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TwoHearts™ Dating - Privacy Policy


Effective Date: April 4, 2025

Version: v2025.04.04

Developer: Deep Lab (PVT) LTD

At TwoHearts, your privacy is of utmost importance to us. This Privacy Policy outlines how DEEP LAB (PVT) LTD ("Company", "we", "us", or "our") collects, uses, discloses, and safeguards your information when you use the TwoHearts Dating mobile application ("App") and related services ("Services"). By using the App, you agree to the collection and use of information in accordance with this Privacy Policy.

This Policy is intended to help you understand what data we collect, why we collect it, how we use it, and the choices you have. We are committed to protecting your personal information in accordance with global data privacy standards, including the Sri Lanka Personal Data Protection Act (PDPA), General Data Protection Regulation (GDPR), and California Consumer Privacy Act (CCPA).

This document applies solely to the TwoHearts Dating mobile app available on Apple App Store and Google Play Store.

Some features within the App, such as match suggestions and profile recommendations, may use algorithmic systems and automated decision-making to improve user experience. These processes help identify potential compatibility based on user-submitted data.

1. Information We Collect

1.1 Personal Information

When you register for an account or use our Services, we may collect the following personal information:

Mandatory Information:

  • First Name (cannot be changed later)

  • Date of Birth (cannot be changed later)

  • Civil Status (cannot be changed later)

  • Country of Residence (cannot be changed later)

  • Email Address

  • Mobile Phone Number

Profile Information:

  • Photographs and profile images

  • Gender

  • Interests and preferences

  • Horoscope details (for informational matching only)

  • Occupation, education, and professional details

  • Lifestyle information

  • Cultural and religious background

  • Languages spoken

  • Family details

  • Any other information you choose to provide in your profile

  • ​

1.2 Sensitive Personal Information

We may collect sensitive personal information such as:

  • Ethnic origin

  • Religious or philosophical beliefs

  • Health information

  • Biometric data (e.g., for verification purposes)

Note: Providing this information is voluntary. By submitting such details, you consent to our processing of this sensitive data in accordance with this Privacy Policy.

1.3 Usage Data

We collect information on how the App is accessed and used ("Usage Data"), which may include:

Device Information:

  • Device type (e.g., smartphone, tablet)

  • Operating system and version

  • Device identifiers (e.g., IDFA, Android Advertising ID)

  • Mobile network

Log Data:

  • IP address

  • Time and date of access

  • Pages and features used

  • Crash reports

  • Referral URLs

Location Data:

  • Approximate location via IP

  • Precise GPS location (with your explicit consent)

In-App Tracking Technologies:

  • Data collected through technologies like local storage, in-app events, or analytics SDKs (not browser cookies)

1.4 Information from Third Parties

We may receive information about you from:

  • Social Media Platforms: If you connect via Facebook, Google, etc., we may receive your name, photo, and social profile.

  • Service Providers: Such as payment platforms.

  • Other Users: Through reports, referrals, or shared interactions.

2. How We Use Your Information

2.1 Service Delivery

  • To create and manage your account

  • To provide matchmaking features, including horoscope comparisons (informational only). Horoscope matching is powered by a third-party service provider. In order to generate match results, we may transmit limited information such as your birth date, time of birth, gender, and location to the third party. This data is used solely for astrology calculations and is not linked to your identity.

  • To facilitate messaging and interactions

  • To personalize recommendations

2.2 Safety and Security

  • To verify identity (e.g., selfie + ID check)

  • To detect and prevent fraud, scams, or abuse

  • To enforce Terms & Conditions and community rules

2.3 Communication

  • Send service-related notices (e.g., updates to Terms or important account activity) that are considered essential and cannot be opted out of.

  • Provide customer support and respond to your inquiries or complaints.

  • With your explicit consent, send marketing, promotional offers, newsletters, and user surveys. You may opt out of promotional messages at any time via the App settings or unsubscribe link.

2.4 Analytics and Development

  • Understand app performance and user behavior

  • Develop new features and improvements

2.5 Legal and Compliance

  • Respond to legal obligations or government requests

  • Enforce policies, resolve disputes, or prevent fraud

3. Legal Basis for Processing

We process data based on:

  • Consent: e.g., for optional data, horoscope use, and marketing

  • Contractual Necessity: to deliver the App’s services

  • Legal Obligation: for compliance and record-keeping

  • Legitimate Interests: e.g., platform safety, analytics, service improvement

We ensure legitimate interests never override your data rights.

4. In-App Tracking and Analytics

We use in-app tracking tools and SDKs (not browser cookies) to understand user behavior and improve performance.

4.1 Types of In-App Data Collection

  • Essential: Required for app functionality

  • Analytics: Track in-app behavior to improve services

  • Functional: Remember app settings and user preferences

  • Advertising: Deliver relevant ads to free users

4.2 Your Choices

  • Manage tracking settings via device-level permissions

  • Disabling tracking may affect certain features

5. How We Share Your Information

5.1 With Other Users

  • Profile info (excluding contact details) may be shown to other users

  • Shared content or messages may be visible to other users

5.2 With Service Providers

We work with third-party service providers to deliver key operational, analytical, and support services, including:

  • Payment processing platforms

  • Analytics and performance measurement tools

  • Customer service support

  • Cloud storage and hosting services

  • Advertising technology providers

All third-party vendors are contractually required to:

  • Use your data only for the services they provide to us

  • Maintain the confidentiality and security of your personal data

  • Comply with applicable data protection laws and regulations

5.3 With Affiliates or Partners

  • If consented to by you, for cross-promotions or service integrations

5.4 Legal and Safety

  • To comply with law, protect rights, or respond to legal processes

5.5 Business Transfers

  • If Deep Lab (PVT) LTD undergoes a sale, merger, or acquisition

5.6 With Consent

  • For any other sharing not listed above

6. Data Security

We implement reasonable technical and organizational safeguards.

6.1 Our Measures

  • Data encryption and secure transmission

  • Limited employee access

  • Physical and cloud security measures

  • Routine risk assessments

6.2 Your Role

  • Protect your account password and credentials

  • Do not share personal information with strangers

6.3 Limitation

  • No system is completely secure

7. Your Rights

You may have the right to access, correct, delete, or restrict the use of your personal data, depending on your location and applicable data protection laws. You can also object to processing or withdraw consent for marketing at any time.

To exercise these rights, email contact@twohearts.dating. We may verify your identity before processing your request. Most requests are handled within 30 days.

8. Data Retention

8.1 How Long We Keep Data

  • Active accounts: Retained as long as needed

  • After deletion: General data for up to 12 months

  • Financial data: 7 years

  • Transaction logs: 3 years

8.2 Why We Retain It

  • Legal compliance

  • Dispute resolution

  • Fraud prevention

  • Audit and security logs

8.3 Secure Deletion

  • We securely delete or anonymize data after the retention period

9. International Transfers

Your data may be processed outside your country. We use:

  • Adequacy decisions (when applicable)

  • Standard Contractual Clauses (SCCs)

  • Consent-based transfers where needed

10. Third-Party Services and Links

We are not responsible for third-party services, sites, or privacy practices. Please review their policies before using.

11. Advertising and Analytics

11.1 Advertising

  • We show ads to free users

  • Personalized ads based on device IDs or tracking SDKs

  • Opt-out via settings or platform tools (where supported)

11.2 Analytics

  • We use tools (e.g., Firebase, Google Analytics) to understand behavior

  • Helps improve app experience and performance

11.3 Do Not Track

  • We do not respond to Do Not Track signals

12. Children’s Privacy

The App is not for users under 18. We:

  • Delete underage accounts

  • Remove associated personal data

  • Encourage reporting of suspected underage use

13. Automated Processing and Profiling

We use automated algorithms to support features such as matchmaking suggestions, compatibility scoring, and personalization of content. These processes help enhance your experience by providing relevant recommendations.

You have the right to:

  • Request a human review of any automated decision that significantly affects you

  • Challenge or contest the outcome of such decisions

  • Receive an explanation of the logic involved and its consequences

These rights apply particularly where the decision has legal or similarly significant effects.

14. Contact Us

For any privacy-related questions: Email: contact@twohearts.dating

Address: Deep Lab (PVT) LTD, No. 272, Anguruwathota Road, Wewala, Horana, Kalutara, Sri Lanka 12400

15. Changes to this Policy

We may update this Privacy Policy from time to time to reflect changes in legal requirements, our data practices, or app functionality. When we do, we will revise the "Effective Date" at the top.

How You’ll Be Notified:

  • Major changes will be notified within the App (e.g., via pop-up or notification banner).

  • Minor updates may be posted on our website or within the policy document.

Your Responsibility: By continuing to use the App after changes are posted, you are agreeing to the updated terms. We encourage you to review this Privacy Policy regularly.

16. Legal Compliance

  • Sri Lanka: Compliant with Personal Data Protection Act No. 9 of 2022

  • EU/EEA: Compliant with GDPR

  • Cross-border data: Transfers follow appropriate legal safeguards

17. California Privacy Rights

California residents have rights under the CCPA:

  • Right to know what data we collect

  • Right to request deletion

  • Right to opt-out of data sale (we do not sell data)

  • Right to non-discrimination

To exercise these, contact us using the details above.

18. Payments and Financial Information

We use third-party payment processors (e.g., Google Pay, Apple Pay) to handle all payment transactions. TwoHearts™ does not store or process your full card details on our servers. All payment-related data is securely handled by the respective payment platforms. Please refer to their privacy policies for more details on how your financial data is managed.

19. Social Media and Integrations

If you connect via social media platforms, we receive basic profile data. What we access depends on your permissions.

20. User-Generated Content

Information you post publicly (e.g., bio, photos) is visible to other users. Use caution before sharing personal or sensitive details.

21. External Links

We may include links to external sites. These are not endorsements, and we are not responsible for their practices.

22. Data Breach Notification

If a breach occurs, we will notify affected users and authorities as required by law. We will act promptly to contain and address the breach.

23. Governing Law

This Privacy Policy is governed by the laws of Sri Lanka.

24. Language

This Privacy Policy is written in English. If translated, the English version prevails in case of conflicts.

By using TwoHearts, you acknowledge that you have read, understood, and agree to the practices described in this Privacy Policy.