Privacy Policy

Effective Date: January 09, 2026
Last Updated: January 09, 2026

1. Who We Are

Circle of Nine Ltd
71-75 Shelton Street
Covent Garden
London, WC2H 9JQ
Email: hello@givrr.app
We are the data controller for the purposes of applicable data protection laws.

2. What Information We Collect

a. User-Provided Information:
– Name or alias
– Email address
– Password (hashed)
– Profile photos
– Optional content shared during chats
– Subscription settings (for creators)

b. Usage Data:
– IP address
– Device information
– Login timestamps
– Session activity
– Crash logs (for bug fixing)

c. Sensitive Features (Optional):
– Voice messages or video calls (not stored unless stated)
– Encrypted messages (end-to-end encrypted; we do not see message content)

3. How We Use Your Data

– Create and manage your account
– Provide core app functions (messaging, voice/video, user discovery)
– Ensure safety and prevent abuse (moderation, reporting tools)
– Enforce our Terms of Use
– Improve the app experience
– Comply with legal obligations

4. Lawful Basis for Processing

– Contractual necessity
– Consent

– Legitimate interests
– Legal obligations

5. Data Retention

We only retain your data for as long as needed to fulfill the purposes outlined in this policy or comply with legal obligations. You can delete your account and all associated data at any time via the app.

6. How We Protect Your Data

– Encrypted storage of personal data
– End-to-end encryption of messages
– Biometric protection for sensitive content (where enabled)
– Hosting on secure infrastructure (Hostinger)

7. Your Rights (UK/EU Users)

You have the right to:
– Access your personal data
– Request correction or deletion
– Withdraw consent at any time
– Object to processing for legitimate interests
– Lodge a complaint with the ICO (UK) or your local data authority

8. Who We Share Data With

We do NOT sell your data.
We may share it with:
– Hosting provider (Hostinger)
– Legal authorities (only if legally required)
– Payment providers (for creators, outside the app)

9. Cookies and Analytics

We may use essential cookies for login and performance. No third-party advertising cookies are used. Analytics (if implemented) will be privacy-safe.
You can adjust cookie preferences upon first visit or via the app settings.

10. International Transfers

If you are located outside the UK, we may transfer your data to the UK where our servers are located. We ensure all data transfers comply with GDPR and use standard contractual clauses when needed.

11. Children’s Data

Givrr is only available to users 18 years or older. We do not knowingly collect data from minors.

12. Changes to This Policy

We may update this Privacy Policy from time to time. If we make significant changes, we’ll notify you in-app or via email.

13. Contact Us

If you have any questions about this Privacy Policy, or wish to exercise your rights, please contact us at:
Email: hello@givrr.app