Last updated 6 July 2026
Company registered in England and Wales, Company No. 14828305
Registered office: 86-90 Paul Street, London, England, EC2A 4NE, United Kingdom
Version: 1.5 | Last updated: 6 July 2026
Available at https://www.everconnected.com/privacy-policy
This summary is for convenience only. It does not replace the full Policy below, which governs.
Who we are. Everconnected is a connection and Matching platform for adults aged 18 and over, not a health, wellbeing, medical, or counselling service.
What we collect. What we need to run the Services: your account and Soul Profile, how you use Matching and Soul Calls, content you share, and the limited payment data needed for Credits and subscriptions.
Beliefs and outlook. Some onboarding answers reveal your beliefs or outlook, special-category data we use only with your explicit consent, only for Matching and safety, and never to assess your health.
Calls and transcripts. We may transcribe Soul Calls and use the transcripts to run, secure and improve the Services and keep them safe. We do not keep the call audio.
Adults only. We use age-assurance checks, which may include facial age estimation or identity documentation, to keep the Services 18+.
Automated decisions. Some matching, safety, and fraud decisions are automated; where a decision significantly affects you, you can ask for human review.
Sharing. We share data with service providers, other Users (in a limited way), and authorities where the law requires, and we do not sell your personal data for money.
Your rights. You can access, correct, delete, and port your data, object to certain processing, and withdraw consent at any time.
Contact. Questions or requests: privacy@everconnected.com. Full detail is in the sections below.
1.1 This Privacy Policy explains how Everconnected Ltd (“Everconnected”, “we”, “us”, “our”) collects, uses, shares, and protects your personal data when you use the Everconnected platform, websites, and applications (the “Services”). It is incorporated into and forms part of our Terms of Service and should be read with them. Capitalised terms that are not defined here have the meaning given in the section of the Terms of Service headed “Definitions and Interpretation”.
1.2 Everconnected is a connection and Matching platform.
1.3 The Services are for adults. You must be at least eighteen (18) years old to use them; see the section headed “Children and age assurance”.
1.4 If you have any questions, or wish to exercise your rights, contact us using the details in the section headed “How to contact us and complain”.
2.1 Everconnected Ltd, a company registered in England and Wales (Company No. 14828305) with registered office at 86-90 Paul Street, London, England, EC2A 4NE, United Kingdom, is the controller of the personal data processed through the Services.
2.2 Data-protection contact: privacy@everconnected.com.
2.3 Supervisory authority: in the United Kingdom, the Information Commissioner’s Office (ICO), www.ico.org.uk. If you are in the EU/EEA, you may also contact your local supervisory authority.
3.1 Our primary data-protection framework is the UK GDPR and the Data Protection Act 2018.
3.2 Where the EU GDPR, the California Consumer Privacy Act (as amended by the CPRA), PIPEDA in Canada, or another applicable data-protection law imposes mandatory obligations on us, those obligations apply of their own force, and where mandatory local rights cannot be excluded by contract they apply to the extent required. Region-specific rights are described in the sections headed “United States” and “Canada”.
3.3 Nothing in our Terms or in this Policy removes mandatory data-protection protections available to you under the law of your country of residence that cannot be excluded by agreement.
4.1 We collect the following categories of personal data, from you, from your use of the Services, and from limited third-party sources:
| Category | Examples | Source |
|---|---|---|
| Account & identity | Username, email address, hashed password, account settings, country or region. | You (registration) |
| Age-assurance & verification | Declared date of birth or age; where age assurance is triggered, the result of facial age estimation and/or an identity-document check, and any biometric-derived data used to estimate or verify your age. | You / verification provider |
| Soul Profile & onboarding | Questionnaire responses about your values, beliefs, interests, and outlook, which may reveal religious or philosophical beliefs or your emotional outlook (special-category data, see “Special-category data”). | You |
| Matching & Behavioural Signals | Soul Profiles, stated preferences, Tribe membership, and Behavioural Signals (for example how promptly you accept a match, your scheduling initiative and response, your attendance and the duration of Soul Calls, and your review behaviour). | Your use of the Services |
| Soul Call data | Scheduling information and call metadata (such as time and duration), and text transcripts of Soul Calls, which we generate, retain and use to operate, secure and improve the Services, to keep users safe, and to comply with law. The audio is not retained. See “Soul Calls and transcripts”. | Your use of the Services |
| Content & communications | Posts, forum and chat messages, Reviews, ratings, reactions, Submissions, and reports you make. | You |
| Transactions & payments | In-App Credits and One-Time Purchases, subscriptions, Virtual Products, Tips, Voluntary Support Contributions, Rewards, and Creator Share records, and the limited payment data needed to process them. Card payments are handled by our payment processor; we are the seller / merchant of record and do not store full card numbers. | You / payment processor |
| Device & technical | Device identifiers, IP address, app and operating-system version, log and diagnostic data, and cookie and SDK identifiers (see “Cookies and similar technologies”). | Your device |
| Linked accounts & contacts | Where you link a third-party or social account, or import contacts to invite others, the information you authorise us to access for that purpose. | You / third-party platforms |
| Advertising & offer-wall identifiers | Identifiers shared with an offer-wall or advertising provider to credit a Reward or prevent fraud (see “Advertising and offer walls”). | Your use of the Services |
| Reports, safety & moderation | Information contained in reports you or others make, and the outcomes of moderation and safety processes. | You / other Users / our systems |
| Correspondence | Information you provide when you contact support or exercise your rights. | You |
4.2 You do not have to provide all of this data, but some of it is necessary to provide the Services; if you do not provide it, certain features (including Matching) may be unavailable or limited.
4.3 Data about other people. If you provide personal data about another person, for example when you import contacts or refer to an identifiable person in your content, you confirm that you are entitled to provide it and, where required, that you have that person’s consent. We process such data only to provide the relevant feature and as otherwise described in this Policy.
5.1 Some information you choose to provide for Matching, in particular your religious or philosophical beliefs, and any data revealing your emotional outlook, is special-category data under data-protection law, in the same way that data revealing sexual orientation is for a dating service.
5.2 Where you provide such data, we process it only on the basis of your explicit consent (Article 9(2)(a) of the UK and EU GDPR) or, where applicable, another condition identified in this Policy, and solely to provide Matching and the features you use and to keep the Services safe. We do not use it to monitor, diagnose, or assess your health, and the Services are not a health, wellbeing, or clinical service.
5.3 You may decline to provide special-category data, withdraw your consent at any time, or delete it, through your settings or by contacting privacy@everconnected.com. Withdrawal does not affect processing carried out before withdrawal, and declining or withdrawing may affect Matching quality or the availability of certain features.
6.1 The Services are for adults only. You must be at least eighteen (18) years old; persons under 18 are not permitted to use the Services, and we do not knowingly collect personal data from anyone under 18.
6.2 Age assurance. You confirm your age at registration. We operate age-assurance measures proportionate to the Services and our risk assessment, which may include analysing account and usage signals to detect users who may be under 18, acting on reports, and requiring you to verify your age, for example by facial age estimation or, where needed, identity documentation, where we have reason to believe you may be under 18, where you take an age-restricted action, or where required by law. Self-declaration of age is not by itself conclusive.
6.3 Biometric and verification data. Facial age estimation analyses an image of your face to estimate your age; depending on the method used, it may not uniquely identify you and the image may not be retained. Where biometric data is processed in order to uniquely identify you (for example, when an identity document is checked against your image), it is special-category (biometric) data, and we process it only to estimate or verify your age, to prevent fraud, and for safety, on the basis of your explicit consent and/or the substantial-public-interest condition for safeguarding and age assurance under the Data Protection Act 2018. We retain such data only as long as necessary for that purpose and aim not to retain facial-estimation images longer than necessary to produce the result (see “How long we keep your data”). For US users, see the note on biometric-privacy laws in the section headed “United States”.
6.4 If we believe a user is under 18, we may restrict, suspend, or terminate the account and delete the associated personal data, subject to any legal retention obligation. If you believe a person under 18 is using the Services, contact safety@everconnected.com.
7.1 We use your personal data for the purposes set out below. The “lawful basis” column states the UK and EU GDPR basis; where we rely on legitimate interests, you may object as described in the section headed “Your rights”.
| Purpose | Main data used | Lawful basis |
|---|---|---|
| Provide the Services and Matching, create your account, build your Soul Profile, pair you for Soul Calls, run Quests and Tribes, and deliver community features. | Account, Soul Profile, Matching & Behavioural Signals, Soul Call, content data. | Performance of a contract (Art 6(1)(b)); for special-category beliefs/outlook, your explicit consent (Art 9(2)(a)). |
| Matching intelligence and prioritisation, measure Behavioural Signals to allocate matches fairly and operate match cadence. | Behavioural Signals, Matching data. | Legitimate interests (Art 6(1)(f)) in a fair and effective matching service; performance of a contract. |
| Keep the Services safe and lawful, moderation, reporting, illegal-content and online-safety duties, age assurance, and safeguarding. | Reports & safety data, age-assurance data, Soul Call data and transcripts, content. | Legal obligation (Art 6(1)(c)); legitimate and recognised legitimate interests (Art 6(1)(f)) in safety and integrity; for special-category or biometric data, the safeguarding / substantial-public-interest conditions and/or explicit consent. |
| Payments, Credits, and tax, process subscriptions, In-App Credits, Virtual Products, Tips, Voluntary Support Contributions, Rewards and Creator Share, and meet accounting and tax-reporting duties. | Transaction & payment data. | Performance of a contract (Art 6(1)(b)); legal obligation (Art 6(1)(c)). |
| Prevent and detect fraud and abuse, including automated checks. | Device & technical data, transaction data, Behavioural Signals. | Legitimate interests (Art 6(1)(f)); legal obligation (Art 6(1)(c)). |
| Communicate with you, service, security, and transactional messages, and support. | Account & correspondence data. | Performance of a contract; legitimate interests. |
| Marketing, where offered. | Account data and limited usage data. | Consent where required (and PECR for electronic marketing); otherwise legitimate interests, with an opt-out. |
| Improve and secure the Services, analytics, diagnostics, testing, and security. | Device & technical data, usage data, Soul Call transcripts and metadata. | Legitimate interests; consent for non-essential cookies (see “Cookies and similar technologies”). |
| Comply with law and establish, exercise, or defend legal claims. | Relevant data as needed. | Legal obligation; legitimate interests. |
7.2 Where we rely on consent (including for special-category data and certain cookies), you may withdraw it at any time without affecting processing carried out before withdrawal.
8.1 Some Matching, prioritisation, fraud-prevention, and safety measures involve automated processing of your data, including profiling, which may significantly affect your experience, for example by restricting features, delaying or blocking a transaction, or limiting matches. For Matching specifically, this profiling draws on the Behavioural Signals defined in the Terms.
8.2 Where a decision producing legal effects concerning you, or similarly significantly affecting you, is based solely on automated processing, you have the right to obtain human review, express your point of view, and contest the decision. To exercise these rights, or to ask about the logic involved, contact privacy@everconnected.com. We also review such measures for accuracy and to reduce false positives.
8.3 Much of this processing is necessary to provide the Services you request, or is carried out with your explicit consent, in each case with the safeguards described above.
9.1 Soul Calls are one-to-one audio conversations and are generally not recorded.
9.2 We may generate, retain and use text transcripts and metadata of Soul Calls to operate, secure and improve the Services, to keep users safe, and to comply with law. The audio is held only briefly to produce the transcript and is then deleted; we do not keep a recording of the audio.
9.3 We use transcripts as described in this Policy, including to provide and improve the Services and to keep them safe, and we keep them in line with our retention schedule for as long as necessary for those purposes. Where a decision based on a transcript significantly affects you, a person reviews it and you can appeal (see the Terms and our Trust and Safety procedure).
9.4 For US users in states that require the consent of all parties to record a call, see the section headed “United States”.
10.1 We share personal data only as described in this section. We do not sell your personal data for money.
10.2 Service providers (processors) who process data on our behalf under contract, including: cloud hosting and infrastructure; communications and email delivery; analytics and diagnostics; payment processing; age-assurance and identity-verification providers; trust-and-safety and moderation tools; customer-support tools; and speech-to-text and transcription tooling used for safety.
10.3 Payment processing and the closed-loop model. Payments are processed by our payment processor; we are the seller / merchant of record and are not a money transmitter, bank, or e-money institution. Tips and Gifts are activated with In-App Credits and are not money transfers between users; recipients receive in-platform Rewards, and Tribe creators receive a Creator Share.
10.4 Other Users. To provide Matching and community features, limited information is shared with other Users, for example the profile information you make available to a match, your Reviews (which are two-sided and revealed simultaneously), your reputation Badges, and content you post in Tribes or community areas. Badges are descriptive and do not make you a professional.
10.5 Tribe creators and administrators receive the limited information needed to operate their Tribe; they are independent and are not our agents.
10.6 Advertising and offer-wall partners. Where an offer wall or advertising provider shares an identifier with us, or we with them, to credit a Reward or prevent fraud, that limited sharing is done as described in the sections headed “Advertising and offer walls” and “Cookies and similar technologies”.
10.7 Authorities and legal. We may disclose data to courts, regulators, law-enforcement, or other authorities where reasonably necessary to comply with law, respond to a valid request, enforce our Terms, or protect the rights, safety, and security of users, the public, or Everconnected, including reporting child-sexual-abuse material to the appropriate authorities.
10.8 Corporate transactions. If we are involved in a merger, acquisition, reorganisation, or sale of assets, personal data may be transferred as part of that transaction, subject to this Policy and applicable law.
10.9 Professional advisers and insurers, where necessary and subject to confidentiality.
11.1 We may transfer personal data outside the UK or the EEA. Where we do, we use an applicable lawful transfer mechanism, such as UK adequacy regulations, the UK International Data Transfer Agreement or the International Data Transfer Addendum to the EU Standard Contractual Clauses, the UK Extension to the EU-US Data Privacy Framework, EU adequacy decisions, the EU-US Data Privacy Framework, or the EU Standard Contractual Clauses, with supplementary measures where required.
11.2 You may request a copy of the relevant safeguard by contacting privacy@everconnected.com.
12.1 We keep personal data only as long as necessary for the purposes for which it was collected, or as required by law, after which it is deleted or anonymised. Retention is governed by our internal Data-Retention Schedule; the indicative periods below summarise our approach:
| Data | Indicative retention period |
|---|---|
| Account & Soul Profile data | While your account is active; deleted or anonymised within [90 days] of account closure, subject to legal holds. |
| Behavioural Signals & matching data | While needed to operate Matching; then aggregated, anonymised, or deleted in line with the Schedule. |
| Soul Call transcripts and metadata | Kept in line with this schedule for as long as necessary for the purposes described in this Policy; the call audio is not retained. |
| Age-assurance / biometric data | Only as long as needed to make or evidence the age decision; facial-estimation images are not retained longer than necessary. |
| Transaction & tax records | As required by accounting and tax law. |
| Reports & moderation records | As needed for safety and legal purposes. |
12.2 Where data is needed for more than one purpose, the longest applicable retention period applies.
13.1 We implement appropriate technical and organisational measures to protect personal data, as required by applicable data-protection law. No system is completely secure, and we do not warrant that the Services will be free from every vulnerability or incident.
13.2 You are responsible for keeping your credentials and devices secure and for notifying us promptly of any unauthorised access or suspected compromise at security@everconnected.com.
14.1 Subject to applicable law, you have the right to: access a copy of your personal data; have inaccurate data rectified; have data erased (the “right to be forgotten”); restrict processing; object to processing (including processing based on legitimate interests and processing for direct marketing); data portability; rights concerning automated decision-making and profiling (see the section headed “Automated decision-making and profiling”); and to withdraw consent at any time.
14.2 How to exercise your rights. Use your account settings or contact privacy@everconnected.com. We may need to verify your identity. We will respond within the period required by law (generally one month, which may be extended for complex requests), normally free of charge.
14.3 Complaints. You may complain to a supervisory authority, in the United Kingdom, the Information Commissioner’s Office (www.ico.org.uk); in the EU/EEA, your local supervisory authority. Residents of US states and of Canada have the rights and routes described in the region-specific sections. We ask that you also contact complaints@everconnected.com so that we can try to resolve your concern directly.
15.1 You have several ways to control how your data is used:
Account & profile: view and update your information, and edit or delete Soul Profile responses, in your settings.
Consent: withdraw consent for special-category data, or for non-essential cookies, at any time (see “Special-category data” and “Cookies and similar technologies”).
Marketing: opt out of marketing using the unsubscribe link or your settings (see “Direct marketing”).
Automated decisions: request human review of a qualifying automated decision (see “Automated decision-making and profiling”).
Your data rights: access, correct, delete, port, or object, as described in the section headed “Your rights”.
US opt-outs: where you are a US resident, use our “Do Not Sell or Share” control and Global Privacy Control, as described in the section headed “United States”.
16.1 We use cookies and similar technologies (including SDKs and device or offer-wall identifiers) as described in our Cookie Policy, which is incorporated into our Terms of Service and explains the categories we use, how to give and withdraw consent, and the specific cookies and identifiers involved.
16.2 Non-essential cookies are used only with your consent, which you can change at any time.
17.1 We may display advertising and may operate third-party offer walls. Our role is limited to providing advertising space; we are not a party to, and are not responsible for, any transaction between you and an advertiser.
17.2 Where an offer wall shares an identifier with a provider to credit a Reward or prevent fraud, that limited sharing is done as described in this Policy and the Cookie Policy. We do not sell your personal data for money; for how the “sale” and “sharing” concepts under US state law apply, see the section headed “United States”.
18.1 We will send you electronic marketing only where we are permitted to, and you can opt out at any time using the unsubscribe link or your settings. Service, security, and transactional messages are not marketing, and you cannot opt out of them while you hold an account.
19.1 Where required, we will notify the Information Commissioner’s Office within 72 hours of becoming aware of a personal-data breach, notify affected individuals without undue delay where the breach is likely to result in a high risk to them, and provide the information required by law.
20.1 Scope. This section applies to residents of US states that have enacted comprehensive consumer privacy laws (around twenty states as of 2026, including California, Colorado, Connecticut, Texas, Virginia, and others) and supplements the rest of this Policy. It does not change our practices for users outside those states.
20.2 Categories of personal information. Using the statutory categories in California law (and comparable to other states), the personal information we collect is summarised below; examples are cross-referenced to the section headed “The personal data we collect”. We disclose these categories to the service providers and recipients listed in the section headed “Sharing your data” for the business purposes described there.
| Statutory category | Do we collect it? | Examples |
|---|---|---|
| Identifiers | Yes | Username, email, IP address, device identifiers. |
| Customer records / commercial information | Yes | Subscriptions, In-App Credits, purchases, transaction history. |
| Internet or other network activity | Yes | Usage, interactions, and Behavioural Signals. |
| Audio or similar information | Yes (limited) | Soul Call metadata and text transcripts; the call audio is not retained. |
| Geolocation | Approximate only | Approximate location inferred from IP address. |
| Sensitive personal information (only with your explicit consent) | Yes (with consent) | Religious or philosophical beliefs; biometric data used for age assurance. |
| Inferences | Yes | Profile and match-related inferences. |
20.3 Sale and sharing. We do not sell personal information for monetary consideration. Some advertising or offer-wall identifier-sharing may constitute “sharing” for cross-context behavioural advertising, or a “sale”, under some state laws.
20.4 Sensitive personal information. We collect sensitive personal information only with your explicit consent, use it only for the purposes permitted by law and described in this Policy, and you may limit its use to the extent your state’s law allows.
20.5 Your state privacy rights. Subject to your state’s law, you may have the right to: confirm whether we process your information and access it; correct it; delete it; obtain a portable copy; opt out of sale, sharing, and certain targeted advertising; opt out of profiling that produces legal or similarly significant effects; and limit the use of sensitive personal information. You are entitled to exercise these rights free from unlawful discrimination.
20.6 How to exercise them. Contact privacy@everconnected.com; you may use an authorised agent (with proof of authority). We will verify your identity and respond within the period your state’s law requires. If we decline a request, you may appeal by replying to our response, and you may contact your state attorney general.
20.7 Profiling and automated decisions. Where your state gives you the right to opt out of certain profiling (for example, Connecticut, Colorado, and similar states), you may exercise it as described above; see also the section headed “Automated decision-making and profiling”.
20.8 Biometric privacy. Where state biometric-privacy laws apply (for example, the Illinois Biometric Information Privacy Act), we provide the notice, obtain the consent, and follow the retention and destruction practices those laws require for any biometric identifiers or information used for age estimation or verification, as described in the section headed “Children and age assurance”.
20.9 Call recording and wiretap laws. Some US states require the consent of all parties to record or intercept a call. We do not retain the audio of Soul Calls; we generate transcripts from a brief copy rather than by intercepting the live call.
21.1 If you are in Canada, we process your personal information in accordance with PIPEDA and applicable provincial laws, on the basis of your consent or as otherwise permitted by law. You may request access or correction, or complain to the Office of the Privacy Commissioner of Canada, by contacting privacy@everconnected.com.
22.1 For non-material changes (such as clerical or typographical corrections) we will update the “Last updated” date. For changes that materially affect your rights or how we process your data, we will give at least thirty (30) days’ notice by email to your account address or by prominent in-app notice, stating the effective date. Where a change involves a new way of processing sensitive personal data, or a significant change to data sharing, we will seek your opt-in consent before it applies to you.
23.1 Data-protection enquiries and rights requests: privacy@everconnected.com.
23.2 Postal: Everconnected Ltd, 86-90 Paul Street, London, England, EC2A 4NE, United Kingdom.
23.3 Complaints: complaints@everconnected.com. You may also complain to the Information Commissioner’s Office (www.ico.org.uk) or your local supervisory authority.
23.4 Accessibility. To request this Policy in an alternative format, or to report an accessibility barrier, contact accessibility@everconnected.com (see the section of the Terms of Service headed “Accessibility”).
v1.5 (6 July 2026): documented Soul Call transcripts on a broad basis. Section 9 renamed to “Soul Calls and transcripts” and rewritten so transcripts are generated, retained and used to operate, secure and improve the Services, keep them safe, and comply with law, with the call audio not retained. Removed the earlier safety-only framing and the matching disclaimer. Added transcript disclosures to the glance and to sections 4, 7, 10, 12 and 20, and US call-recording guidance at section 20.9. Earlier versions: v1.2 (30 May 2026) working draft for legal review.
End of Privacy Policy, Everconnected Ltd.
Version 1.5, 6 July 2026 | Confidential working draft for legal review
