Privacy Policy

1. Introduction and Scope

This Privacy Policy explains how [Legal Entity Name] ("MNF," "we," "us," or "Company"), established in the Republic of Azerbaijan, collects, uses, discloses, and protects personal data when you use the MNF – Make New Friends mobile application, website, and related services (the "Service").

This Policy applies to all users worldwide. It is incorporated by reference into our Terms of Service. Certain sections of this Policy (Sections 14 and 15) provide additional disclosures required for users in specific regions, such as the European Economic Area, United Kingdom, and California.

2. Who We Are — Data Controller and Contact

For the purposes of applicable data protection law, the data controller responsible for your personal data is: support@fortcoretech.net.

3. Personal Data We Collect

3.1 Information You Provide Directly

• Account information: email address and/or phone number, password, date of birth, gender, and gender you're interested in matching with;
• Profile information: name or display name, photos, bio/description, interests, and any other details you choose to add to your profile;
• Communications: messages you send to other users through the Service, and messages you send to our support team;
• Preferences: matching preferences, age range, distance range, and similar settings;
• Payment-related information: if you purchase a Subscription, your purchase is processed by the applicable app store (Apple App Store / Google Play) or our designated payment processor — we receive confirmation of your purchase and subscription status, but we do not collect or store your full payment card details ourselves.

3.2 Information Collected Automatically

• Device information: device type, operating system, unique device identifiers, browser type, and mobile network information;
• Usage data: features used, profiles viewed, matches, likes/passes, time spent in the app, and interaction patterns;
• General location: we determine your approximate location at a city/country level (for example, from your IP address or a location you enter) in order to show you nearby matches. We do not currently collect precise GPS location.

3.3 Information From Other Sources

• If you register or log in using a third-party account (for example, Google or Apple sign-in), we receive basic profile information from that provider as authorized by you and by that provider's permissions;
• Information other users provide about you, such as when they report you or reference you in a support request.

3.4 Information We Do Not Currently Collect

We do not currently require government ID or facial/selfie verification to create an account, and we do not currently collect precise GPS location. If we introduce identity verification or precise location features in the future, we will update this Policy and provide notice before the change takes effect, and will describe any new data collected and the purpose for it.

4. Special Category (Sensitive) Data

5. How We Use Your Data

We use your personal data to:

• Create and manage your Account, and authenticate your identity when you log in;
• Operate core Service features, including generating match suggestions, displaying profiles, and enabling messaging;
• Process Subscription purchases and manage your billing status (via the app store/payment processor);
• Maintain the safety, security, and integrity of the Service, including fraud prevention, spam/bot detection, content moderation, and enforcement of our Terms of Service, and to detect and report child sexual abuse material or exploitation as described in our Terms;
• Respond to your support requests and communicate with you about your Account or the Service;
• Analyze and improve the Service, including troubleshooting and understanding feature usage;
• Comply with legal obligations, respond to lawful requests from public authorities, and establish, exercise, or defend legal claims;
• Once implemented, serve and measure advertising within the free version of the Service, and analyze app performance, using third-party analytics and advertising partners (see Section 9).

6. Legal Bases for Processing (EEA/UK Users)

Where GDPR or UK GDPR applies, we rely on the following legal bases:

• Performance of a contract — to create your Account, operate core features, and process Subscriptions;
• Consent — for special category data you choose to share, for marketing communications where required, and for non-essential cookies/advertising once implemented;
• Legitimate interests — for safety and fraud prevention, service improvement, and basic analytics, balanced against your rights and interests;
• Legal obligation — to comply with applicable law, respond to lawful requests, and meet reporting obligations such as those relating to child safety.

7. How We Share Your Data

We do not sell your personal data to third parties for money. We may share personal data with:

• Other users: your profile information (name/display name, photos, bio, general location, age) is visible to other users as part of the core functioning of the Service; messages are visible to the recipient;
• Service providers: hosting and cloud infrastructure providers, customer support tooling, and, once implemented, analytics and advertising partners, who process data on our behalf under contractual confidentiality and data protection obligations;
• App stores and payment processors: Apple, Google, or other payment processors, to process Subscription purchases;
• Legal and safety: law enforcement, regulators, or other third parties where required by law, to protect the rights, property, or safety of MNF, our users, or the public, or to detect, prevent, or address fraud, security, or technical issues, including child safety reporting to bodies such as NCMEC where applicable;
• Business transfers: a successor entity in connection with a merger, acquisition, financing, or sale of assets, subject to this Policy or a policy providing at least equivalent protections.

8. Cookies and Similar Technologies

Our website and app may use cookies, SDKs, or similar technologies to keep you logged in, remember your preferences, and (once implemented) measure app performance and deliver and measure advertising. Where required by law (for example, under the EU/UK ePrivacy rules), we will request your consent before setting non-essential cookies or SDKs and will provide a way to manage your preferences.

9. Advertising and Analytics

MNF is free to use with in-app Advertising. We are not currently using third-party advertising or analytics SDKs, but we plan to integrate industry-standard providers (for example, tools comparable to Google Analytics, Meta Audience Network, or Google AdMob) to serve and measure ads and to understand app usage. Once integrated, these providers may collect device identifiers, general location, and usage data directly, and may use this information to personalize ads, subject to your choices and applicable law (including opt-out and consent mechanisms required by GDPR/ePrivacy, and “Sale/Share” and “Targeted Advertising” opt-outs required by US state privacy laws).

10. Data Retention

We retain personal data for as long as your Account is active and as needed to provide the Service. If you delete your Account, we will delete or anonymize your personal data within [30/90] days, except where we are required or permitted to retain it for longer — for example, to comply with legal obligations, resolve disputes, enforce our agreements, or preserve records relating to safety violations (including child safety matters, which may require longer retention for law enforcement cooperation).

11. International Data Transfers

MNF is established in the Republic of Azerbaijan and serves users worldwide. Your personal data may be transferred to, stored, and processed in Azerbaijan and in other countries where our service providers operate (including hosting and, once implemented, analytics/advertising providers), which may have different data protection laws than your home country.

Where required by applicable law, we will implement appropriate safeguards for such transfers — for example, Standard Contractual Clauses for transfers of personal data out of the EEA/UK, and compliance with the cross-border transfer requirements of the Azerbaijani Law “On Personal Data” (No. 998-IIIQ) for transfers of data collected in Azerbaijan to other countries.

12. Data Security

We use technical and organizational measures designed to protect personal data against unauthorized access, alteration, disclosure, or destruction, including encryption in transit, access controls, and vetting of service providers. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

13. Children's Privacy

14. Your Rights — EEA, UK, and Similar Jurisdictions

If GDPR, UK GDPR, or a similar law applies to you, you have the right to:

• Access the personal data we hold about you;
• Rectify inaccurate or incomplete personal data;
• Erase your personal data (“right to be forgotten”), subject to certain exceptions;
• Restrict or object to our processing of your personal data, including processing based on legitimate interests and, where applicable, direct marketing;
• Data portability — receive your data in a structured, commonly used format, or have it transferred to another provider where technically feasible;
• Withdraw consent at any time, where processing is based on consent, without affecting the lawfulness of processing before withdrawal;
• Lodge a complaint with your local data protection supervisory authority.

You can exercise these rights by contacting us at support@fortcoretech.net. We may need to verify your identity before fulfilling your request.

15. Your Rights — California and Other US State Laws

If the California Consumer Privacy Act (CCPA), as amended by the CPRA, or a similar US state privacy law applies to you, you have the right to:

• Know and access the categories and specific pieces of personal information we have collected about you;
• Delete personal information we have collected from you, subject to certain exceptions;
• Correct inaccurate personal information;
• Opt out of the “sale” or “sharing” of your personal information (including for cross-context behavioral advertising), once any such sale/sharing begins via advertising SDKs;
• Limit the use of “sensitive personal information” (which may include information revealing sexual orientation) to purposes necessary to provide the Service;
• Not receive discriminatory treatment for exercising any of these rights.

You can submit a request by emailing support@fortcoretech.net. We do not currently sell personal information for monetary consideration. Once advertising SDKs are integrated, certain data sharing with ad partners may be considered a “share” under CPRA, and we will provide a “Do Not Sell or Share My Personal Information” mechanism at that time.

16. Your Rights — Azerbaijan

If the Law of the Republic of Azerbaijan “On Personal Data” (No. 998-IIIQ) applies to your data, you have rights consistent with that law, including the right to know what data of yours is processed, to request correction of inaccurate data, to request cessation of processing or destruction of your data in the cases provided by that law, and to change the confidentiality status of your own data. You may exercise these rights by contacting us at support@fortcoretech.net.

17. Marketing Communications

We may send you Service-related communications (such as safety notices, security alerts, or Account confirmations) which you cannot opt out of while your Account is active. We may also send optional marketing communications, which you can opt out of at any time via the unsubscribe link in the email or through your in-app notification settings.

18. Automated Decision-Making and Profiling

MNF uses algorithmic features to suggest potential matches and rank or order profiles based on your activity, preferences, and general location. These features assist you in browsing the Service but do not produce legal or similarly significant effects about you, and they do not replace human judgment about who you choose to interact with. Where applicable law grants you rights regarding automated decision-making, you may contact us to learn more or to request human review of any decision that significantly affects you.

19. Third-Party Links and Services

The Service may contain links to, or integrations with, third-party services (such as social sign-in providers or, once implemented, advertising partners). This Policy does not apply to those third parties' own data practices, and we encourage you to review their privacy policies separately.

20. Changes to This Policy

We may update this Privacy Policy from time to time, including as we integrate new features such as advertising/analytics SDKs or identity verification. If we make material changes, we will provide notice (for example, by in-app notice or email) before the changes take effect. The “Last updated” date at the top of this Policy indicates when it was last revised.

21. Contact Us

If you have questions, requests, or complaints about this Privacy Policy or our data practices, contact us at: support@fortcoretech.net.