Privacy Policy

Effective date: 1 January 2025

Your privacy is important to Avo Dating LLC ("Avo," "we," "us," or "our"). This Privacy Policy explains how we collect, use, share, and protect personal information when you interact with the AvoVietnam application, website, and related services (collectively, the "Services"). It also describes the rights and choices available to you under current 2025 global privacy, consumer, and digital safety standards.

Avo Dating LLC is the data controller for the Services. If you are located in the European Economic Area ("EEA") or United Kingdom ("UK"), you may contact our Data Protection Officer at [email protected].

1. Information We Collect

• Account and Profile Information We collect identifiers such as your name, email address, phone number, date of birth, gender identity, pronouns, and profile preferences you choose to share.
• Identity and Age Verification Data To comply with emerging dating safety regulations, we may collect government ID images, selfies, biometric templates used for liveness checks, and verification status. Biometric templates are processed for matching and deleted or anonymized promptly after verification unless law requires longer retention.
• Payment and Transaction Data If you purchase subscriptions or virtual goods, we process billing information, transaction history, payment tokens, and tax status through secure third-party payment processors.
• Content and Communications We process photos, videos, prompts, audio, messages, and other content you upload or exchange with other users, including safety reports, support inquiries, and content flagged for moderation.
• Usage and Device Data We collect information about how you interact with the Services, including app and web activity, device identifiers, cookie data, crash logs, language, time-zone, and network information.
• Location Data With your permission, we may collect approximate or precise location data via GPS, Wi-Fi, or IP address to enable discovery, safety alerts, and other location-based features. You can manage location permissions through your device settings.
• Information from Others We may receive information about you from other users (such as reports), from partners who assist with age checks, fraud prevention, or background screening, and from third-party sign-in providers consistent with their privacy policies.

2. How We Use Information

We use the information we collect to:

• Provide, operate, personalize, and improve the Services and user experience.
• Verify identity, age, and eligibility; detect bots; and maintain community integrity.
• Facilitate matches, messaging, audio or video chats, and other interactions between users.
• Moderate content and enforce community standards using a combination of trained teams and automated tools, including machine learning and generative AI.
• Communicate with you about updates, safety alerts, promotions, and customer support.
• Conduct research and analytics to enhance matching, reduce bias, and support new features.
• Comply with legal obligations, regulatory reporting, and law enforcement requests.

3. Legal Bases for Processing (EEA/UK)

Where GDPR or UK data protection law applies, we rely on the following bases:

• Performance of a contract: to provide the Services and customer support.
• Consent: for optional features such as precise location, marketing emails, or biometric checks.
• Legitimate interests: to maintain safety, prevent fraud, conduct analytics, and improve the Services, balanced against your rights and expectations.
• Compliance with legal obligations: to satisfy regulatory requirements or valid law enforcement requests.

4. Sharing of Information

We do not sell your personal information. We may share information with:

• Service providers who support identity verification, moderation, analytics, hosting, customer support, or payment processing under contractual safeguards.
• Other users when you share content through your profile, live features, or messaging tools.
• Partners offering joint promotions or safety programs when you choose to participate.
• Law enforcement or regulators when required by law or to protect the rights and safety of users or others.
• Buyers or successors in connection with a corporate transaction, subject to confidentiality commitments.

5. Automated Decision-Making and Profiling

We use automated tools to surface potential matches, prioritize content, and detect harmful behavior. These tools may evaluate profile attributes, activity patterns, and location signals. We routinely test our systems to reduce bias and offer opt-out mechanisms where required by law. Human review is available for significant decisions, such as account suspensions in regulated markets.

6. Your Choices and Rights

You may exercise the following controls:

• Update account information and communication preferences in your settings.
• Manage cookies and tracking technologies through in-app or browser controls.
• Opt out of marketing communications by using unsubscribe links or contacting support.
• Request access, correction, deletion, portability, or restriction of your data by emailing [email protected].
• Appeal automated moderation or account actions where applicable law grants that right.
• For California and other U.S. state residents: exercise rights to know, delete, correct, limit the use of sensitive personal information, or opt out of cross-context behavioral advertising by visiting our in-app privacy controls or emailing [email protected].
• For EEA/UK users: lodge a complaint with your local supervisory authority if you believe we have processed your data unlawfully.

7. Data Retention

We retain personal information for as long as necessary to provide the Services, comply with legal obligations, resolve disputes, and enforce our agreements. We apply category-based retention schedules—for example, chat content is generally retained for up to 24 months unless a report or legal requirement necessitates a longer period, while biometric verification templates are deleted within 24 hours after verification unless we must retain evidence of compliance.

8. Security

We implement administrative, technical, and physical safeguards designed to protect your data, including encryption in transit, access controls, periodic security audits, and incident response plans. No system is completely secure, so we encourage you to use strong passwords and report suspected incidents promptly.

9. International Data Transfers

We operate globally. Your information may be transferred to countries other than where it was collected. When we transfer personal information outside of your country, we rely on recognized safeguards such as the EU-U.S. Data Privacy Framework, standard contractual clauses, or other lawful mechanisms.

10. Children’s Privacy

The Services are not directed to individuals under 18, and we do not knowingly collect personal information from minors. If we learn that a minor has provided us with personal information, we will take steps to delete it and may disable the associated account.

11. Changes to this Policy

We may update this Privacy Policy from time to time. We will post the updated version with a revised effective date and provide notice of material changes. Continued use of the Services after the effective date indicates acceptance of the updated policy.

12. Contact Us

If you have questions or concerns about this Privacy Policy, contact us at [email protected].