Privacy Policy

Effective Date: 1 February 2026

Partnered Holdings Inc.1209
Orange Street, Wilmington, Delaware 19801, United States
Support Contact: info@partnered.me

Partnered is committed to protecting your privacy. This Privacy Policy ('Policy') explains how we collect, hold, use, and disclose your Personal Information in connection with our services.

This Policy is drafted to achieve compliance with the Australian Privacy Principles ('APPs') contained in the Privacy Act 1988 (Cth) ('Privacy Act'). The APPs govern how we collect, use, disclose, store, secure, and dispose of your Personal Information.

Further information about the APPs is available on the website of the Office of the Australian Information Commissioner at https://www.oaic.gov.au/

1. What is Personal Information and why does Partnered collect it?

Personal Information is information or an opinion that identifies someone. This may include names, addresses, email addresses, and phone numbers.

This Personal Information is obtained in many ways, including from correspondence, by phone, by email, via our website, from media and publications, from other publicly available sources, from cookies, and from third parties. Partnered is not responsible for the privacy practices or content of any third-party websites or services that may be linked to or accessed through our services, including the Partnered website or app.

Partnered collects your Personal Information for the primary purpose of providing and operating its services, communicating with you, administering your Partnered user account, and, where permitted, marketing.

Partnered may also use your Personal Information for secondary purposes closely related to the primary purpose, in circumstances where you would reasonably expect such use or disclosure. For example, Partnered may disclose your Personal Information to contractors and other external service providers where reasonably necessary to deliver, operate, or improve the services.

You may unsubscribe from Partnered's marketing communications at any time by following the unsubscribe instructions contained in those communications, or by contacting us in writing.

When Partnered collects Personal Information, we will, where reasonable and practicable, explain to you why we are collecting the information and how we plan to use it.

2. Sensitive Information

Sensitive information is defined in the Privacy Act to include information or opinions about such things as a person's racial or ethnic background, political views, political affiliations, religious or philosophical beliefs, union or professional body membership, criminal record, or health information.

Partnered will only use Sensitive Information:

  1. for the primary purpose for which it was obtained;

  2. for a secondary purpose that is directly related to the primary purpose; with your consent; or

  3. where required or authorised by law.

3. Third Parties

Where reasonable and practicable to do so, Partnered will collect your Personal Information only from you. In some circumstances, however, we may be provided with information by third parties. In such a case, we will take reasonable steps to ensure that you are made aware of the information provided to us by the third party.

4. Disclosure of Personal Information

Your Personal Information may be disclosed in a number of circumstances, including the following:

  1. use or disclosure to third parties where you consent to the use or disclosure; and

  2. where required or authorised by law.

5. Security of Personal Information

Your Personal Information is stored in a manner that reasonably protects it from misuse and loss and from unauthorised access, modification, or disclosure.

When your Personal Information is no longer needed for the purpose for which it was obtained, Partnered will take reasonable steps to destroy or permanently de-identify your Personal Information.

Otherwise, Partnered will retain Personal Information for as long as reasonably necessary to fulfil the purposes for which it was collected, including to meet legal, regulatory, or record-keeping requirements.

6. Access to your Personal Information

You may access the Personal Information Partnered holds about you, including for the purpose of updating or correcting it, subject to certain exceptions. If you wish to access your Personal Information, please contact us in writing.

Partnered will not charge any fee for your access request, but may charge an administrative fee for providing a copy of your Personal Information.

In order to protect your Personal Information, Partnered may require identification from you before releasing the requested information.

7. Maintaining the Quality of your Personal Information

Partnered will take reasonable steps to make sure that your Personal Information is accurate, complete, and up to date. If you find that the information we have is not up to date or is inaccurate, please advise us as soon as practicable so we can update our records.

8. Account Deletion and Data Retention

Requesting Account Deletion

You may request deletion of your Account at any time through the application or by contacting us at info@partnered.me.

When you submit a deletion request, you may be asked to select a reason for leaving and may provide additional comments. Providing a reason is optional and does not affect your right to request deletion.

Once you submit a deletion request, the following changes take effect promptly:

  • You are logged out of all devices

  • Your profile is no longer visible to other users

  • You no longer appear in introductions, matches, or messaging

  • Push notifications cease

  • Your real-time presence is removed from the platform

The Account will immediately enter a Pending Deletion state.

60-Day Retention Period

After you request deletion, your Account enters a pending deletion state for sixty (60) days, referred to as the Retention Period.

During the Retention Period:

  • Your Account is inaccessible to you

  • Your profile is not visible to other users

  • You cannot reactivate, log in, or access the Services

Your personal information, profile data, photographs, videos, chat history, connections, and associated records remain securely stored in our systems during this period.

Retention during this period is necessary for the following legitimate purposes:

Community safety
To investigate and resolve reports, complaints, abuse reports, or safety concerns involving your Account or other users.

Legal compliance
To comply with obligations under applicable laws and regulations, including responding to lawful requests from courts, regulators, or law enforcement authorities.

Dispute resolution and legal defence
To preserve records reasonably necessary for the establishment, exercise, or defence of legal claims.

Platform integrity
To enforce our End User Agreement, Community Guidelines, fraud prevention processes, and other incorporated policies.

Administrative Review and Legal Holds

Partnered may place a deletion request on temporary hold where reasonably necessary, including where:

  • There is an active report, complaint, or investigation involving your Account

  • A safety or fraud concern has been identified

  • Retention is required to comply with a legal obligation, subpoena, court order, or regulatory requirement

  • Deletion would materially interfere with an ongoing dispute or investigation

Where a hold is placed, relevant data will be retained only for as long as reasonably necessary to resolve the matter or comply with the applicable obligation.

In limited circumstances, Partnered may cancel a deletion request and restore Account access where reasonably necessary, including where a request is determined to have been submitted in error, fraudulently, or under duress.

Permanent Deletion

Once the Retention Period expires, and provided no administrative or legal hold is in place, Partnered will permanently delete or de-identify personal information associated with your Account.

Deletion includes:

  • Your profile and personal information

  • Photographs and videos

  • Chat history and connections stored within our systems

  • Stored files in our cloud storage environments

Deletion is carried out in accordance with industry-standard data destruction practices.

Please be aware that:

  • Deleted data cannot be recovered once permanently erased

  • Certain residual copies may remain in secure backup systems for a limited period as part of routine backup cycles

  • Backup data is securely stored, access-restricted, and automatically overwritten in accordance with our internal retention schedules

Third-Party Processors

Subscription and payment records are processed and stored by third-party payment providers. Partnered does not store full payment card details. Such providers may retain transaction records in accordance with their own legal and regulatory obligations.

Exceptions to Deletion

Partnered may retain certain categories of data beyond the Retention Period where retention is reasonably necessary and permitted by law, including:

Transaction and financial records
Retained for up to ten (10) years or such longer period as required under tax, accounting, and corporate record-keeping laws.

Ban prevention and security records
Limited identifiers may be retained indefinitely where reasonably necessary to prevent fraud, protect community safety, enforce bans, or prevent re-registration by users removed for violations of our policies. Such data is retained in a restricted format and used solely for safety and compliance purposes.

Consent and policy acceptance records
Retained for up to five (5) years or as reasonably required to demonstrate compliance with applicable laws.

De-identified or aggregated data
Data that has been anonymised so that it cannot reasonably identify you may be retained indefinitely for analytical, operational, security, or product improvement purposes.

All retained data is stored using reasonable administrative, technical, and physical safeguards designed to protect against misuse, loss, unauthorised access, modification, or disclosure.

Your Statutory Rights

Nothing in this section limits any rights you may have under applicable privacy laws.

Australian users
You have rights under the Privacy Act 1988 (Cth) and the Australian Privacy Principles, including rights to request access to and correction of your personal information.

United States users
Depending on your state of residence, including California and other states with applicable privacy legislation, you may have rights to request deletion, access, correction, portability, and to limit certain processing of your personal information. Where required by law, we will comply with verified consumer requests within statutory timeframes.

If you are located in a jurisdiction that requires deletion within a shorter statutory timeframe than the Retention Period described above, we will comply with applicable legal requirements.

To exercise any privacy right, enquire about the status of a deletion request, or submit a verified consumer request, contact us at info@partnered.me

9. Updates to the Policy

This Policy may change from time to time and is available on our website.

10. Privacy Policy Complaints and Enquiries

If you have any queries or complaints about our Policy, please contact us at info@partnered.me

11. Users in the United States of America

This section applies if you are located in the United States.

Depending on your US State of residence, you may have rights to:

  1. request access to personal information we hold about you;

  2. request deletion of your personal information;

  3. request correction of inaccurate personal information;

  4. request a copy of your personal information in a portable format; and

  5. opt out of certain processing, including targeted advertising where applicable.

We may need to verify your identity before processing your request. To submit a privacy request, contact us via info@partnered.me

We will not discriminate against you for exercising privacy rights available under applicable US laws.

We may refuse or limit a request to the extent permitted by law, including where we are unable to verify your identity, where an exception applies, or where compliance would be unlawful or unreasonably burdensome.

12. California Users

This section supplements the Privacy Policy and applies only to California users, excluding Partnered's personnel.

The information below describes how we process California users' personal information as required by the California Consumer Privacy Act (CCPA).

Note: Not all of the items listed below may be relevant to you. For example, we do not collect Social Security numbers from our users, but we may collect this data from job applicants.

Categories of Personal Information

Third Parties with Whom Shared

Business Purposes

Sources of Collection

Identifiers such as real name, alias, postal address, unique personal identifier (device identifier, cookies, beacons, pixel tags, mobile ad identifiers), online identifier, IP address, email address, account name, Social Security number, driver's license number, passport number, and other similar identifiers.

  • Other users as part of platform operation

  • Other persons via profile-sharing features

  • Our affiliates (fraud prevention)

  • Payment processors and fraud detection vendors

  • Joint marketing partners

  • Other vendors and professional service organisations

  • Performing services (accounts, customer service, orders, payments, marketing, analytics, data storage)

  • Auditing ad impressions and compliance

  • Short-term contextual ad customisation

  • Security and integrity

  • Research and development

  • Quality and safety verification

  • Managing job postings

  • Supplier relationship management

  • From you (account creation, job applications)

  • From social media (social login)

  • From partners (advertisements, consumer reporting agencies)

  • From affiliated companies (anti-fraud)

  • From data brokers (anti-fraud)

Signature, physical characteristics or description, state identification card number, education, bank account number, credit card number, debit card number, other financial information, and medical information

N/A

N/A

  • From you (account creation, job applications)

  • From affiliated companies (anti-fraud)

Sensitive Personal Information: Some of the information we collect also constitutes 'sensitive personal information' under the CCPA, including information that reveals your social security, driver's license, state identification card, or passport number, precise geolocation, racial or ethnic origin, sex life or sexual orientation, religious or philosophical beliefs, biometric information and contents of your messages.

Partnered does not use sensitive personal information we collect for reasons other than providing and improving our services to you and protecting the safety and integrity of the Partnered platform. Partnered does not use sensitive personal information to infer characteristics about you.

Partnered may publish ads about third-party advertisers' products and services on our service and publish ads promoting our own service on third-party sites and apps. Under California law, these activities may be treated as 'sharing' or 'sales' of personal information:

Categories of Personal Information

Categories of Third Parties

  • Identifiers such as your IP address, cookie ID or email address

  • Internet or electronic network activity information, including links you access

  • Basic demographic data, including age and gender (may be characteristics of protected classifications under California or federal law)

  • Advertising networks

  • Data analytics providers

  • Social media platforms

We do not knowingly 'share' or 'sell' information about individuals under 16, and you must be at least 18 years old to use our services. You can opt out of these activities via the mechanisms described in this section.

Consumer Privacy Rights under California law

Sales and sharing opt out: You may opt out of any 'sales' or 'sharing' of your personal information that Partnered may engage in. To exercise this right, please toggle the appropriate setting via the website or App, as the case may be.

Know/Access: You may request to learn more about the personal information Partnered processes about you. You may also request a copy of the specific pieces of personal information Partnered has collected about you.

Correction: You may request that Partnered corrects inaccurate information it holds about you.

Deletion: You may request that Partnered deletes personal information it has obtained from you.

Non-Discrimination: If you exercise any of your rights under the CCPA, you have the right to non-discriminatory treatment.

You can submit a request in relation to your consumer privacy opt out rights directly to us via info@partnered.me with the subject line 'California Opt Out Request' or via the mechanisms made available to you via the Website or App, as the case may be.

To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to your personal information or otherwise complying with your request.

You may use an authorised agent to submit your request. If you do, we may ask for evidence that you have provided the agent with a valid power of attorney or other written permission to act on your behalf. If you are an authorised agent seeking to make a request, please contact us via info@partnered.me and include proof of your authorisation.

How long Partnered retains your information

We keep your personal information only as long as needed for legitimate business purposes and as permitted by applicable law.

If you stop using Partnered, you can close your account, at which point your profile will stop being visible to other users. Note that we will close your account if required by applicable law.

Following account closure, we delete your data, as set out below:

  1. To protect the safety and security of Partnered's users, we have a retention window of three months after account closure or up to two years after an account ban. During the retention window, we retain certain account information to help prevent misuse of the Partnered platform, investigate any harmful or unlawful conduct and protect other users.

  2. Partnered maintains limited data to comply with legal data retention obligations: in particular, we keep transaction data for 10 years to comply with tax, accounting and legal requirements, credit card information for the duration the holder may challenge the transaction, and 'traffic data' or logs for one year to comply with legal data retention obligations. We also keep records of consents users give us for five years to comply and demonstrate compliance with applicable law.

  3. Partnered maintains limited data for its legitimate business purposes. In particular, we keep customer care records and supporting data, as well as imprecise location of downloads and purchases for five years in support of our safety efforts, to support our customer care decisions and exercise our rights. Partnered also profiles data for one year in anticipation of potential litigation. Further, Partnered maintains data necessary to prevent users who were banned, for as long as necessary to ensure the platform's safety and integrity.

  4. Partnered may retain certain information where there is an actual or reasonably anticipated legal claim, complaint, dispute, or investigation, including if we receive a valid subpoena, court order, preservation request or other lawful direction to preserve data.

Where legally permitted, we may maintain and use data that, by itself, cannot identify or be attributed specifically to you for the purposes described in this Privacy Policy, including to improve the safety and quality of the Partnered platform.

13. Users in Washington and Nevada

This Section supplements the Privacy Policy and applies solely to Washington and Nevada users.

How we disclose Consumer Health Data

Partnered may share consumer health data with the following categories of third parties when necessary for the above-described purposes:

  1. Other users: You share information with other users when you disclose information on the service for others to see, such as your public profile.

  2. Service providers: We share information with our suppliers, including in relation to data hosting and maintenance, customer care and security operations.

  3. Affiliates: We may share information with suppliers who assist us in data processing operations. This assistance may include data hosting and maintenance, customer care, data security and addressing spam, abuse, fraud and other wrongdoing.

  4. Parties to a corporate transaction: Partnered may disclose your information if we are involved in a merger, sale, acquisition, divestiture, restructuring, reorganisation, dissolution, bankruptcy or other change of ownership or control.

  5. Government authorities: We may disclose your data to:

    1. comply with a legal process;

    2. assist in the prevention or detection of crime;

    3. protect the safety of any person; and

    4. establish, exercise or defend legal claims.

You can exercise your rights under applicable law in relation to privacy by submitting a request to info@partnered.me

Collection and use of Consumer Health Data

Partnered does not intentionally collect 'consumer health data,' and we do not use data we collect to identify or make inferences about your past, present or future physical or mental health status.

However, because 'consumer health data' is defined widely in some jurisdictions, the information Partnered may collect from or about you may be treated as 'consumer health data' under laws in those jurisdictions. Like other data Partnered collects, we mainly use this information to deliver the services offered via the Partnered platform.