PRIVACY POLICY
Last updated: 2025-07-20

1. Introduction
Doppi, Inc. ("ValuesVibe," "we," "us," or "our") respects your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use the ValuesVibe mobile or web application (the "Service") in the United States, Canada, and the United Kingdom.

2. Scope
This Policy applies to personal information we process about individual users of the Service. It does not apply to third-party websites or services that we do not control.

3. Information We Collect
Category Examples Source
Account Information Name, email, phone, password You
Profile Details Age, gender, occupation, education, city, religious affiliation (sensitive), dating preferences You
Transaction Data Payment card tokens, billing address, amount paid, refunds Stripe
Usage Data IP address, device ID, browser, app version, date/time, pages viewed, referral URLs Automated
Cookies & Similar Tech Session cookies, analytics cookies, marketing tags Automated
Communications Messages with support, feedback surveys, in-app reports You

Sensitive Data Notice: By joining a specific Vibe (e.g., Sikh Vibe), you voluntarily provide information that may reveal your religious beliefs. You may withdraw consent at any time by deleting your account.

4. Legal Bases for Processing (EU/UK Users)
We process personal information based on:
- Contract Performance: To provide matchmaking services and process payments
- Legitimate Interests: For fraud prevention, analytics, and service improvement
- Consent: For sensitive data, marketing communications, and non-essential cookies
- Legal Obligations: To comply with tax, accounting, and safety requirements

5. How We Use Your Information
We process personal information to:

Provide & operate the Service (matchmaking, date scheduling, payments).

Verify identity & ensure safety, including fraud prevention.

Facilitate payments and issue refunds.

Send transactional and marketing communications (you can opt out of marketing).

Improve the Service via analytics and research.

Comply with legal obligations and enforce our Terms of Service.

6. How We Share Information
Recipient Purpose Legal Safeguards
Other Users Limited profile data shared after you match; photos released only after the first in-person date. Consent-based matching
Service Providers Payment processing (Stripe), hosting, analytics, customer support Data Processing Agreements with appropriate safeguards
Affiliates & Business Transfers In case of merger, acquisition, or asset sale Subject to privacy obligations
Legal & Safety To comply with subpoenas, court orders, or protect rights, safety, or property Legal obligation or legitimate interest

We do not "sell" your personal information as defined by privacy laws. We may "share" limited data for cross-context behavioral advertising; you can opt out (Section 9).

7. International Data Transfers
We operate primarily in the United States. For users outside the US:

Canada: We may transfer data to the US under adequacy decisions or with appropriate safeguards
UK/EU: We implement appropriate safeguards including Standard Contractual Clauses and adequacy decisions where available

Transfer Safeguards:
- Standard Contractual Clauses (SCCs) approved by relevant authorities
- Adequacy decisions where available
- Technical and organizational measures to protect data

8. Cookies & Tracking
We use cookies and similar technologies for:
- Essential: Authentication, security, fraud prevention
- Analytics: Google Analytics to understand usage patterns  
- Marketing: Targeted advertising (with consent where required)

Cookie Management:
- Essential cookies: Cannot be disabled as they're necessary for service operation
- Non-essential cookies: You can manage preferences in our cookie banner or browser settings

9. Data Retention
We retain personal information as long as necessary for the purposes stated above:

Active account: Until you delete it
Deleted accounts: 30 days (for recovery), then permanently deleted except for legal obligations
Transaction records: 7 years (tax & accounting requirements)
Marketing data: Until you unsubscribe plus reasonable period for processing
Legal claims: As required by applicable limitation periods

10. Your Privacy Rights
Your rights vary by jurisdiction:

United States (California - CCPA/CPRA):
- Right to Know: What personal information we collect and how we use it
- Right to Delete: Request deletion of your personal information
- Right to Correct: Fix inaccurate personal information
- Right to Opt-Out: Opt out of sharing for targeted advertising
- Right to Non-Discrimination: We won't discriminate for exercising rights
Contact: privacy@valuesvibe.com or use in-app "Privacy Center"

Canada (PIPEDA & Provincial Laws):
- Right of Access: Request access to your personal information
- Right to Correction: Request correction of inaccurate information
- Right to Withdraw Consent: Withdraw consent for processing (may limit services)
- Right to Complain: File complaints with privacy commissioners
Contact: privacy@valuesvibe.com
Privacy Commissioner of Canada: priv.gc.ca

United Kingdom (UK GDPR/Data Protection Act 2018):
- Right of Access: Obtain copies of your personal data
- Right to Rectification: Correct inaccurate or incomplete data
- Right to Erasure: Request deletion ("right to be forgotten")
- Right to Restrict Processing: Limit how we use your data
- Right to Data Portability: Receive your data in machine-readable format
- Right to Object: Object to processing based on legitimate interests
- Right to Withdraw Consent: For consent-based processing
- Right to Complain: Lodge complaints with supervisory authorities
Contact: privacy@valuesvibe.com
Information Commissioner's Office (ICO): ico.org.uk

Verification: We may require photo ID or additional information to verify your identity before fulfilling requests to protect against fraud.

Response Times:
- US: 45 days (extendable by 45 days)
- Canada: 30 days (extendable in complex cases)
- UK: 1 month (extendable by 2 months in complex cases)

11. Security
We employ administrative, technical, and physical safeguards:
- Encryption in transit (TLS 1.3) and at rest (AES-256)
- Regular security audits and penetration testing
- Employee access controls and training
- Incident response procedures

No method is 100% secure. We notify users and authorities of data breaches as required by law:
- US: As required by state laws
- Canada: Within 72 hours to Privacy Commissioner for serious breaches
- UK: Within 72 hours to ICO for high-risk breaches

12. Children's Privacy
The Service is restricted to users 18 years or older. We do not knowingly collect data from:
- US: Children under 13 (COPPA)
- Canada: Children under 13, or under provincial age requirements
- UK: Children under 13 (UK GDPR)

If you believe we have collected data from a child, contact us immediately for deletion.

13. Cross-Border Data Processing
For users outside the United States:

Canada-US Transfers:
- Generally permitted under PIPEDA with appropriate safeguards
- We ensure adequate protection through contractual and technical measures

UK-US Transfers:
- Governed by UK adequacy decisions or Standard Contractual Clauses
- Additional technical measures implemented for high-risk transfers
- Regular assessment of transfer mechanisms

14. Automated Decision Making
We use automated processing for:
- Fraud detection and prevention
- Basic compatibility matching algorithms
- Content moderation

We do not make solely automated decisions with legal or significant effects without human oversight. EU/UK users have the right to request human review of automated decisions.

15. Changes to This Policy
We may update this Policy. Changes will be:
- Posted at /privacy with effective date
- Notified via email for material changes (30 days advance notice)
- Highlighted in-app for significant changes affecting your rights

For material changes affecting sensitive data processing, we will seek renewed consent where required.

16. Contact Us & Data Protection Officers
Doppi, Inc. (ValuesVibe)
600 California Street 11th Floor
San Francisco, CA 94108 USA
Phone: +1 (415) 523-6939
Email: privacy@valuesvibe.com

For privacy-specific inquiries:
General Privacy Questions: privacy@valuesvibe.com
Data Subject Requests: requests@valuesvibe.com

Supervisory Authorities:
Canada: Office of the Privacy Commissioner of Canada
- Website: priv.gc.ca
- Phone: 1-800-282-1376

United Kingdom: Information Commissioner's Office (ICO)
- Website: ico.org.uk  
- Phone: 0303 123 1113
- Address: Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

European Economic Area: Contact your local Data Protection Authority
- List available at: edpb.europa.eu/about-edpb/about-edpb/members_en