Last Updated: February 22, 2026
Effective Date: February 22, 2026
1. Introduction
Welcome to BuddyBuddy (“we,” “our,” “us,” or the “Company”). We are committed to protecting your personal data and respecting your privacy in accordance with the General Data Protection Regulation (EU) 2016/679 (“GDPR”), the Swiss Federal Act on Data Protection (“FADP” / “nDSG”), and other applicable data protection laws.
This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application BuddyBuddy (the “App”). Please read this Privacy Policy carefully. By using the App, you consent to the data practices described in this policy.
Current Operating Jurisdiction: BuddyBuddy is currently operated exclusively in and from Switzerland. Our primary governing law is the Swiss Federal Act on Data Protection (FADP/nDSG). References to GDPR in this policy are included for transparency and to ensure compliance should we expand to the European Economic Area (EEA) in the future. GDPR provisions apply only to the extent that we intentionally offer services to individuals located in the EEA.
Users Accessing from the EEA: If you access the App from the EEA before we officially launch services in your region, we process your data only to the extent necessary to provide basic access to the App. We do not actively market or target services to EEA residents at this time. Until we officially launch in the EEA and appoint an EU Representative under Art. 27 GDPR, data processing for EEA users is governed by Swiss data protection law (FADP/nDSG), which provides a comparable level of protection.
If you do not agree with the terms of this Privacy Policy, please do not access or use the App.
2. Data Controller
The data controller responsible for your personal data is:
BuddyBuddy Website: https://buddybuddy.ch Email: legal@buddybuddy.ch
For users in Switzerland, this entity also serves as the responsible party under the Swiss FADP.
3. Categories of Personal Data We Collect
We collect and process the following categories of personal data:
3.1 Identity and Account Data
| Data Type | Purpose | Legal Basis |
|---|---|---|
| Email address | Account creation, authentication, communication | Contract performance, Consent |
| Password (hashed) | Account security | Contract performance |
| Display name | Profile identification, social interaction | Contract performance, Consent |
| Date of birth | Age verification, age display to other users | Consent, Legitimate interest (safety) |
| Age (calculated) | Matching and filtering features | Consent, Legitimate interest |
3.2 Profile Information
| Data Type | Purpose | Legal Basis |
|---|---|---|
| Biography/Description | Self-presentation to other users | Consent |
| Profile photographs (up to 6) | Visual identification, social interaction | Consent |
| Instagram handle (optional) | Social connectivity | Explicit Consent |
3.3 Location Data
| Data Type | Purpose | Legal Basis |
|---|---|---|
| Precise GPS coordinates (latitude/longitude) | Activity location, distance calculations, discovery features | Explicit Consent (collection via device permission) |
| Address information | Activity location display | Explicit Consent |
| Last known location (cached locally) | Distance filtering, improved user experience | Consent |
| Approximate distance from activity location | Displayed to activity hosts to help them invite relevant nearby users | Contract performance (essential feature) |
Important: Location data is considered sensitive. We only collect location data when you explicitly grant permission and when you create or interact with activities. You can revoke location permissions at any time through your device settings.
How distance is used: BuddyBuddy is fundamentally a proximity-based activity platform. Connecting users who are near an activity’s location is essential to the core functionality of the App — without it, the service cannot fulfill its purpose. When an activity host views nearby users to invite, the App displays each user’s approximate distance from the activity location (not from the host’s personal location). Your precise GPS coordinates are never shared with other users. Only a rounded distance value (e.g., “3 km away”) calculated from the activity’s published location is displayed, and only when your Show Distance privacy setting is enabled (see Section 12). Disabling this setting hides the distance label, but you may still appear in nearby user lists since proximity-based discovery is a core feature of the service.
3.4 Activity and Event Data
| Data Type | Purpose | Legal Basis |
|---|---|---|
| Activity title and description | Event organization | Contract performance |
| Activity date and time | Event scheduling | Contract performance |
| Activity location (coordinates and address) | Event location, participant navigation | Contract performance, Consent |
| Activity photographs | Visual representation of events | Consent |
| Participant information | Group coordination | Contract performance |
| Activity status | Event management | Contract performance |
| Activity participation visibility | Display of activities you’re attending on your profile | Contract performance, Consent |
3.5 Communication Data
| Data Type | Purpose | Legal Basis |
|---|---|---|
| Chat messages | Communication between participants | Contract performance |
| Join request messages | Activity participation requests | Contract performance |
| Message timestamps | Message ordering, read receipts | Contract performance |
| Read receipts | Communication status | Legitimate interest |
3.6 Interaction and Behavioral Data
| Data Type | Purpose | Legal Basis |
|---|---|---|
| Activity interactions (swipes: passed/requested/accepted) | Matching algorithm, preventing duplicate content | Legitimate interest, Contract performance |
| Join requests and responses | Activity participation management | Contract performance |
| Notification interactions | Service improvement | Legitimate interest |
Note: Activity interaction data (swipes) is retained to prevent showing you the same activities repeatedly and to improve our matching algorithms.
3.7 Technical and Device Data
| Data Type | Purpose | Legal Basis |
|---|---|---|
| Device type and platform (iOS/Android) | App functionality, compatibility | Legitimate interest |
| App version | Technical support, updates | Legitimate interest |
| Push notification tokens (FCM) | Delivery of notifications | Consent |
| Device identifiers (for analytics) | Usage analytics, app improvement | Consent |
| IP address | Security, fraud prevention, consent logging | Legitimate interest |
| Network information | Service optimization, troubleshooting | Legitimate interest |
Note on IP addresses: We may collect your IP address when you register or interact with the App. IP addresses are used for:
- Security and fraud prevention
- Recording consent (as required by GDPR accountability)
- Geographic region detection (not precise location)
- Technical troubleshooting
IP addresses are not used for tracking, profiling, or advertising purposes.
3.8 Preference Data
| Data Type | Purpose | Legal Basis |
|---|---|---|
| Notification preferences | Customized notification delivery | Consent |
| Privacy settings (show age, show distance, discovery visibility) | User privacy control | Consent |
| Discovery filter preferences (distance, age range, group size) | Personalized content | Contract performance |
3.9 Special Category Data (Art. 9 GDPR)
Important Notice: BuddyBuddy is an activity-based social platform. We do not intentionally collect special category data (also known as “sensitive personal data”). However, we recognize that:
- Photos you upload may reveal information about your racial or ethnic origin, religious beliefs, or health status
- Activity descriptions you create or join may indicate religious practices, political views, health conditions, or sexual orientation
- Your profile content may contain information you choose to share about your beliefs, lifestyle, or identity
Our approach:
- We do not process this data for profiling, targeting, or automated decision-making
- We do not analyze photos using facial recognition or biometric processing
- We do not categorize users based on inferred sensitive characteristics
- Any such data exists only because you chose to include it in your profile or activities
Legal basis: Where special category data is processed, we rely on your explicit consent under Art. 9(2)(a) GDPR. By uploading photos, creating activity descriptions, or adding profile information that reveals special category data, you explicitly consent to:
- Storage of this data as part of your profile/activities
- Display of this data to other authenticated users (subject to your privacy settings)
- Processing necessary to provide the App’s core functionality
Your control: You can remove any special category data at any time by:
- Deleting or replacing photos
- Editing activity descriptions
- Modifying your profile information
- Deleting your account entirely
4. How We Collect Your Data
We collect personal data through the following methods:
4.1 Data You Provide Directly
- Account registration information
- Profile information you enter
- Photos you upload
- Messages you send
- Activities you create
- Preferences you set
4.2 Data Collected Automatically
- Device and technical information
- Location data (with your permission)
- Usage and interaction data
- Push notification tokens
4.3 Data from Third-Party Authentication Providers
When you choose to sign in or register using a third-party authentication service, we receive information from that service:
Sign in with Google
If you authenticate using your Google account, we receive:
| Data Type | Purpose | Legal Basis |
|---|---|---|
| Email address | Account creation, communication | Contract performance |
| Display name | Profile pre-population | Consent |
| Profile picture URL | Profile pre-population (optional) | Consent |
| Google account identifier | Account linking, authentication | Contract performance |
Your Google account password is never shared with us. For more information, see Google’s Privacy Policy.
Sign in with Apple
If you authenticate using your Apple ID, we receive:
| Data Type | Purpose | Legal Basis |
|---|---|---|
| Email address | Account creation, communication | Contract performance |
| Name (if you choose to share) | Profile pre-population | Consent |
| Apple user identifier | Account linking, authentication | Contract performance |
Note: Apple offers a “Hide My Email” feature that provides a private relay email address. If you choose this option, we receive a unique Apple-generated email address that forwards to your real email. We cannot see your actual email address.
Your Apple ID password is never shared with us. For more information, see Apple’s Privacy Policy.
Phone Number Authentication
If you authenticate using your phone number, we collect:
| Data Type | Purpose | Legal Basis |
|---|---|---|
| Phone number | Account creation, verification | Contract performance |
| SMS verification status | Security, fraud prevention | Contract performance |
We use Firebase Authentication to send SMS verification codes. Standard SMS rates may apply.
4.4 Data from Analytics Services
- Analytics data from Firebase Analytics
4.5 How We Obtain and Record Consent
For processing activities that require consent, we obtain and record consent as follows:
At Registration:
- You must affirmatively accept this Privacy Policy by checking a checkbox
- The checkbox is not pre-checked (consent is not assumed)
- You cannot create an account without accepting the Privacy Policy
- We record: timestamp, IP address (if available), version of Privacy Policy accepted
Important - Consent Unbundling (Art. 7(2) GDPR):
We distinguish between required and optional processing:
| Processing Type | Required? | Can Use App Without? |
|---|---|---|
| Account creation & management | Required | No |
| Core activity features | Required | No |
| User-to-user messaging | Required | No |
| Location data | Optional | Yes (limited functionality) |
| Push notifications | Optional | Yes |
| Analytics | Optional | Yes |
| Profile discovery visibility | Optional | Yes (can hide profile) |
You can use BuddyBuddy’s core features while declining optional processing. Declining optional consent will not prevent account creation, but may limit certain features (e.g., you cannot create location-based activities without granting location permission).
For Location Data:
- Your device’s operating system requests permission before we access location
- You can grant or deny permission
- We only access location when you explicitly grant permission
- You can revoke permission at any time via device settings
- Declining does not prevent account creation or use of non-location features
For Push Notifications:
- Your device’s operating system requests permission before we send notifications
- We only send notifications after you grant permission
- You can revoke permission at any time via device settings or in-app
- Declining does not affect any other App functionality
For Analytics:
- Analytics processing helps us improve the App
- You can disable analytics via Settings > Privacy (where available)
- Disabling analytics does not affect App functionality
For Photos:
- Your device’s operating system requests permission before we access your photo library
- You choose which photos to upload
- Uploading photos constitutes consent to display them to other users
Consent Records: We maintain records of consent including:
- What was consented to
- When consent was given
- How consent was given (registration flow, permission prompt)
- Version of Privacy Policy in effect at the time
5. Purposes and Legal Bases for Processing
We process your personal data for the following purposes. We only collect data that is strictly necessary for each stated purpose (data minimization principle).
5.1 Contract Performance (Art. 6(1)(b) GDPR)
Processing necessary for the performance of our contract with you:
- Creating and managing your account
- Enabling you to create and join activities
- Facilitating communication between users
- Processing join requests
- Displaying approximate distance of users from activity locations to enable proximity-based discovery and invitations (essential feature — see Section 3.3)
- Providing core App functionality
Without this processing, we cannot provide the App’s services to you. In particular, BuddyBuddy is a proximity-based activity platform. The ability to discover and invite users near an activity’s location is fundamental to the service. Without proximity-based discovery, the App would be unable to fulfill its core purpose of connecting people for nearby activities.
5.2 Consent (Art. 6(1)(a) GDPR)
Processing based on your explicit, informed, freely given consent:
- Collecting and displaying your profile photos
- Processing your precise location data
- Sending push notifications
- Displaying your age to other users
- Showing your Instagram handle
- Processing analytics data
You may withdraw consent at any time via Settings > Privacy or by contacting us. Withdrawal does not affect the lawfulness of processing before withdrawal.
5.3 Legitimate Interests (Art. 6(1)(f) GDPR)
Processing necessary for our legitimate interests, balanced against your rights:
| Processing Activity | Our Legitimate Interest | Balancing Test | Your Rights |
|---|---|---|---|
| Improving and optimizing the App | Business improvement, user experience | Minimal privacy impact, anonymized data used | Opt-out via settings |
| Preventing fraud and abuse | Platform integrity, user safety | Essential for safe platform, minimal data used | Object via contact |
| Ensuring platform safety | Legal compliance, user protection | Overriding safety interest | Object via contact |
| Analyzing usage patterns | Service improvement | Anonymized/aggregated only | Disable analytics |
| Preventing duplicate content | User experience | Necessary for core feature | N/A |
| Technical troubleshooting | Service continuity | Limited to technical data | Object via contact |
You have the right to object to processing based on legitimate interests. Contact us to exercise this right, and we will cease processing unless we demonstrate compelling legitimate grounds.
5.4 Legal Obligations (Art. 6(1)(c) GDPR)
Processing necessary to comply with legal obligations:
- Complying with applicable laws and regulations
- Responding to valid legal requests from authorities
- Maintaining legally required records
- Cooperating with law enforcement when legally required
5.5 Vital Interests (Art. 6(1)(d) GDPR)
In exceptional circumstances, we may process data to protect vital interests:
- Emergency situations involving risk to life or safety
- Reporting imminent threats to authorities
This basis is used only in genuine emergencies.
6. Data Sharing and Third-Party Services
6.1 Service Providers
We use the following third-party service providers who process data on our behalf:
Firebase (Google LLC)
- Services used: Authentication, Cloud Firestore (database), Cloud Storage, Cloud Messaging (push notifications), Analytics
- Data processed: All user data, photos, messages, authentication tokens
- Location: Data may be processed in the United States and other countries
- Safeguards: Standard Contractual Clauses (SCCs), Google’s Data Processing Terms
- Privacy Policy: https://firebase.google.com/support/privacy
Google Maps Platform (Google LLC)
- Services used: Maps display, Geocoding, Places API
- Data processed: Location coordinates, address queries
- Location: United States and other countries
- Safeguards: Standard Contractual Clauses (SCCs)
- Privacy Policy: https://policies.google.com/privacy
6.2 International Data Transfers
Your data may be transferred to and processed in countries outside the European Economic Area (EEA) and Switzerland, including the United States. When we transfer data internationally, we ensure appropriate safeguards are in place.
Transfer Mechanisms
- Standard Contractual Clauses (SCCs): We use the 2021 EU Commission-approved SCCs with our service providers
- Adequacy Decisions: Where applicable, we rely on adequacy decisions by the European Commission or Swiss authorities
- EU-U.S. Data Privacy Framework: Google LLC (Firebase, Google Maps) is certified under the EU-U.S. Data Privacy Framework
Transfer Safeguards
Google LLC (Firebase, Google Maps) is certified under the EU-U.S. Data Privacy Framework. We rely on Standard Contractual Clauses (SCCs), supplementary technical measures, and Google’s contractual commitments to ensure adequate protection for international transfers.
Supplementary Technical Measures
We implement the following supplementary measures to protect transferred data:
- Encryption in transit: All data transfers use TLS 1.2+ encryption between your device and Firebase servers
- Encryption at rest: Data stored on Firebase servers is encrypted at rest using AES-256 (managed by Google)
- Access controls: Strict authentication and authorization for data access
- Data minimization: We transfer only data necessary for service provision
- Pseudonymization: Where possible, we use user IDs rather than directly identifying information
Your Rights Regarding International Transfers
You have the right to:
- Request information about specific transfers and safeguards
- Object to transfers based on your specific situation
- Lodge a complaint with your supervisory authority regarding transfers
To exercise these rights, contact us at legal@buddybuddy.ch.
6.3 Other Disclosures
We may disclose your personal data:
- To other users as part of the App’s functionality (profile information, activity details, messages)
- To comply with legal obligations or valid legal requests
- To protect our rights, privacy, safety, or property
- In connection with a merger, acquisition, or sale of assets (with prior notice)
7. Data Retention
We retain your personal data for as long as necessary to fulfill the purposes outlined in this Privacy Policy. Below we explain why each retention period is necessary (as required by GDPR’s purpose limitation principle):
7.0 Data Retention Summary Table
| Data Category | Retention Period | Justification |
|---|---|---|
| Account & Profile Data | ||
| Account data | Until account deletion + 30 days | Core service provision; 30-day grace period allows account recovery if deleted accidentally |
| Profile information | Until account deletion | Required for user identification and social interaction while account is active |
| Profile photos | Until deleted by user or account deletion | User-controlled content; needed for profile display |
| Push notification tokens | Until invalid or account deletion | Required for notification delivery; automatically cleared when invalid |
| Activity-Related Data | ||
| Activity data | 90 days after activity date | Allows post-activity reference, dispute resolution, and safety review; 90 days balances utility with privacy |
| Activity group chat messages | 90 days after activity ends | Enables communication context for activity coordination, dispute resolution, and safety review |
| Join requests | 90 days after activity date | Enables activity history review and dispute resolution |
| Activity invitations | 90 days after activity date | Invitation history for dispute resolution; no value after activity ends |
| Attendance verifications | 90 days after activity date | Post-activity verification records; needed for reliability score disputes |
| Verification determinations | 90 days after verification | Final attendance determination results; retained for reliability score audit |
| Social & Messaging Data | ||
| Direct messages (DM chats) | Until both users delete accounts or unfriend | User-to-user communication history; retained for ongoing conversations between friends |
| Friendships | Until unfriended or account deletion | Active relationship data; needed while friendship exists |
| Activity interactions (swipes) | Duration of account existence | Prevents showing duplicate activities; improves user experience |
| User reliability scores | Duration of account existence | Trust and safety feature; needed for platform integrity |
| Administrative Data | ||
| Notification records | 90 days | Technical troubleshooting and delivery confirmation |
| User reports | 2 years | Safety investigations and pattern detection; legal compliance |
| User feedback | 1 year | Product improvement; no longer needed after addressed |
| Rate limit records | 24 hours | Technical spam prevention; short-term operational data |
| Temporary Verification Data | ||
| Email verification codes | 24 hours | One-time use; automatically expires |
| Deletion verification codes | 24 hours | One-time use; automatically expires |
| Email change codes | 24 hours | One-time use; automatically expires |
| Analytics Data | ||
| Raw analytics events | 90 days | Aggregated into metrics, then raw data deleted |
| Analytics sessions | 90 days | Session tracking for product improvement |
| Analytics user profiles | Duration of account existence | Aggregated usage patterns; tied to account lifecycle |
| Aggregated analytics metrics | 14 months | Service improvement and usage pattern analysis; standard industry retention |
7.1 Retention Period Selection Criteria
We determined these retention periods based on:
- Necessity: How long is data needed to fulfill its purpose?
- User expectation: What would users reasonably expect?
- Legal requirements: Any legal retention obligations?
- Technical constraints: What is technically feasible?
- Risk assessment: What are the privacy risks of longer retention?
7.2 Automatic Deletion
Data is automatically deleted after the retention period expires through:
- Scheduled deletion processes for activity-related data
- Cascade deletion when accounts are deleted
- Automatic token invalidation for push notifications
After the retention period, data is permanently deleted or anonymized.
8. Your Rights
Under GDPR and Swiss FADP, you have the following rights:
8.1 Right of Access (Art. 15 GDPR)
You have the right to obtain confirmation of whether we process your personal data and to receive a copy of that data.
8.2 Right to Rectification (Art. 16 GDPR)
You have the right to correct inaccurate personal data and to complete incomplete data.
8.3 Right to Erasure (“Right to be Forgotten”) (Art. 17 GDPR)
You have the right to request deletion of your personal data when:
- The data is no longer necessary for its original purpose
- You withdraw consent (where consent was the legal basis)
- You object to processing and there are no overriding legitimate grounds
- The data was unlawfully processed
8.4 Right to Restriction of Processing (Art. 18 GDPR)
You have the right to restrict processing in certain circumstances.
8.5 Right to Data Portability (Art. 20 GDPR)
You have the right to receive your personal data in a structured, commonly used, machine-readable format and to transmit it to another controller.
8.6 Right to Object (Art. 21 GDPR)
You have the right to object to processing based on legitimate interests at any time.
8.7 Right to Withdraw Consent (Art. 7(3) GDPR)
Where processing is based on consent, you have the right to withdraw consent at any time without affecting the lawfulness of processing before withdrawal.
8.8 Right to Lodge a Complaint
You have the right to lodge a complaint with a supervisory authority:
For EU residents:
- Your local Data Protection Authority
- List of EU DPAs: https://edpb.europa.eu/about-edpb/about-edpb/members_en
For Swiss residents:
- Federal Data Protection and Information Commissioner (FDPIC)
- Website: https://www.edoeb.admin.ch/
For cross-border complaints involving international transfers: Swiss residents may also contact the FDPIC regarding concerns about international data transfers, including transfers to the United States. The FDPIC can coordinate with other data protection authorities where appropriate.
8.9 How to Exercise Your Rights
To exercise any of these rights, please contact us at:
- Email: legal@buddybuddy.ch
- In-App: Settings > Legal > Export My Data / Delete Account
We will respond to your request within 30 days (or as required by applicable law).
9. Data Security
We implement appropriate technical and organizational measures to protect your personal data in accordance with Art. 32 GDPR:
9.1 Technical Measures
| Measure | Implementation | Purpose |
|---|---|---|
| Encryption in transit | TLS 1.2+ for all API communications | Protects data during transmission |
| Encryption at rest | AES-256 encryption (Firebase) | Protects stored data |
| Password security | Bcrypt hashing with salt (Firebase Auth) | Prevents password exposure |
| Authentication | Firebase Authentication with secure tokens | Verifies user identity |
| Session management | JWT tokens with expiration | Limits unauthorized access window |
| Input validation | Server-side validation of all inputs | Prevents injection attacks |
9.2 Organizational Measures
| Measure | Implementation | Purpose |
|---|---|---|
| Access control | Role-based access; principle of least privilege | Limits data exposure |
| Data processing agreements | Executed with Firebase/Google | Ensures processor compliance |
| Security reviews | Conducted before major releases | Identifies vulnerabilities |
| Incident response | Documented procedures for breach handling | Enables rapid response |
| Development practices | Secure coding guidelines followed | Prevents security flaws |
9.3 Firebase Security Rules
We implement Firestore Security Rules that enforce:
- User data isolation: Users can only read/write their own profile data
- Activity access control: Activity details visible based on privacy settings
- Chat privacy: Messages only accessible to activity participants
- Photo access: Profile photos accessible only to authenticated users
- Admin separation: No client-side admin access to other users’ data
9.4 Data Access Matrix
| Data Type | User (self) | Other Users | Us (Admin) | Firebase |
|---|---|---|---|---|
| Profile data | Full access | Read (if discoverable) | Read (support only) | Storage/processing |
| Photos | Full access | Read (if discoverable) | Read (support only) | Storage/processing |
| Messages | Read/write own | Read (if participant) | Read (legal/safety) | Storage/processing |
| Location | Full access | Approximate distance from activity location only (if Show Distance enabled) | Aggregated only | Processing |
| Activity interactions | Read own | None | Aggregated only | Storage/processing |
9.5 Security Limitations
While we implement industry-standard security measures, no method of electronic transmission or storage is completely secure. We cannot guarantee absolute security of your data.
9.6 Data Breach Notification (Art. 33-34 GDPR)
In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will:
Notification to Supervisory Authority (within 72 hours):
- Report the breach to the competent data protection authority
- Document the nature of the breach, categories of data affected, and remedial measures
Notification to You (without undue delay): If the breach is likely to result in a high risk to your rights and freedoms, we will notify you directly via:
- Email to the address associated with your account
- In-app notification
- Public communication if direct contact is not feasible
Your Responsibility: You should ensure your email address is current to receive breach notifications.
10. Children’s Privacy
The App is not intended for users under the age of 18. We do not knowingly collect personal data from children under 18. If we become aware that we have collected personal data from a child under 18, we will take steps to delete that information promptly.
If you are a parent or guardian and believe your child has provided us with personal data, please contact us at legal@buddybuddy.ch.
10A. Safety
BuddyBuddy connects users for in-person activities. Your safety when meeting other users is your responsibility. We strongly recommend meeting in public places, informing friends or family of your plans, and reporting any suspicious behavior through the App.
For detailed safety information and disclaimers, see our Terms of Service, Section 6.
11. Automated Decision-Making (Art. 22 GDPR)
We use automated processing for the following purposes:
11.1 Activity Discovery and Ranking
- Purpose: To show you relevant activities based on distance and timing
- Logic: Activities are ranked based on proximity to your location and time until the activity
- Factors used: Geographic distance, time until activity starts, activity status
- Factors NOT used: We do not use profiling based on personal characteristics, behavior patterns, or inferred preferences
- Impact: Determines the order of activities shown to you
- Your rights: You can adjust distance and filtering preferences in Settings
11.2 Assessment Under Art. 22 GDPR
Does our automated processing produce legal or similarly significant effects?
We have assessed our automated processing and determined that it does not produce legal effects or similarly significantly affect you because:
- No access restrictions: All activities remain accessible to all users; ranking only affects display order
- No profile-based exclusion: We do not exclude users from activities based on automated profiling
- User control: You can adjust all filtering parameters and view all available activities
- No economic impact: The App is free; ranking does not affect pricing or access to paid features
- Manual alternative: You can always manually browse and search for activities
11.3 Your Rights Regarding Automated Processing
Our automated processing does not produce legal or similarly significant effects as described in Art. 22 GDPR. Nonetheless, we support the following rights:
- Right to explanation: You can contact us to understand how activity ranking works. We will explain the logic involved, the significance, and the envisaged consequences of such processing.
- Right to human review: You can request human review of any automated decision affecting you. We commit to reviewing such requests within 14 days.
- Right to contest: You can challenge any perceived unfair treatment in activity visibility. We will investigate and provide a reasoned response.
- Right to opt-out: You can disable location-based ranking by denying location permissions (though this limits functionality).
If we introduce new automated features in the future, we will reassess their impact under Art. 22 GDPR and update this policy accordingly before deployment.
To exercise these rights, contact us at legal@buddybuddy.ch.
11.4 No Profiling for Marketing or Third Parties
We do not:
- Create behavioral profiles for advertising purposes
- Sell or share profiling data with third parties
- Use automated decision-making for credit, employment, or similar significant decisions
- Engage in predictive profiling about your behavior, preferences, or characteristics
12. Privacy Settings and Controls
You can control your privacy through the following in-app settings:
| Setting | Description | Location |
|---|---|---|
| Show Age | Control whether your age is visible to others | Settings > Privacy |
| Show Distance | Control whether your approximate distance from an activity location is visible to activity hosts. When disabled, the distance label is hidden but you may still appear in proximity-based discovery (see Section 3.3). | Settings > Privacy |
| Profile Discovery | Control whether you appear in activity discovery | Settings > Privacy |
| Show Instagram | Control Instagram handle visibility | Settings > Privacy |
| Profile Activities | Your upcoming activities are visible to your buddies. Non-buddies may see them with a premium subscription. | N/A (cannot be disabled) |
| Push Notifications | Control notification preferences | Settings > Notifications |
| Location Permissions | Control location access | Device Settings |
13. Local Data Storage
The App stores some data locally on your device using SharedPreferences:
- Filter and preference settings
- Cached activity data (for faster loading)
- Last known location (for distance calculations)
- Hidden/removed chat identifiers
This local data:
- Remains on your device only
- Is not transmitted to our servers
- Can be cleared by uninstalling the App or clearing App data
14. Push Notifications
We use Firebase Cloud Messaging (FCM) to send push notifications. You will receive notifications for:
- New join requests on your activities
- Accepted/declined join requests
- New messages in your chats
- Activity updates and reminders
- When participants leave activities
You can control notifications:
- In-App: Settings > Notifications
- Device Level: Your device’s notification settings
We store your FCM token to deliver notifications. Invalid tokens are automatically removed.
15. Photos and Media
15.1 Profile Photos
- You can upload up to 6 profile photos
- Photos are compressed (max 1920x1920 pixels, 85% quality)
- Photos are stored in Firebase Cloud Storage
- Photos are visible to all authenticated users (unless you disable profile discovery)
15.2 Activity Photos
- One photo per activity
- Same compression settings as profile photos
- Visible to all users who can view the activity
15.3 Photo Deletion
- You can delete your photos at any time
- Deleted photos are removed from Cloud Storage
- Cached versions may persist temporarily on other users’ devices
16. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. We will notify you of any material changes by:
- Posting the new Privacy Policy in the App
- Updating the “Last Updated” date
- Sending you a notification (for significant changes)
We encourage you to review this Privacy Policy periodically. Your continued use of the App after changes constitutes acceptance of the updated Privacy Policy.
17. Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:
Email: legal@buddybuddy.ch Website: https://buddybuddy.ch
We aim to respond to all inquiries within 30 days.
18. Jurisdiction-Specific Provisions
18.1 Current Operating Jurisdiction
BuddyBuddy is currently operated exclusively in and from Switzerland. Swiss law, specifically the Swiss Federal Act on Data Protection (FADP/nDSG), is the primary governing law for all data processing activities.
18.2 European Economic Area (EEA)
Status: We do not currently target or actively offer services to individuals in the EEA. GDPR provisions referenced in this policy apply only if and when we officially expand to offer services in the EEA.
For EEA residents who access the App before official EEA launch:
- Your data is processed under Swiss data protection law
- We process only data necessary to provide basic App access
- We do not actively market to or target EEA residents
- Full GDPR compliance (including appointment of an EU Representative under Art. 27) will be ensured before any official EEA launch
Once we officially launch in the EEA, this policy will be updated to reflect full GDPR compliance, including designation of a Lead Supervisory Authority under Art. 56 GDPR.
18.3 Switzerland
For users in Switzerland, this Privacy Policy complies with the Swiss Federal Act on Data Protection (FADP/nDSG) and its implementing ordinances. The competent supervisory authority is the Federal Data Protection and Information Commissioner (FDPIC).
Additional rights under Swiss law:
- Right to information about data processing
- Right to data portability
- Right to object to automated individual decision-making
18.4 Legal Basis Equivalence
Where this policy refers to GDPR legal bases, the equivalent bases under Swiss law apply:
- Contract performance → Contract performance
- Consent → Consent
- Legitimate interests → Overriding private or public interests
- Legal obligation → Legal obligation
19. Definitions
- Personal Data: Any information relating to an identified or identifiable natural person
- Processing: Any operation performed on personal data (collection, storage, use, disclosure, deletion, etc.)
- Data Controller: The entity that determines the purposes and means of processing personal data
- Data Processor: An entity that processes personal data on behalf of the controller
- Consent: Freely given, specific, informed, and unambiguous indication of agreement to data processing
- GDPR: General Data Protection Regulation (EU) 2016/679
- FADP/nDSG: Swiss Federal Act on Data Protection (Bundesgesetz über den Datenschutz)
20. Data Protection Compliance Documentation
20.1 Our Compliance Measures
We maintain appropriate documentation and measures to demonstrate compliance with applicable data protection laws, including records of processing activities, data processing agreements with our service providers, and technical and organizational security measures.
20.2 Data Protection by Design and Default (Art. 25 GDPR)
We implement privacy by design principles:
- Data minimization: We only collect necessary data
- Purpose limitation: Data used only for stated purposes
- Storage limitation: Data retained only as long as necessary
- Privacy settings default to most protective options where appropriate
- Regular privacy reviews of new features
20.3 International Transfer Mechanisms
For transfers outside the EEA/Switzerland:
- Primary mechanism: Standard Contractual Clauses (SCCs) - 2021 EU Commission version
- Supplementary measures: Encryption, access controls, contractual commitments
- Transfer Impact Assessments: Conducted for each third-country transfer
21. Acknowledgment
By using BuddyBuddy, you acknowledge that you have read and understood this Privacy Policy and agree to the collection, use, and disclosure of your personal data as described herein.
Specifically, you acknowledge and agree that:
- You have had the opportunity to review this Privacy Policy before using the App
- You understand what personal data we collect and why
- You understand your rights and how to exercise them
- You accept the data processing described herein as necessary for the App’s functionality
- For processing based on consent, you provide your informed, specific, and unambiguous consent
- You may withdraw consent at any time without affecting prior processing
- You understand that withdrawing certain consents may limit App functionality
For users in the EU/Switzerland:
- You acknowledge that this Privacy Policy complies with GDPR and Swiss FADP requirements
- You understand your right to lodge a complaint with your supervisory authority
- You understand that we may transfer your data internationally with appropriate safeguards
For processing activities based on consent, you may withdraw your consent at any time through the App settings or by contacting us. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.
22. Severability and Survival
22.1 Severability
If any provision of this Privacy Policy is found to be invalid, illegal, or unenforceable by a court of competent jurisdiction, such invalidity shall not affect the validity of the remaining provisions, which shall remain in full force and effect.
22.2 Survival
The following sections shall survive termination of your account or this Privacy Policy: Section 7 (Data Retention), Section 21 (Acknowledgment), and this Section 22.
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This Privacy Policy was last reviewed on February 22, 2026.