Privacy Policy

1. Who We Are

We are the data controller for all information processed through the app and website.

2. Age Requirement

Nudge is intended for users aged 18 and over. We do not knowingly collect data from anyone under 18.

3. Data We Collect

We collect the following categories of personal data:

3.1 Identity & Contact Data

• Name
• Email
• Date of birth
• Profile photo (optional)

3.2 Profile & Preferences

• Interests and categories selected
• Questionnaire answers
• Professional or social preferences
• Bio and information you choose to display

3.3 Location Data

• Real-time GPS location when you grant permission
• Event check-in location
• Approximate proximity data for matching

Note: Location features require consent and can be disabled. Without location, certain features will not function.

3.4 Device & Technical Data

• IP address
• Device model and operating system
• App activity logs
• Crash reports
• Browser type (website only)
• Cookies and similar technologies (see Cookie Policy)

3.5 Usage Data

• Features used
• Nudges sent/received
• Matches and connections
• Event participation

3.6 Communications

• Messages with other users (where applicable)
• QR handshake confirmations
• Feedback submitted to us

3.7 AI Processing Data

We process profile information, interests, questionnaire answers and interaction data to generate compatibility scores using AI models (OpenAI or equivalent).

We do not use AI for decision-making that produces legal or significant effects.

3.8 B2B Data

For businesses, event partners, and advertisers:

• Business name
• Contact person details
• Payment information
• Advert content submitted for approval

4. How We Use Your Data

We use personal data for the following purposes:

4.1 To Operate and Improve Nudge

Legal basis: Contract; legitimate interests

• Create and manage accounts
• Provide matching and proximity-based nudges
• Display user profiles
• Enable QR handshake verification
• Show local offers to relevant users

4.2 Location-Based Functionality

Legal basis: Consent; contract

• Identify compatibility when users are nearby
• Notify users of matches
• Show location-triggered offers in partner venues

Your real-time location is never displayed to other users, and is not used for third-party advertising.

4.3 To Show Offers and Sponsored Spots

Legal basis: Contract; legitimate interests

• Premium users may receive location-triggered offers from businesses
• In future, free-tier users may see sponsored placements

No personal data is shared with advertisers.

4.4 To Improve Matching Using AI

Legal basis: Legitimate interests

We use AI to:

• Suggest compatible matches
• Help identify relevant interests
• Improve interaction quality

4.5 To Support Events and Partnerships

Legal basis: Contract

When you join an event, certain information may be shared with the organiser:

• Name
• Email
• Attendance confirmation

4.6 Marketing

Legal basis: Consent; legitimate interests

We may send updates about:

• New features
• Events
• Premium plans

4.7 External Advertising (for Nudge Recruitment)

Legal basis: Legitimate interests

We promote Nudge on platforms like Meta, Google, or TikTok. This activity does not involve tracking you inside the app.

4.8 Safety, Fraud, and Legal Obligations

Legal basis: Legal obligation; legitimate interests

Including moderation, misuse detection, or enforcing our Terms.

5. Data Sharing

We share data only when necessary:

5.1 Service Providers

Including:

• Firebase
• Supabase
• Mapbox
• OpenAI
• Payment processors
• CRM and email providers

5.2 Event Organisers

Your name and email when you sign up for an event.

5.3 Advertisers (Business-Submitted Offers)

Advertisers do not receive any personal data.

We show offers based on:

• Proximity
• Interests
• App activity

All matching happens inside Nudge.

5.4 Legal Authorities

If required by law or court order.

6. International Transfers

Some providers (e.g., Firebase, OpenAI) are based outside the UK. We ensure protection through:

• UK-approved Standard Contractual Clauses
• ICO-approved safeguards

7. Data Retention

8. Your Rights

Under UK GDPR, you have the right to:

• Access your data
• Rectify inaccuracies
• Request erasure of your data
• Restrict processing
• Object to processing
• Data portability – receive your data in a portable format
• Withdraw consent at any time
• Complain to the ICO – Information Commissioner's Office at ico.org.uk

9. Security

We use encryption, access controls, and monitoring to protect your data. No system is perfectly secure; we encourage responsible use.

10. Contact Us