&em
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&Em: Privacy Policy

DRAFT: for solicitor review before publishing. Last updated: 11 August 2026.

This is a first draft written directly from how the app is actually built today, not a substitute for a solicitor's review, particularly the retention period below.

1. Who we are

&Em is provided by Let Living Lead Ltd ("we", "us", "our"), a company registered in England and Wales. We are the data controller for the personal information described in this policy.

If you have any questions about this policy or how we handle your data, contact us at letlivinglead@gmail.com.

2. What this policy covers

This policy explains what personal information &Em collects, why, how it's used, who it's shared with, and the rights you have over it. It applies to anyone who creates an account or uses the &Em app.

&Em is currently in early testing. Features, data practices, and this policy may change as the product develops. We'll let testers know of any material change.

3. Information we collect

Account and profile information

  • Display name, date of birth, pronouns, home borough/area
  • Gender, sexual orientation, and who you're looking to date (if you choose to add these)
  • What you're using &Em for (dating, friends, groups) and your dating-mode preference
  • Profile and favourite photos
  • Optional personality/preference fields you choose to fill in, e.g. a fun fact, dream day trip, comfort food, alcohol attitude, transport preference, general availability

Safety and security

The IP address you sign up from, specifically: kept on your account record (distinct from the general request logs mentioned under "Technical information" below) for ban-evasion detection. See section 6 for how long and why.

Identity verification

Before you can post an outing or request to join one, we ask you to verify your identity through Stripe Identity, a third-party verification provider. This involves submitting a photo of a government-issued ID and a selfie directly to Stripe. We receive and store the outcome of that check (verified / not verified). We do not store copies of your ID document or selfie ourselves; those are held by Stripe under its own privacy policy. We treat verification outcome data as sensitive and restrict who can see or change it.

Content you create

  • Outings/plans you post, including title, description, category, timing, and location details
  • Join requests you send or receive, including any message or answer to a screening question
  • Messages you send to other users once a join request is accepted
  • Reviews left after an outing, reports you submit, and circle connections you make with other users
  • Announcements you post to a group outing you're hosting

Technical information

Like most apps, we automatically collect some technical information when you use &Em: this can include IP address, device and browser type, and general usage/log data, mainly for security, debugging, and keeping the service running reliably.

4. How we use your information

We use your information to:

  • Create and run your account, and show your profile to other verified users
  • Let you post outings, request to join others', and message people you've been matched with
  • Verify your identity, and restrict posting/joining to verified users for safety
  • Filter what's shown to you based on your own preferences (e.g. dating vs. friends, who you're looking to date)
  • Investigate reports, and suspend or restrict accounts that break our Terms of Service
  • Keep the service secure, debug problems, and improve the product

Our legal bases for this processing (under UK GDPR) are: performance of our contract with you (running the service you signed up for), our legitimate interests (safety, security, improving the product), your consent (for optional profile fields), and legal obligation where relevant.

5. Who we share it with

We share information with a small number of third-party providers who help us run &Em:

  • Supabase: our database, authentication, and file storage provider. Data is hosted in the EU (Paris, France).
  • Stripe / Stripe Identity: payment processing and identity verification.
  • Resend: sends transactional emails (e.g. magic-link sign-in emails). Hosted in the EU (Ireland).
  • Vercel: hosts the application itself. Runs in the US (Washington, D.C.).
  • Google Places: resolves the area you type when creating an outing or organiser event into a validated place (borough, coordinates). Only the text you type into that field is sent, not your full profile.

We don't sell your personal information, and we don't share your profile or content with third parties for their own marketing purposes. Vercel and Google Places both process through US-based infrastructure as their primary location, which is a transfer outside the UK/EU. Both are covered by the standard safeguard for this, the UK Addendum to the EU Standard Contractual Clauses, in their respective Data Processing Addendum/terms.

6. How long we keep your information

We keep your account information for as long as your account is active. If you delete your account, we anonymise your personal profile fields (photos, date of birth, gender, sexual orientation, and similar) immediately rather than deleting the underlying row outright. Your account ID and display name stay linked to your past outings, requests, messages, and reviews, both because another user may have an accepted plan or message history with you that they have a legitimate reason to keep, and so we can analyse platform activity internally. This means that data is pseudonymised, not fully anonymous: we can still identify you from it internally, even though it's no longer shown as your personal profile.

Your account itself is suspended rather than deleted, so it can't be used to sign back in. We also keep the IP address you signed up from for up to 3 years, even through account deletion. This is specifically so we can recognise if a banned account tries to come back under a different email, since one person can hold several. Today this is reviewed by hand rather than checked automatically at signup.

Anything else (backups, logs) is fully cleared within 30 days, except where we need to keep something longer for safety, legal, or fraud-prevention reasons (for example, records relating to an open report).

7. Your rights

Under UK GDPR, you have the right to:

  • Access the personal information we hold about you
  • Ask us to correct inaccurate information
  • Ask us to delete your information, in some circumstances
  • Ask us to restrict or object to certain processing
  • Ask for your information in a portable format

To exercise any of these, contact us at letlivinglead@gmail.com. You also have the right to complain to the UK Information Commissioner's Office (ICO) at ico.org.uk if you're unhappy with how we've handled your data.

8. Age requirement

&Em is only for people aged 18 and over. We don't knowingly collect personal information from anyone under 18, and the app enforces this when you set a date of birth on your profile. If we become aware that someone under 18 has created an account, we'll close it.

9. Safety and moderation

Because &Em facilitates in-person meetups, we use identity verification and a reporting system to help keep the community safer. We may review reports, message content relevant to a report, and account activity to investigate concerns, and may suspend accounts that break our Terms of Service. See our Terms of Service for more on safety and your own responsibilities when meeting people in person.

10. Changes to this policy

We may update this policy as &Em develops. If we make a material change, we'll let you know. For early testers, this will likely be a direct message rather than a formal notice, given the current stage of the product.

11. Contact us

If you have any questions, concerns, or requests relating to your data, contact us at letlivinglead@gmail.com.

See also our Terms of Service.