
• Process and validate premium pass purchases
• Activate and manage premium features
• Track pass expiration and renewal eligibility
• Restore purchases across devices

Safety and Security

• Verify user age (18+ requirement)
• Prevent fraud, abuse, and unauthorized access
• Enforce our Terms of Service
• Investigate and respond to user reports
• Maintain audit logs for security purposes
• Validate purchase receipts with Apple and Google
• Detect and prevent fraudulent transactions
• Prevent duplicate or shared purchases
• Monitor for payment-related abuse
• Automated content moderation using third-party AI services (see AI Usage Policy below)

Service Improvement

• Analyze usage patterns to improve our Service
• Develop new features and functionality
• Troubleshoot technical issues
• Conduct research and analytics

Communications

• Send service-related announcements
• Respond to your inquiries and support requests
• Send marketing communications (with your consent, where required)

How We Share Your Information

With Other Users

• Your profile information (name, photos, bio, age, location, interests, cruise information) is visible to other users for matching purposes
• Your messages are shared with users you match with
• You control what information appears on your profile through privacy settings (e.g., show/hide age)

With Service Providers

We may share your information with third-party service providers who perform services on our behalf:

• Cloud hosting providers (for data storage)
• Analytics providers
• Push notification services
• Customer support tools
• Payment processors (Apple App Store, Google Play Store)
• Receipt validation services (Apple and Google APIs)

These providers are contractually obligated to protect your data and use it only for the purposes we specify. AI service providers are specifically prohibited from using your data for training, model development, or any purpose beyond immediate content moderation.

With Payment Processors

When you make a purchase:

• Payment information is processed directly by Apple App Store (iOS) or Google Play Store (Android)
• We receive transaction IDs and purchase receipts but never receive your credit card or payment details
• We validate receipts with Apple and Google to confirm purchase legitimacy
• Transaction data is used for fraud prevention and customer support

For Legal Reasons

We may disclose your information if required by law or in response to:

• Legal processes (subpoenas, court orders)
• Government requests
• Protection of our rights, property, or safety
• Investigation of fraud or security issues
• Enforcement of our Terms of Service

Business Transfers

If CruiseMates is involved in a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction. We will notify you of any such change.

With Your Consent

We may share your information for other purposes with your explicit consent.

AI Usage and Data Training Policy

Our Commitment to Your Privacy

CruiseMates uses artificial intelligence (AI) for content moderation purposes only. We are committed to protecting your privacy and data rights.

AI Content Moderation

We use enterprise-grade, third-party AI services to:

• Analyze profile bios for inappropriate content, hate speech, or policy violations
• Review photos for compliance with our content standards
• Detect spam, scams, and fraudulent activity
• Identify potential safety concerns in user-generated content

Strict No-Training Policy

We DO NOT use your data to train AI models. Specifically:

• Your personal information, profile data, photos, messages, and any user-generated content are NEVER used to train, improve, or develop any AI models or machine learning systems
• Third-party AI service providers we use are contractually prohibited from using your data for training purposes
• All AI processing is performed solely for real-time content moderation and safety purposes
• Your data is not retained by AI service providers beyond the immediate moderation task
• We do not sell, license, or share your data with AI companies for model training or development

AI Service Provider Requirements

All third-party AI services we use must:

• Process data solely for the specific moderation task requested
• Delete or anonymize data immediately after processing
• Maintain enterprise-grade security and privacy standards
• Comply with GDPR, CCPA, and other applicable data protection laws
• Provide contractual guarantees against data retention and training use
• Undergo regular security and compliance audits

Your Rights Regarding AI Processing

You have the right to:

• Know when AI is used to process your content (as disclosed in this policy and our Terms of Service)
• Object to AI processing of your data by discontinuing use of the Service
• Request deletion of your data from our systems

Automated Decision-Making: AI content moderation decisions do not produce legal or similarly significant effects on you. These decisions are made solely for safety, policy enforcement, and community standards compliance. AI moderation decisions are final and are not subject to human review or appeal.

For questions about our AI usage, contact us at privacy@cruisemates.app.

Data Storage and Security

Where We Store Your Data

Your data is stored on secure servers located in the United States. If you are accessing our Service from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States.

How We Protect Your Data

We implement industry-standard security measures to protect your personal information:

• Encryption of data in transit (HTTPS/TLS)
• Encryption of sensitive data at rest (including purchase receipts)
• Access controls and authentication
• Regular security audits and monitoring
• Secure backup procedures
• Receipt data encryption using AES-256
• Secure storage of transaction IDs with fraud detection monitoring

Payment Security:

• We never store credit card or payment method details
• All payment processing is handled by Apple and Google
• Purchase receipts are encrypted before storage
• Transaction validation uses secure APIs

However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your personal information, we cannot guarantee absolute security.

Data Retention

We retain your personal information for as long as necessary to provide our Service and fulfill the purposes outlined in this Privacy Policy:

• Active Accounts: We retain your data while your account is active
• Deleted Accounts: When you delete your account, we will delete or anonymize your personal information within 30 days, except where we are required to retain it for legal or regulatory purposes
• Messages: Messages are retained as long as both users maintain their accounts
• Audit Logs: Security and audit logs may be retained for up to 2 years for fraud prevention and security purposes
• Transaction Records: Purchase history, transaction IDs, and receipts are retained for up to 7 years for tax, legal, and fraud prevention purposes
• Subscription Events: Premium pass activation, expiration, and usage events are retained for up to 2 years for analytics and customer support

Your Rights and Choices

Depending on your location, you may have the following rights:

Access and Portability

• Request a copy of your personal information
• Download your data in a portable format

Correction

• Update or correct your profile information at any time through the app settings

Deletion

• Delete your account and associated data
• Request deletion of specific information

Objection and Restriction

• Object to certain processing of your data
• Request restriction of processing in certain circumstances

Withdraw Consent

• Withdraw consent for data processing where we rely on consent
• Opt-out of marketing communications

Do Not Sell My Personal Information (CCPA)

• We do not sell your personal information to third parties

To exercise these rights, please contact us at privacy@cruisemates.app

Cookies and Tracking Technologies

We use cookies and similar tracking technologies to:

• Maintain your session
• Remember your preferences
• Analyze app usage
• Improve our Service

You can control cookies through your device settings, but disabling cookies may limit your ability to use certain features of our Service.

Third-Party Links

Our Service may contain links to third-party websites or services. We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies before providing any personal information.

Children's Privacy (COPPA Compliance)

Our Service is not intended for children under 18. We do not knowingly collect personal information from anyone under 18 years of age. If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately at privacy@cruisemates.app, and we will delete such information from our systems.

International Data Transfers

If you are located outside the United States, please be aware that your information will be transferred to and processed in the United States. By using our Service, you consent to the transfer of your information to the United States and other countries where we operate.

For users in the European Economic Area (EEA), United Kingdom, and Switzerland, we comply with applicable data protection laws, including the GDPR, and implement appropriate safeguards for international data transfers.

Your California Privacy Rights (CCPA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA):

• Right to Know: Request information about the categories and specific pieces of personal information we collect
• Right to Delete: Request deletion of your personal information
• Right to Opt-Out: Opt-out of the sale of personal information (we do not sell your information)
• Right to Non-Discrimination: We will not discriminate against you for exercising your CCPA rights

To exercise these rights, contact us at privacy@cruisemates.app or call 1-XXX-XXX-XXXX.

European Privacy Rights (GDPR)

If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, you have rights under the General Data Protection Regulation (GDPR):

• Legal Basis for Processing: We process your data based on consent, contract performance, legitimate interests, and legal obligations
• Data Protection Officer: Contact our DPO at dpo@cruisemates.app
• Right to Lodge a Complaint: You may file a complaint with your local data protection authority
• Data Breach Notification: We will notify you and relevant authorities within 72 hours of discovering a data breach

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of any material changes by:

• Posting the updated policy in the app
• Sending you an email notification
• Displaying a prominent notice in the app

Your continued use of the Service after changes become effective constitutes acceptance of the updated Privacy Policy.

Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

Email: privacy@cruisemates.app
Mail: CruiseMates Privacy Team
Emptyset Solutions LLC
611 South DuPont Highway, Suite 102
Dover, Delaware 19901

Data Protection Officer: dpo@cruisemates.app

Consent

By using CruiseMates, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and sharing of your information as described herein.

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This Privacy Policy is effective as of January 10, 2026.