Fey

Privacy Policy

Last updated: {{EFFECTIVE_DATE}}

This Privacy Policy describes how {{LEGAL_NAME}} ("the Company", "we", "us", "our") collects, uses, stores and discloses your personal data when you visit yourfey.com, complete the Fey quiz, receive a Soulmate Portrait, or otherwise interact with our website and related services (together, the "Services").

BY USING THE SERVICES YOU CONFIRM THAT (I) YOU HAVE READ, UNDERSTOOD AND ACCEPTED THIS PRIVACY POLICY, AND (II) YOU ARE AT LEAST 18 YEARS OF AGE. If you do not agree with this Policy, or cannot make this confirmation, you must not use the Services. In that case you may ask us to delete any personal data you have already submitted by writing to {{SUPPORT_EMAIL}}.

Where this Policy is made available in a language other than English, the translation is provided for convenience only. If the English version and a translation differ in meaning or interpretation, the English version published at yourfey.com prevails and is the only legally binding text.

Residents of certain jurisdictions (for example, the European Economic Area, the United Kingdom, or individual U.S. states that have adopted consumer privacy legislation) may be entitled to additional rights or disclosures under local law. If you believe such rights apply to you, please contact us at {{SUPPORT_EMAIL}} and we will respond in accordance with the law that governs your request.

Table of Contents

  1. Personal Data Controller
  2. Categories of Personal Data We Collect
  3. Purposes and Legal Bases for Processing Your Personal Data
  4. How We Share Your Personal Data
  5. Your Privacy Rights
  6. Age Limitation
  7. International Data Transfers
  8. Data Retention
  9. Security Measures
  10. Third-Party Websites and Services
  11. Changes to This Privacy Policy
  12. Contact Us

1. Personal Data Controller

{{LEGAL_NAME}}, with its registered office at {{LEGAL_ADDRESS}}, is the controller of the personal data processed through the Services, meaning that it determines why and how your personal data is processed.

2. Categories of Personal Data We Collect

We collect the following kinds of data about you:

2.1. Data you directly provide to us

Identifiers. This includes your email address and, if you choose to provide it, your name and phone number. You give us this information when you complete the quiz, request your Soulmate Portrait, make a purchase, sign up for our communications, or contact us by any means.

Quiz and product data. As you move through the Fey quiz we ask you a series of questions and record your answers. Depending on the version of the quiz, this may include your gender, date of birth, relationship status and preferences, and other answers you choose to give. We use this information to produce your personalised Soulmate Portrait and the content that accompanies it.

Face image. At one step of the quiz we may invite you to upload a photo of your face. Providing a photo is optional. We process the image solely to create your Soulmate Portrait; we do not analyse it to identify you or anyone else, and we do not use it for any biometric identification purpose. The image is deleted promptly after the portrait has been generated. If you complete the quiz but do not purchase the portrait, we may send you reminders to finish your order; in that case we keep the image for a limited period of no more than two months so that we can still generate the portrait if you decide to complete the purchase after receiving a reminder. After that period the image is deleted.

Communications data. When you contact our support team, we process the content of your messages, including your questions, feedback, attachments and any other information you include. We also process the information you submit through any contact or feedback form available on the Services.

Payment data. If you make a purchase through the Services, you provide your payment details directly to third-party payment processors acting on our behalf. We do not collect, store or have access to your full card number or similar financial account details. We may receive limited information from the processor, such as a secure payment token, the product purchased, the date, time and amount of the transaction, the payment method type and the last digits of your card.

2.2. Data we collect automatically

Advertising performance data. When you arrive at the Services after clicking an advertisement or link, we collect information about the referring page or campaign. This may include the name and identifier of the advertising campaign and creative, the click time, and a campaign-level user identifier.

Device and location data. We collect technical data from the device and browser you use to access the Services. This may include IP address, browser type and version, language settings, time zone, operating system, screen resolution, device type and model, Internet service provider, and unique identifiers we assign to your session or device. Where your device settings permit, we may also derive your approximate location from your IP address, such as city, region, country or postal code.

Online activity data. We record how you interact with the Services. For example, we log which quiz steps you reach, how long you spend on each page, which features and content you view, whether you open or click the communications we send you, and the purchases you make.

Cookies and similar technologies. We use cookies, pixels, local storage and similar tools to operate the Services, improve your experience, analyse traffic and measure our advertising. Our own essential cookies are necessary for the website to work: they support page loading, session management, security and fraud prevention, remember your preferences, and collect limited diagnostic information such as page requests, load times and error logs. We may also use analytics and advertising technologies provided by third parties that record the pages you visit, the time you spend on them and the actions you take, so that we can understand how the Services are used and measure the effectiveness of our campaigns. Unless applicable law allows otherwise, non-essential technologies are activated only after you give consent through our cookie banner. You can withdraw or change your choices at any time; disabling these technologies may limit certain features, but the Services will remain usable.

2.3. Aggregated and de-identified data

We may aggregate, anonymise or de-identify your personal data so that it can no longer reasonably be linked to you. We use such data for statistical analysis, to identify trends, to improve the Services, to develop new features and for other lawful purposes. For example, we may study aggregated quiz-completion, purchase and advertising data to understand which parts of the experience work best for our visitors. Once properly aggregated or de-identified, this data is no longer personal data under applicable privacy laws.

3. Purposes and Legal Bases for Processing Your Personal Data

We collect and use your personal data mainly to (1) provide and improve the Services, (2) maintain their quality and security, and (3) attract new customers. The purposes for which we process each category of data, and the legal basis we rely on, are set out below.

3.1. Purposes and legal bases

To provide the Services, including generating and delivering your Soulmate Portrait.

To research, analyse and improve the performance of the Services.

To ensure quality control and safety of the Services.

To provide customer support.

To process payments, refunds and chargebacks.

To enforce our Terms of Use, investigate complaints, prevent and combat fraud, unlawful conduct and misuse, and protect the security of the Services.

To send service communications about your order, your portrait and the Services. We may send these by email or, where you have provided a number, by SMS.

To send marketing communications. You may receive information about special offers, new features and available Services, as well as reminders to complete a purchase you started. We may send these by email or SMS. Every marketing message includes an unsubscribe option.

To serve personalised advertising. For example, after you visit the Services you may see our advertisements on social media platforms.

To analyse the performance of our advertising. This includes measuring impressions and conversions, verifying proper ad placement and quality, and confirming compliance with industry standards.

To comply with our legal obligations.

3.2. Description of our legitimate interests

3.3. Automated decision-making

We do not use your personal data to make decisions based solely on automated processing that produce legal effects concerning you or similarly significantly affect you. The Soulmate Portrait is an entertainment product generated from the answers and image you choose to provide; it does not constitute such a decision.

4. How We Share Your Personal Data

We share personal data with third parties that help us operate, deliver, improve, support and market the Services. We share only the data sets needed for the purposes described in Section 3 and, wherever we engage a provider to process data on our behalf, we aim to put in place a data processing agreement that limits the provider to processing on our instructions.

The categories of third parties with whom we share information are the following.

4.1. Service providers

We engage third parties to provide services or perform business functions on our behalf and under our instructions. The types of providers we use (and, in some cases, their sub-processors) include:

4.2. AI tools

We may use artificial-intelligence tools to generate the Soulmate Portrait and to automate or improve certain customer-facing processes, such as tailoring the messages we send you. These uses change over time, so the specific processes may vary. For such processing we rely on private, tenant-isolated deployments of AI models from vetted providers, we configure them so that your personal data is not used by the provider to train its models, and we send only the minimum data required.

4.3. Advisors, consultants and independent contractors

We may share limited personal data with independent contractors, consultants, specialists, partners and advisors who act on our behalf to operate, maintain, secure and improve the Services or to ensure legal and regulatory compliance. We require them to use the information only for these purposes, to protect it appropriately and to keep it confidential.

4.4. Marketing and advertising partners

4.5. Law enforcement and public authorities

We may use and disclose personal data to enforce our Terms of Use; to protect our rights, privacy, safety or property or those of our affiliates, you or others; and to respond to requests from courts, law enforcement, regulators and other public authorities, or in other cases where the law requires or permits it.

4.6. Corporate transactions

As our business develops we may buy or sell assets or business lines. Customer information is typically one of the assets transferred in such transactions. We may also transfer personal data in the course of a sale of our business, a divestiture, merger, consolidation or asset sale, or in the unlikely event of bankruptcy.

4.7. Affiliates

We may share your personal data with companies within our corporate group, that is, companies that own us, are owned by us or are under common ownership with us. These companies use the information in ways consistent with this Policy.

5. Your Privacy Rights

We encourage you to contact us first with any question or concern about how we handle your personal data, at {{SUPPORT_EMAIL}}.

Depending on where you live, you have some or all of the rights below. Applicable law may not grant every right to every person, or may name them differently.

5.1. Right to access / know

You have the right to receive information about what personal data we process, how we use it and with whom we share it. This Policy provides that information: the categories of data we process (Section 2), the purposes and legal bases (Section 3) and the recipients (Section 4). You may also ask us to confirm whether we hold personal data about you.

5.2. Right to delete / erase

You have the right to ask us to delete your personal data, unless deletion is restricted under applicable law. To request deletion, email {{SUPPORT_EMAIL}}. We will make reasonable efforts to honour your request. In some cases we are legally required to keep certain data for a period of time, for example to comply with accounting obligations, resolve disputes or enforce our agreements; in that event we will complete the deletion once those obligations have been met.

5.3. Right to rectify / correct

You have the right to ask us to correct inaccurate personal data about you. Please email {{SUPPORT_EMAIL}} with the details to be corrected. Some information collected automatically at the system level (such as device and usage data) cannot be manually edited because of its nature; it is refreshed each time you use the Services.

5.4. Right to withdraw consent

Where we process your personal data on the basis of your consent, you may withdraw that consent at any time; this does not affect processing that took place before withdrawal. Only a limited number of our processing activities rely on consent (see Section 3). To withdraw consent to cookies and personalised advertising, use the cookie settings on yourfey.com. To stop marketing emails, use the unsubscribe link in any message; to stop marketing SMS, reply as instructed in the message or contact us at {{SUPPORT_EMAIL}}.

5.5. Right to data portability

You have the right to receive a copy of the personal data you have provided to us in a structured, commonly used, machine-readable format. To request a copy, email {{SUPPORT_EMAIL}}.

5.6. Right to object or restrict processing

In certain situations you have the right to object to the processing of your personal data or to ask us to restrict it. You can submit such a request to {{SUPPORT_EMAIL}}.

5.7. Right to lodge a complaint

In certain countries, including those in the European Economic Area and the United Kingdom, you have the right to lodge a complaint with your data protection authority if you are concerned about how we process your personal data. We would appreciate the chance to address your concern first, so please consider contacting us before you do so.

5.8. Verification and authorised agents

We may need to verify your identity before acting on a request. Verification may involve confirming your email address, date of birth, the date of your purchase or other details about your use of the Services that reasonably identify you. We may ask for additional proof where necessary, but we aim to keep the information requested to a minimum. For certain requests we may send a verification code to your email address or phone number. If you appoint an authorised agent to act on your behalf, the agent will need to provide evidence of their identity and of your authorisation.

6. Age Limitation

The Services are intended for adults. We do not knowingly allow anyone under 18 to use the Services, and we do not knowingly collect or process personal data of anyone under 18. If you become aware that a person under 18 has used the Services or provided us with personal data, please contact us at {{SUPPORT_EMAIL}} and we will delete the data.

7. International Data Transfers

We may transfer personal data to countries other than the one in which it was collected, in order to provide the Services and achieve the purposes described in this Policy. Where those countries do not offer the same level of data protection as the country in which you provided the data, we apply appropriate safeguards.

In particular, when we transfer personal data originating from the European Economic Area or the United Kingdom to a country recognised as providing an adequate level of protection, we rely on the relevant adequacy decision; for example, transfers to the United States may rely on the EU-U.S. Data Privacy Framework and its UK extension where the recipient is certified. When we transfer such data to a country without an adequacy decision, we rely on the Standard Contractual Clauses approved by the European Commission (and the UK International Data Transfer Addendum where applicable), together with supplementary measures where needed.

8. Data Retention

We keep your personal data only for as long as necessary to fulfil the purposes described in this Policy and our Terms of Use, including providing the Services to you. In determining the appropriate retention period we consider the amount, nature and sensitivity of the data; its relevance to delivering the Services (including the possibility that you return to complete a purchase); the potential risk of harm from unauthorised use or disclosure; whether the purposes could be achieved by other means; and applicable legal requirements, including mandatory retention periods, limitation periods and legal holds.

Specific retention rules apply to certain data:

More generally, the retention period depends on the lawful basis for processing (see Section 3):

If several lawful bases apply, we keep the data until the latest applicable period ends. When you ask us to delete your data, we delete or anonymise it unless retention is required to comply with legal obligations, to establish, exercise or defend legal claims, to resolve disputes or to enforce our agreements. For example, accounting and tax laws may require us to retain payment records for several years; in that case a limited portion of data relating to our compliance obligations will remain stored even after your deletion request has otherwise been satisfied.

9. Security Measures

We apply reasonable and appropriate organisational, technical, administrative and physical safeguards, as required by applicable law, to protect your personal data from unauthorised access, disclosure, use or alteration. These include, without limitation, encryption of data in transit and at rest, pseudonymisation where feasible, access controls and authorisation procedures, vulnerability testing, internal policies, and regular reviews of our technical and organisational measures. We update our security practices as new technologies and methods become available. However, no transmission over the Internet or method of storage is completely secure, and we cannot guarantee absolute security. We encourage you to exercise caution online and to protect any credentials or verification codes we send you.

10. Third-Party Websites and Services

The Services may contain links to third-party websites or services, and third parties may link to the Services. We do not control these third parties and are not responsible for their privacy practices or content. We encourage you to read the privacy policies of every website or service you interact with. We do not endorse, screen or approve any third-party website, and your use of them is at your own risk.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes, we will notify you through the Services or by other available means (for example, by email if we hold your address) and give you an opportunity to review the revised Policy before it takes effect. The "Last updated" date at the top of this page indicates when the Policy was most recently revised. By continuing to use the Services after the changes take effect, you agree to the revised Policy.

12. Contact Us

You may contact us at any time with questions about this Privacy Policy, its previous versions or the way we handle your personal data:

If you have a privacy- or data-protection-related matter you would like to raise with the person responsible for data protection at the Company, please mark your email "Data Protection" so that it can be routed accordingly.