Privacy policy

Version 1.9 · Last updated October 26, 2026

Deep Connect Solutions GmbH ("we", "us", "our") operates the Abbs mobile application (the "App"). This Privacy Policy explains how we collect, use, disclose, and safeguard your personal data when you use our App. We are committed to protecting your privacy and complying with the EU General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), and other applicable data protection laws.

By using Abbs, you acknowledge that you have read and understood this Privacy Policy.

1. Information We Collect

1.1 Information You Provide

• Account information: When you use Sign in with Apple, we receive your Apple user identifier and, when Apple provides them, your name and email address. We store those details as part of your Abbs account. If you verify your phone number, we collect that number for additional account security and abuse prevention.
• Profile information: Your username, date of birth, calculated age, gender, ethnicity, height, weight, body type, tribe, relationship status, positions, looking-for preferences, profile status, and any free-text "about me" description you enter.
• Photos and videos: Images and videos you upload to your profile or share in chats, including album content.
• Messages: Text messages, photos, and videos sent through the in-app chat feature.
• Location data: Your precise GPS coordinates (latitude and longitude) and derived city name, used to show you nearby users and to show other users how far away you are (see section 4.1). We also retain a limited history of your location updates for service operation, security, troubleshooting, and improvement. With each location update the App also sends how accurate the reading is and whether your device reported it as simulated; we use these two details only to check that someone joining or staying on a venue list is really there (Section 12).
• Subscription and purchase data: Details of any in-app purchases (Gold or Platin subscriptions), processed through Apple's App Store.
• Safety and moderation information: Blocks and reports you submit, including the reported account, reason, optional details, review status, and any moderation or enforcement records associated with the report.
• QR pass information: If you create a QR pass, we store its destination (chat or profile), selected validity, creation and expiry times, and a one-way hash of the pass token. We do not store the raw bearer token on our servers.
• Feedback: When you send us feedback in Settings > Help, we collect whether it is a bug or an idea, your text, a screenshot if you add one, and your app version and build, iOS version, device model and how you installed the App (TestFlight or the App Store) (Section 11).
• Venue list information: If you join a venue list, the club you joined, when you joined, when the membership expires, whether your phone can take you off the list on its own, whether you chose to show the club on your profile, a counter of your recent joins (not tied to a club), and the version and time of your consent. We keep no history of lists you joined (Section 12).

1.2 Information Collected Automatically

• Device information: We maintain a record of the devices you use to access the App, which is updated each time you open the App and is associated with your account. This record includes your device model, platform, operating system name and version, app version and build number, language, locale, time zone, a per-vendor device identifier (Apple's identifierForVendor), basic display characteristics (screen dimensions and scale), low-power-mode status, and push notification tokens. The per-vendor device identifier is not an advertising identifier (we do not collect Apple's IDFA) and is not used for cross-app tracking; accordingly, no App Tracking Transparency prompt is presented.
• Device-integrity information: On supported devices, Apple App Attest helps us verify that protected actions come from a genuine instance of Abbs. We process App Attest key identifiers, public keys, attestation receipts, assertion counters, timestamps, and validation results for this purpose.
• Usage data: Interactions within the App such as viewing or opening profiles, likes, favorites, and starting chats. These records are used to operate and improve the discovery experience and to understand feature use.
• Location history: A record of your location updates over time, retained for service operation, security, troubleshooting, and improvement. Location history is retained for no more than 90 days and then automatically deleted.
• Log and connection data: IP addresses, access times, API and feature errors, and related diagnostic information. When you open the App, we record the IP address of your connection (determined on our servers from your network request) together with the device record described above, to help secure your account and prevent fraud and abuse.
• Online status: Whether you are currently active in the App, based on your WebSocket connection state.

1.3 Information from Third Parties

• Sign in with Apple: Authentication tokens and, when provided by Apple, your name and email address.
• Apple App Store: Subscription status and transaction identifiers for in-app purchases.
• Apple device services: App Attest integrity information and push-notification delivery services where those features are used.

1.4 Face Verification and Verified Badge Data

These features are explained in full in Section 10.

• Face check: If you verify with the face check, a short live video selfie is streamed from the App directly to Amazon Web Services (AWS) in Ireland. AWS returns a liveness score and one still frame from the video, which our backend uses only in memory to create your face template: a set of numbers that describes your facial features. A face template is biometric data. We never store the video, the frame, or any other image from the check.
• Verification record: Your verification status, how you verified (face check or video review), a reference to your face template, the liveness score of your last passing check, the version and time of your consent, when you were verified, whether and why a sign-up was stopped, the identifier of another account your face matched where our check found one (Section 10.5), the details of an alternative video review, and when a face template was removed.
• Alternative video check: If you choose "Verify another way", the 5 to 10 second video in which you say a code we show you, and that code.
• Verified badge: If you turn on the Verified badge, the result of each check of your main photo (match, no match, no face found, or more than one face), when it was checked, and a reference to the face template it was checked against, as well as when you turned the badge on and the version of the text you agreed to.

2. How We Use Your Information

We process your personal data for the following purposes:

• Providing the service: Creating your account, displaying your profile to other users, enabling chat and messaging, facilitating discovery of other users based on location and preferences.
• Personalisation: Tailoring the profiles shown to you based on your stated preferences (filters), location, and interaction history.
• Content moderation: Automatically evaluating uploaded photos and videos, recording user reports, and enforcing our community guidelines and applicable laws.
• Safety and security: Detecting and preventing fraud, abuse, harassment, and other harmful activities. Enforcing our Terms of Service and blocking users who violate them. We use device information, device-integrity information, and connection data (including device identifiers and IP addresses) to identify suspicious activity and protect accounts.
• Face verification: Confirming that each account is created by a real person who is present, keeping each person to one account, keeping banned members from returning, spotting someone using another member's face on their profile, and, if you turn it on, showing the Verified badge (Section 10).
• Push notifications: Sending you messages, likes, visit notifications, and other relevant updates via Apple Push Notification Service (APNs).
• Subscriptions: Processing and verifying in-app purchases, managing your subscription tier (Free, Gold, or Platin), and providing tier-appropriate features.
• QR passes: Creating time-limited QR links and resolving them to the chat or profile destination you selected.
• App compatibility and support: Recording the app version and build you are running so we can ensure compatibility, deliver and prompt required updates, and provide technical support and diagnostics.
• Analytics and improvement: Understanding how users interact with the App to improve features, fix bugs, and enhance the user experience. We may use aggregated, de-identified data for this purpose.
• Feedback: Reading the bugs and ideas you send us, fixing bugs and improving Abbs, and letting you know in the App when something you reported is fixed or added (Section 11).
• Venue lists: Letting members who are at the same club, and chose to join, see each other, letting people near the club see which club you are at if you choose, and checking that a join comes from a current location at that club (Section 12).
• Legal compliance: Responding to legal requests, enforcing our agreements, and complying with applicable laws and regulations.

3. Legal Basis for Processing (GDPR)

Under the GDPR, we rely on the following legal bases:

• Contract performance (Art. 6(1)(b)): Processing necessary to provide you with the App's services, including account creation, profile display, messaging, and discovery.
• Legitimate interests (Art. 6(1)(f)): Processing for fraud prevention, security, analytics, and service improvement, where our interests do not override your fundamental rights.
• Consent (Art. 6(1)(a)): For processing your precise location data, sending push notifications and showing arrival notices. You may withdraw consent at any time through your device settings.
• Explicit consent for biometric data (Art. 6(1)(a) and Art. 9(2)(a)): For the face check and your face template, including its use in the comparisons described in Section 10.4, and, as a separate consent, for the Verified badge. You give the first by tapping "Agree and start" before the face check, and the second by turning on "Show the Verified badge". You can withdraw either at any time in the App (Section 10.10). A banned account's template is kept on a different basis (next point).
• Face templates of banned accounts (Art. 6(1)(f) and Art. 9(2)(f)): When we ban an account, we keep its face template for 3 years after the ban (Section 10.9), so that the banned person can't return with a new account and so that we can establish, exercise or defend legal claims, such as enforcing the ban under our Terms of Service. This no longer rests on consent, so withdrawing consent or deleting the account doesn't remove that template before the 3 years end (Art. 17(3)(e)).
• Alternative video check (Art. 6(1)(b) and Art. 6(1)(f)): Reviewing the video you send when you choose "Verify another way" is necessary to provide the account you ask for, and serves our legitimate interest in keeping fake accounts, second accounts and banned members off Abbs. No face template is made and no automated means is used to recognise you, so this video is not processed as biometric data.
• Feedback (Art. 6(1)(f)): Processing the feedback you send us, including the automatic check of a screenshot and the notification that something you reported is fixed, serves our legitimate interest in fixing bugs and improving Abbs (Section 11).
• Explicit consent for venue lists (Art. 6(1)(a) and Art. 9(2)(a)): Showing your profile on the list of a club you join. You give it by tapping "Join", the first time after an explanation and each later time on a short sheet. You can leave a list at any time and turn off venue lists in Settings (Section 12.5). Showing the club to people within 15 km is a separate explicit consent, given by a switch that is off at every visit.
• Automated decisions (Art. 22(2)(c) and Art. 22(4)): The face check decides automatically whether your sign-up can finish or, for an existing account, whether you can keep using it. The consent text tells you this before you agree. The decision is based on that explicit consent, and you can ask a person from our team to review it (Section 10.5).
• Legal obligation (Art. 6(1)(c)): Where we are required to process data to comply with applicable law.

4. How We Share Your Information

4.1 With Other Users

Your profile information (username, calculated age, photos, profile status, your distance from the viewer, and other profile fields) is visible to other Abbs users in accordance with your privacy settings. Other users never see your coordinates or your position on a map. The one exception is a venue list: if you choose to join the list of a club, the members on that list see your profile there, which tells them you are at that club now. If you also turn on "Show on my profile" for that visit, people whose phone location is within 15 km of the club see which club you are at too. Joining and showing are always your own choice, each time (Section 12). A user who browses from their current GPS location sees the distance between their location and your most recent GPS location, or the place you picked on the map if your location access is off: in 10-metre steps when you are less than 1 km apart (for example "350 m"), in whole kilometres up to 10 km, and in larger rounded steps beyond that. Because nearby distances are precise, someone who compares distances from several places could estimate where you are. A user who browses from a location they picked on the map sees only the name of your city (for example "Near Berlin, Germany"), never a distance. You can hide both your distance and your city from everyone by turning off "Show Distance" in your privacy settings. That setting doesn't hide a venue list you choose to join, or the club tag you choose to show. If you turn on the Verified badge, other users see a Verified mark next to your name while your main photo matches your face check; they never see your face template, your verification record or any comparison result beyond the mark itself (Section 10). Messages and media you send are visible to their recipients subject to the sharing controls you select.

4.2 Service Providers

We use the following infrastructure providers to operate the App:

• Amazon Web Services (AWS): Our core backend, database, and media-storage systems are hosted in the European Union (Germany). A global content delivery network may process network information and deliver requested media from locations closer to users.
• Amazon Web Services (AWS) Rekognition: The face check, the face templates and the Verified badge comparisons are processed by AWS on our behalf in Ireland (European Union), because this AWS service is not offered in Germany. We have opted out of AWS using this content to develop or improve its services (Section 10.8).
• Apple: For Sign in with Apple, App Attest, Apple Push Notification Service, and App Store subscription processing. Apple services may process data outside the European Union in accordance with Apple's applicable terms and privacy policies.
• Anthropic: Our team uses Claude, an AI assistant by Anthropic PBC in the United States, to help sort and summarise the feedback you send us (Section 11). Anthropic receives the feedback text and the details attached to it, and a screenshot only if our team chooses to share one for a specific report. It is not given your name, your username or your account identifier. These transfers rely on the safeguards described in Section 9.

Where a service provider processes personal data on our behalf, we require contractual, organisational, and technical protections consistent with this Privacy Policy and applicable law, providing the same or an equivalent level of data protection.

4.3 We Do Not Sell Your Data

We do not sell, rent, or trade your personal information to third parties for their marketing purposes. We do not share your data with advertisers.

4.4 Legal Requirements

We may disclose your information if required by law, court order, or governmental request, or if we believe disclosure is necessary to protect our rights, your safety, or the safety of others.

5. Data Storage and Security

• Core account data, databases, and media storage are hosted on AWS infrastructure in the European Union (Germany). Requested media may be delivered through global content-delivery edge locations.
• Media files (photos and videos) are delivered through a content delivery network with signed, time-limited URLs that expire automatically.
• Passwords are not stored; authentication is handled through Sign in with Apple and secure token-based sessions.
• Verified phone numbers are encrypted at rest and are not displayed to other users. On our servers, QR pass bearer tokens are stored only as one-way hashes.
• Face templates are kept apart from our other data, in a face collection at AWS. Among our systems, only one dedicated function of our backend can add to or search it, and technical access by our administrators is limited to a few people. That function never accepts an image from the rest of our systems. Our database holds only a reference to your template. Videos for the alternative video check are stored privately and are never delivered through our content delivery network.
• We implement industry-standard security measures including encryption in transit (TLS), encrypted storage, and access controls. However, no method of transmission or storage is completely secure.

6. Data Retention

• Active accounts: Your data is retained for as long as your account is active.
• Account deletion: When you delete your account, we initiate a 30-day grace period during which the account is deactivated and may be restored only after your confirmation. After the grace period, the account and its associated profile, messages, conversations, media, locations, interactions, and other user-linked records are permanently deleted from our active production systems. Limited records may be retained where required by law, to establish or defend legal claims, or to meet financial and security-audit obligations. Residual copies may remain temporarily in protected backups until they are overwritten under our normal backup cycle.
• Location history: Your location history is retained for a maximum of 90 days. Older entries are automatically and permanently deleted on a regular schedule.
• Chat messages: Messages are retained for the duration of the conversation. When a conversation or account is permanently deleted, its associated messages are removed from active systems.
• Interaction data: User-linked interaction records are retained for a maximum of 90 days. Aggregated or de-identified statistics that no longer identify an individual may be retained for service analytics.
• QR passes: A QR pass expires after the validity period you select, which is no longer than 30 days. Expired pass records are deleted by our cleanup process.
• Safety records: User-linked blocks, reports, profile status, and moderation records are removed during permanent account deletion unless limited retention is required for a legal or security reason.
• Face templates: Kept until your account is permanently deleted, until you remove the template yourself, or until 24 months pass in which you don't use Abbs, whichever comes first. The template of a banned account is kept for 3 years after the ban, also after the account is deleted or consent is withdrawn, and then deleted (Section 3). A template from a check that didn't verify you, for example because your sign-up was stopped or the check couldn't finish, is deleted right away, and at the latest within 8 days.
• Face check video and frame: Never stored.
• Alternative video check: The video is deleted, with every stored copy, right after our team's decision. If nobody decides within 7 days, the request is reset and the video deleted. Every stored copy is gone at the latest 10 days after you upload it, also if you never send it for review.
• Verification record and Verified badge results: The verification record is kept for as long as your account exists. Badge results are kept until the photo is deleted, your face template is removed, or you turn the badge off. Log entries about these checks are kept for 30 days. Section 10.9 has the details.
• Feedback: Your feedback text and the details attached to it are kept until 12 months after we have fixed or closed it, and no longer than 24 months after you sent it. Screenshots are deleted automatically after 90 days. Both are deleted when your account is permanently deleted (Section 11).
• Venue list membership: Deleted when you leave, when your phone reports you left, when a location update puts you outside the club's area, or when you turn your location off. Otherwise it is no longer shown after it expires (at the latest 12 hours after you join) and deleted shortly after, in a daily cleanup at the latest. If you delete your account in the App, the record is deleted at once; if your account is deleted in any other way, it is deleted when it expires or when the account is permanently erased. Copies may remain in protected backups until overwritten under our normal backup cycle, currently up to 30 days. We keep no history of lists you joined. Your choice to show the club on your profile is part of the membership and goes with it. The record that you consented (version and time, not the club) is kept as long as your account exists (Section 12.4).
• Legal holds: We may retain data longer if required by law or ongoing legal proceedings.

7. Your Rights

7.1 GDPR Rights (EU/EEA Users)

You have the right to:

• Access: Request a copy of the personal data we hold about you.
• Rectification: Request correction of inaccurate personal data.
• Erasure ("Right to be Forgotten"): Request deletion of your personal data, subject to legal retention requirements.
• Restriction of processing: Request that we limit how we use your data in certain circumstances.
• Data portability: Receive your personal data in a structured, machine-readable format and transmit it to another controller.
• Object: Object to processing based on legitimate interests.
• Withdraw consent: Where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing. For face verification, use "Remove my face template"; for the Verified badge, turn off "Show the Verified badge" (Section 10.10). For venue lists, tap "Leave" or turn off "Venue lists" in Settings (Section 12.5).
• Human review of automated decisions: Where our face check decided automatically that your sign-up can't finish, or that you can't keep using your existing account, you can ask a person from our team to review the decision, give your point of view and contest it (Section 10.5).
• Lodge a complaint: File a complaint with your local data protection authority.

7.2 CCPA Rights (California Residents)

You have the right to:

• Know: Request disclosure of the categories and specific pieces of personal information we have collected about you.
• Delete: Request deletion of your personal information.
• Opt-out of sale: We do not sell personal information, so this right does not apply.
• Non-discrimination: We will not discriminate against you for exercising your CCPA rights.

To exercise any of these rights, please contact us using the information in Section 14 or use the account deletion feature within the App (Settings > Account > Delete Account).

8. Children and Age Restriction

Abbs is strictly for users aged 18 and older. We do not knowingly collect personal information from anyone under 18. If we learn that we have collected data from a person under 18, we will delete that data immediately. If you believe a minor has provided us with personal information, please contact us. The face check and the Verified badge do not verify age.

9. International Data Transfers

Our core backend, database, and media-storage systems process data in the European Union. Face checks, face templates and Verified badge comparisons are processed by AWS in Ireland, also in the European Union. If you use Abbs outside the EU, your data is transferred to the EU. Global content delivery and Apple services may process limited data in other countries. When our team uses Claude to sort and summarise feedback, Anthropic processes the feedback text and the details attached to it in the United States (Section 11). Where personal data is transferred outside the EU/EEA, we use safeguards required by applicable law, such as an adequacy decision or standard contractual clauses where appropriate, and require processors acting on our behalf to provide the same or an equivalent level of protection.

10. Face Verification and the Verified Badge

This section explains in one place how Abbs uses your face, and can be read on its own. It applies when you verify your account and, if you choose, when you use the Verified badge.

10.1 Why We Ask You to Verify

We ask members to show, when they join, that they are a real person who is present. We use the face check so that each person has only one Abbs account, so that members we have banned can't come back with a new account, and so that we can spot someone using your face on another profile. Verification may be required to finish signing up. Existing members may be asked to verify when they next open the App; if you are asked, you can't keep using the App until you have verified (the video review in Section 10.6 usually takes up to 48 hours). If you don't want a face template, you can verify another way instead (Section 10.6). If you do neither, you can't finish setting up your account or, as an existing member, keep using it.

10.2 How the Face Check Works

• Consent first: Before the check, the App explains it and asks for your explicit consent. The check starts only when you tap "Agree and start"; there is no pre-ticked box.
• The video selfie: The App records a short live video of your face while the screen changes colour (or, in the version without flashing lights, while you move as shown). The video is streamed straight from your device to AWS Rekognition Face Liveness in Ireland.
• The result: AWS tells us how confident it is that a live person was in front of the camera (the liveness score) and gives us one still frame from the video. Only one dedicated function of our backend handles that frame, in memory, to create your face template, and then discards it.
• Your face template: It is stored in a face collection at AWS in Ireland, linked to your account identifier. It is a set of numbers, not a picture.
• Limits: You can try up to 5 times a day. To prevent abuse, we also limit the number of checks per network address and in total each day.

10.3 What We Keep and What We Never Keep

• We keep: One face template per verified account, in the AWS face collection in Ireland, and your verification record in our database in Germany (Section 1.4).
• We never keep: The video from the face check, the still frame, or any other image from the check. We don't ask AWS to save any images of the check for us, and our own database never holds a copy of your face template.
• No other analysis: We don't ask AWS to estimate your age, gender, emotions or any other characteristic from your face.

10.4 How Face Templates Are Compared

• Your new template: When you verify, your new face template is compared with the face templates of all Abbs members, including the kept templates of banned members, to find out whether you already have an account or were banned. It is never compared with anything outside Abbs.
• Your template in other checks: Your face template is, in turn, part of the same comparison when someone else verifies, and when the main photo of a member who turned on the Verified badge is checked (Section 10.7). This is how we can spot someone using your face for a second account or on another profile.
• Only close matches count: Weaker matches are discarded and, apart from the temporary log described in Section 10.7, not recorded.
• When someone else matches you: If another person's face check or main photo closely matches your face template, we record your account identifier with their verification record, or in an internal log entry kept for 30 days, so that our team can review both accounts. If your account was verified but never finished setting up, it loses its verification and its face template, so that the new sign-up can continue (Section 10.5).

10.5 Outcomes and Human Review

• What you see: The App tells you only that you are verified, that you should try again, or that we can't finish your sign-up. It never shows a score, a match or a reason.
• Try again: The check couldn't confirm a live person, for example because of poor light. Each try counts toward your daily limit.
• We can't finish your sign-up: This happens when your face matches a member we have banned, or another account that has already finished setting up. The decision is made automatically. Your account then can't finish setup or, if you are already a member, you can't keep using it. We record the reason and the matched account's identifier, and your new face template is deleted right away.
• Possible second accounts: If your face is similar to another account's but not similar enough to stop your sign-up, or matches an account that is in its 30-day deletion grace period, your sign-up continues, and we record the matched account's identifier so our team can look into it. If that other account is later banned, our team also reviews yours.
• Unfinished accounts: If your face matches an earlier account that was verified but never finished setting up, that earlier account loses its verification and its face template is deleted, so that your new sign-up can continue.
• Human review: If you think a decision is wrong, email privacy@abbsapp.com. A person from our team will review it, and you can give your point of view and contest the decision. You can also ask us to delete the account.

10.6 Verify Another Way (No Face Template)

• How it works: Instead of the face check, you can choose "Verify another way". The App shows you a 3-digit code and records a 5 to 10 second video with the front camera in which you say it. The video is uploaded straight to private storage at AWS in Germany.
• The review: A person from our team watches the video, usually within 48 hours, to check that it shows a real person in front of the camera saying the code, who appears to be an adult. No face template is made and no automated face recognition is used.
• After the decision: The video is deleted with every stored copy right after the decision. If it is approved, your account is verified without a face template. If not, you can record a new video or use the face check. If nobody decides within 7 days, the request is reset, the video is deleted, and you can send a new one. Every stored copy of a video is gone at the latest 10 days after you upload it, also if you never send it for review.
• What it means: Because no template is made, accounts verified this way are not covered by our checks for second accounts and banned members, and they can't show the Verified badge. Other members are never told how you verified, unless you show the Verified badge, which only members who used the face check can have.
• Legal basis: Art. 6(1)(b) and Art. 6(1)(f) GDPR (Section 3).

10.7 The Verified Badge

• Opt-in: The Verified badge is optional and off by default. You can turn on "Show the Verified badge" on the Face verification page in the You tab. This is a separate explicit consent (Art. 9(2)(a) GDPR). The badge is available only if you verified with the face check and still have a face template.
• Your main photo: This is your first approved profile photo, the one other members see first. Your main photo must show only you; please don't use a photo of anyone else.
• The check: While the badge is on, our backend checks each new main photo once. The dedicated function reads the photo from our storage in Germany, converts it in memory, and sends it to AWS Rekognition in Ireland. AWS first counts the faces. If the photo shows more than one sizeable face, it is never compared. Otherwise, the largest face in the photo is compared with the face templates of Abbs members. The photo is not added to the face collection, and no new template is stored.
• If it's you: If the photo matches your own face template, other members see a Verified mark next to your name while that photo is your main photo. If it shows no usable face, more than one face, or doesn't match, there is no mark.
• If it's someone else: If the photo matches another member's face template, there is no mark and nobody is told; you see the same "doesn't match" as for any other photo. Instead, an internal log entry with both account identifiers and a rounded similarity score lets our team review a possible impersonation and act under our Terms of Service. These log entries are kept for 30 days.
• People who aren't you: A photo with several sizeable faces is never compared. A photo that shows one person who isn't you is compared once, and only the result described in this section is kept.
• What we keep: Only the result for each photo checked (match, no match, no face found, or more than one face), until the photo is deleted, your face template is removed, or you turn the badge off. Turning the badge off deletes the results at once.
• Setting the match level: Until November 16, 2026, we also log, for each check, a rounded similarity score between your main photo and your own face template, so that we can set the match level correctly. These log entries are kept for 30 days.
• What the badge means: Only that the member's main photo matched the face from their own live face check. It does not confirm a name, an age or an identity. Members without the badge may have verified another way or chosen not to show it.

10.8 Who Processes Your Face Data

• AWS: Amazon Web Services processes the face check, the face templates and the badge comparisons as our processor, in Ireland, within the European Union. We have opted out of AWS using this content to develop or improve its services. Among our systems, only one dedicated function can add templates to the face collection or search it, and technical access by our administrators is limited to a few people.
• Our team: A small number of people from our team review alternative check videos, decisions you ask us to review, and possible matches flagged for review.
• Nobody else: We don't share your face data with anyone else, except where the law requires it (Section 4.4). Other members never see it; they see only the Verified mark if you turn it on.

10.9 How Long We Keep It

• Face template: Until the first of these: your account is permanently deleted (at the end of the 30-day grace period), you remove the template yourself, or 24 months pass in which you don't use Abbs. After 24 months the template is deleted and you'll be asked to verify again when you come back.
• Template from a check that didn't verify you: If your sign-up was stopped, or the check couldn't finish, the template made in that check is deleted right away, and at the latest within 8 days.
• Banned accounts: The face template of a banned account is kept for 3 years after the ban, also after the account is deleted, together with the banned account's identifier and the time of the ban, so that the person can't return with a new account. It is then deleted. If your account is banned, withdrawing consent or deleting the account doesn't remove the template kept for the ban before the 3 years end (Section 3). If we lift a ban, this longer period no longer applies.
• Face check video and frame: Never stored.
• Alternative check video: Deleted right after the decision, or when an undecided request is reset after 7 days. Every stored copy is gone at the latest 10 days after you upload it.
• Verification record: Kept for as long as your account exists, and deleted when the account is permanently deleted.
• Verified badge results: Kept until the photo is deleted, your face template is removed, or you turn the badge off.
• Logs: Log entries about face checks and badge checks, including the entries that note a possible match for our team to review, are kept for 30 days.

10.10 Your Choices

• Remove my face template: On the Face verification page in the You tab, "Remove my face template" deletes your template at once. Your account stays verified, but our checks for second accounts and banned members no longer cover it, and the Verified badge goes away and can't be turned on again, because there is nothing left to compare your photo with. If your account has been banned, the template kept for the ban stays until the 3 years end (Section 10.9).
• Turn off the badge: Turning off "Show the Verified badge" removes the mark and deletes the badge results at once.
• Withdrawal: Withdrawing either consent doesn't affect the lawfulness of processing before you withdrew it.
• Your data: Your data export includes part of your verification record (status, method, and the times of your consent, your verification and any template removal) and your Verified badge consent and results. It doesn't include the face template itself, which is held only in the AWS face collection. You can ask us at privacy@abbsapp.com for the rest of your verification record, such as the consent version, the liveness score or the reason a sign-up was stopped; we withhold only other members' identities. Your other rights are described in Section 7, and you can contact us as set out in Section 14.

10.11 What We Never Do

• We never use your face data for advertising, marketing or profiling, to rank or recommend profiles, or for any purpose other than those described in this section.
• We never sell your face data, and we don't use it to sign you in.

11. Feedback

You can tell us about a bug or share an idea in Settings > Help > Send feedback. This section explains what happens with what you send.

• What we collect: Whether it is a bug or an idea, the text you write and, if you add one, one screenshot or other image you pick from your photos. The App also attaches your app version and build number, your iOS version, your device model and how you installed the App (TestFlight or the App Store). Your feedback is stored with your account, so that we can tell you when something you reported is fixed.
• Why we use it: To find and fix bugs and to improve Abbs. When something you reported is fixed or added, we may let you know with a notification inside the App. We don't send push notifications about feedback.
• Legal basis: Our legitimate interest in fixing bugs and improving Abbs (Art. 6(1)(f) GDPR, Section 3).
• Screenshots: Before anyone opens it, your screenshot is checked automatically for prohibited content with the same automatic moderation we use for photos (AWS Rekognition, run for us by AWS in Germany), and it is re-encoded, which removes its metadata, such as location data. If the check finds prohibited content, the screenshot is not kept. The file you uploaded is deleted after the check, or within a few days if the check can't finish. The screenshot is stored privately, is never delivered through our content delivery network and is never shown to other members. Screenshots can show other people, so please crop them out if you can.
• Who sees it: Our team. To help sort and summarise feedback, our team uses an AI assistant, Claude by Anthropic PBC in the United States (Section 4.2). It receives your feedback text and the details attached to it, but it is not given your name, your username or your account identifier. Screenshots are opened by our team, not by the assistant, unless our team chooses to share one with it for a specific report. Other members never see your feedback. When we track a bug or an idea as a work item on GitHub, a code-hosting service based in the United States, that work item holds only a summary in our own words, without personal data: never your text, your name, your username or your screenshot.
• How long we keep it: Your text and the details attached to it are kept until 12 months after we have fixed or closed your feedback, and no longer than 24 months after you sent it. Screenshots are deleted automatically after 90 days. When your account is permanently deleted, your feedback and its screenshot are deleted with it.
• Your data: Your data export includes your feedback, the details attached to it and whether it was fixed, but not the screenshot. You can ask us at privacy@abbsapp.com for a copy of a screenshot we still keep. Your other rights, including the right to object, are described in Section 7.

12. Venue Lists

This section explains in one place how Abbs uses your presence at a club if you choose to join a venue list. It can be read on its own. Venue lists are optional. Nothing in this section happens to you unless you tap "Join".

12.1 What a Venue List Is

Abbs has a catalogue of clubs in selected cities. Each club has a list of the Abbs members who are there now and chose to join it. Members on a list see each other's profiles. Nobody else sees the list, and a list can't be browsed from home. Joining changes nothing else: you stay in Discovery as before. Being on a list doesn't mean we have checked that you are inside the building; a phone's location can't tell the queue, or the building next door, from the inside. The clubs have no part in Abbs, receive no data from us and don't know who is on a list. Optionally, you can also let people near the club see which club you are at (Section 12.2).

12.2 How It Works

• Arrival on your phone: Once you have joined a list for the first time and allowed location access "Always", iOS watches a small number of nearby clubs from the catalogue, plus one larger circle around where you are. Allowing "Always" alone doesn't start this. When you leave the larger circle, your phone takes one location reading on the device to pick the nearest clubs again, and never sends it to us. When you arrive at a club, iOS tells Abbs on your phone. Abbs doesn't follow your route, and nothing is sent to us when you arrive. We don't learn that you were near a club. If you are on that club's list, your phone sends us one request to take you off it when you leave.
• The notice: Abbs then shows a notification created on your phone, using the notification permission you already gave Abbs. It names the club. It is shown at most once per club every 12 hours, and not while Abbs is open or while you are already on that club's list. If your iPhone hides notification previews, the lock screen shows only "Abbs". The notice is removed when you join, leave, turn off Venue lists or sign out.
• Without "Always": The same offer appears when you open Abbs at a club. Your phone compares its location with the catalogue stored in the App.
• What the App sends us: The App downloads the club catalogue and settings. Those requests carry no location and name no club. Your position reaches us only through the normal location update (Section 1.1). Nothing names a club until you tap "Join".
• Joining: When you tap "Join", the App sends your consent (the first time, or after we change the text), then your choice of club and whether your phone can take you off the list on its own. The join request carries no coordinates. The App first takes a fresh, precise GPS reading and doesn't accept one simulated by software or an accessory, or an approximate one. We check that your latest location update is at most 2 minutes old, was not reported as simulated, is precise to at most 100 m, was taken with GPS on, and lies inside the club's area plus a small margin. Every join is its own tap. Nothing joins you automatically, not even a club you joined before.
• Who can join: Your profile must be visible in Discovery as a single profile. Members with a private profile or with their solo profile hidden can't join, and drop off a list if they switch that on later. You can be on one list at a time. To prevent misuse, we limit how often you can join within 12 hours.
• What members on the list see: Members on the same list see your profile tile, as in Discovery, and the number of other people on the list. They can open your full profile and like or message you, as in Discovery. They don't see your distance, your coordinates or when you arrived. Members who have blocked you, or whom you blocked, don't see each other on a list. When a tile disappears, the other members can't tell whether the person left, expired, blocked them, was banned or deleted the account. You can't see a list, or how many people are on it, unless you are on it.
• Your settings: Turning off "Show Distance" doesn't hide a list you join, or a tag you choose to show (below): the people who can see them see which club you are at. If you appear offline (Hidden), you can still join, and your online dot stays hidden.
• Show on my profile (optional): The join sheet has a second switch, "Show on my profile". It is off at every visit, and joining works without it. If you turn it on, people who are not on the list also see which club you are at, as set out in the next two points.
• Who sees the tag: Only people whose own phone location (GPS) was updated within the last 60 minutes and lies within 15 km of the club. A place picked on the map never counts, and neither does a phone with location turned off. These people see a tag with the club's name under your name on your Discovery tile, and, on your profile, the line "At {club} right now" with a "Route" button that opens Apple Maps directions to the club, not to you. They don't see how long you have been there, or where in the club. Members who have blocked you, or whom you blocked, never see the tag. Everyone else sees your normal tile and profile with no hint. To decide who sees it, we compare the viewer's latest location update, which we already hold (Section 1.1), with the club's position. We store nothing new about the viewer.
• Changing it: While you are on a list you can switch between "Show to people nearby" and "Only on the list" at any time from your own card in the You tab. The tag ends at once when your membership ends (Section 12.4), and for other people the next time their app refreshes your profile.

12.3 Your Explicit Consent

• Why we ask: That you are at a named club can reveal sensitive things about you, such as your sexual orientation or sex life. We treat it as special-category data and rely on your explicit consent (Art. 6(1)(a) and Art. 9(2)(a) GDPR).
• How you give it: The first time you join, the App explains this on a sheet. You give your consent by tapping "Join", and the App sends it to us. After that, every join is a separate tap on "Join" on a short sheet. The full sheet returns if we change the consent text. There is no pre-ticked box.
• A separate choice: "Show on my profile" is a separate explicit consent (Art. 6(1)(a) and Art. 9(2)(a)) for showing the club to people near it who are not on the list. You give it only by turning its switch on, at that visit or later in the You tab. Nothing is pre-set: the switch is off at every visit.
• What we record: That you consented to venue lists: the version of the text and the time. We do not record which club there. Your choice for this visit is kept with your membership and deleted with it.
• Location and notifications: We read your location from your phone only with your permission in iOS. "Always" is optional; without it you can still join when you open the App at a club.

12.4 What We Keep and for How Long

• While you are on a list: One record: your account identifier, the club, when you joined, whether your phone can take you off the list on its own, whether you chose to show the club on your profile, and when the membership expires. Joining another club replaces it. A membership expires at the latest 12 hours after you join. For members whose phone can't take them off automatically, the expiry also moves forward each time a location update confirms you are inside, never more than 3 hours ahead and never beyond the 12 hours.
• Join counter: To limit misuse we keep a counter of your recent joins, tied to your account identifier but not to any club. It is deleted automatically after 12 hours.
• Deleted at once: When you tap "Leave", when your phone reports that you left the club, when a location update puts you outside the club's area, and when you turn your location off in the App. When you turn off "Venue lists" or sign out, the App sends the same request on a best-effort basis; if it fails, the expiry applies.
• Expiry: A membership is no longer shown to anyone as soon as it expires. It is deleted shortly after: by a sweep that runs when lists are read, and by a daily cleanup at the latest.
• Account changes: If your account is banned or deleted, or you switch your profile to private or hide your solo profile, you are no longer shown on any list at once. If you delete your account in the App, the record is deleted at once. Otherwise it is deleted when it expires or when the account is permanently erased, whichever is first.
• No history: We keep no list of the clubs you joined, and we don't use this record for Discovery, recommendations, advertising or analytics.
• Backups: A deleted record may remain in protected backups of our database until they are overwritten under our normal backup cycle, currently up to 30 days. Backups are used only to recover from a failure.
• Logs: We don't write the club into server logs, events or error reports together with your account identifier.
• Location history: The location update you send before you join is stored like any other and kept for up to 90 days (Section 6). It isn't tagged with the club, but a reading taken inside a club can by its coordinates point to it.
• Consent record: The record that you consented (version and time, not the club) is kept as long as your account exists, and deleted with it.

12.5 Your Choices

• Leave: Tap "Leave" on Discovery at any time. It takes effect at once, and you can join again while you are still there.
• Show on my profile: Switch to "Only on the list" on your own card in the You tab at any time. We then stop sending the tag to others, and it disappears for them the next time their app refreshes your profile.
• Turn it off: In Settings, turn off "Venue lists" for no arrival notices and no venue lists. The App also asks us to take you off any list you are on. If that request can't be sent, the membership ends at its expiry (Section 12.4).
• Sign out: When you sign out, or sign out of all devices, the App asks us to take you off any list you are on, and arrival detection stops on that phone. If the request can't be sent, the membership ends at its expiry (Section 12.4).
• Location: You can turn off "Always", or location access, in iOS Settings at any time. Your phone then stops telling you when you arrive. A membership still ends as described in Section 12.4.
• What leaving does not do: Leaving a list, or turning off "Venue lists", ends your membership and your notices, but doesn't delete the record that you consented. Your next join is then a single tap on the short sheet. The full explanation returns only if we change the consent text. You can ask us to delete the record (Section 7).
• Withdrawal: Withdrawing consent doesn't affect processing before you withdrew it.
• Your data: Your data export includes your current membership (club, join time, expiry and whether you chose to show it on your profile) and the record of your consent. Your other rights are described in Section 7.

12.6 Who Processes the Data

• AWS: Our database is hosted by Amazon Web Services in Germany, as our processor (Section 4.2).
• Apple: iOS watches the club locations and creates the notification on your phone. Apple doesn't receive them from us, and we don't receive them from Apple. Apple App Attest (Section 1.2) protects the consent, join and leave requests.
• Other members: Members on the same list see your profile there and, if you turned on "Show on my profile", people within 15 km of the club see the tag (Section 12.2). The "Route" button opens Apple Maps on their phone with the club as the destination.
• Nobody else: We don't share this data with clubs, advertisers or anyone else, except where the law requires it (Section 4.4).

12.7 What We Never Do

• We never tell anyone that you are at a club unless you tapped "Join", and then only the members on the same list and, if you also turned on "Show on my profile", people within 15 km of the club.
• We never send anyone to you: "Route" leads to the club, never to your position.
• We never follow your route, never receive an arrival from your phone, and never keep a history of the clubs you joined in the venue-list data. Your location history (Section 6) and our database backups (Section 12.4) are described there.
• We never use this data to rank or recommend profiles, for advertising or profiling, and we never sell it.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we make material changes, we will notify you through the App (for example, by requiring re-acceptance) and update the "Last Updated" date above. Your continued use of the App after changes constitutes acceptance of the updated policy.

14. Contact Us

If you have questions about this Privacy Policy, wish to exercise your data protection rights, or have concerns about how we handle your data, please contact us at:

Deep Connect Solutions GmbH
Represented by: Cenk Türkeli
Address: Konsul-Smidt-Str. 8q, 28217 Bremen, Germany
Email: privacy@abbsapp.com

For GDPR-related inquiries, you may also contact your local data protection authority. The lead supervisory authority for Abbs is Die Landesbeauftragte fuer Datenschutz und Informationsfreiheit der Freien Hansestadt Bremen.