Privacy Policy

Part A: Privacy Notice

Your privacy matters to us

Cwtch is designed to help couples build stronger relationships. We know that doing this may involve sharing information that is personal or sensitive.

We want you to understand clearly what information we use, why we use it and, particularly, what information your partner can and cannot see.

Who we are

Cwtch is operated by CWTCH Innovations Ltd, a company incorporated in England and Wales under company number 17488925.

Registered office: Forest Lodge, Forest Road, Pyrford, Surrey, GU22 8NA
Email: hello@getcwt.ch

We are responsible for deciding how and why your personal information is processed in connection with Cwtch.

What information do we collect?

Depending on how you use Cwtch, we may collect:

Account information

name;
email address;
account details; and
login and authentication information.

Relationship information

information about your relationship;
relationship goals and preferences;
responses to Cwtch questions and activities;
information you choose to share about your relationship; and
information generated through your use of Cwtch.

Some relationship information may be sensitive personal data under applicable data-protection law.

Conversation and interaction data

messages and responses you provide;
activities you complete;
interactions with Cwtch;
feedback; and
information about how you use particular features.

Technical information

device information;
IP address;
browser and operating system information;
log information; and
information about how you interact with the Service.

Payment information

Payments may be processed by our payment provider. We may receive information such as transaction identifiers, subscription status and payment history without receiving or storing your full payment-card details.

Why do we use your information?

We may use your information to:

provide and personalise Cwtch;
create and maintain your account;
facilitate shared experiences with your partner;
understand how Cwtch is being used;
improve the safety, quality and functionality of Cwtch;
provide customer support;
process payments;
prevent fraud and protect the security of Cwtch;
communicate important service information;
conduct research where we have an appropriate legal basis and, where required, your consent;
comply with legal obligations; and
protect the rights and safety of Cwtch, our users and others.

Your private information and your partner

This is particularly important.

Cwtch will allow you to provide information privately. Information that Cwtch identifies as private will not be shown to your partner.

Information deliberately submitted to a shared activity, shared profile or other shared feature may be visible to your partner.

We will design Cwtch to make the distinction between private and shared information clear.

AI and your information

Cwtch uses AI to provide personalised experiences.

Depending on the feature you use, information you provide may be processed by third-party technology providers acting on our behalf.

We select providers and contractual arrangements designed to protect your information.

We do not treat an AI provider as having an independent right to use your relationship information for its own purposes merely because Cwtch uses that provider.

Where information is used for product improvement, research or model-related purposes, the applicable processing and legal basis will be explained in this Privacy Policy and, where required, through additional consent.

Sensitive information

Cwtch may process information that can reveal sensitive aspects of your life or relationship.

Where information falls within a special category of personal data under UK data-protection law, we will identify and document an appropriate legal basis and additional conditions for processing.

We will only collect and use sensitive information where we have a legitimate and appropriate reason to do so.

Who do we share information with?

We may share information with carefully selected service providers who help us operate Cwtch, such as:

cloud hosting providers;
AI technology providers;
payment providers;
analytics providers;
communications providers;
customer-support providers; and
security and technology providers.

We may also disclose information where required by law or where necessary to protect users, Cwtch or others.

We do not sell your private relationship conversations to advertisers.

How long do we keep information?

We retain personal information only for as long as reasonably necessary for the purposes for which it was collected, including legal, accounting, security and legitimate business requirements.

Different categories of information may have different retention periods.

Our internal data-retention schedule sets out these periods.

Your rights

Depending on the circumstances, you may have rights to:

access your personal information;
correct inaccurate information;
request deletion;
restrict processing;
object to certain processing;
receive certain information in a portable format;
withdraw consent where processing is based on consent; and
complain to the Information Commissioner's Office.

You can contact us at hello@getcwt.ch to exercise your rights.

Questions

If you have questions about privacy at Cwtch:

hello@getcwt.ch

Part B: Full Privacy Policy

1. Introduction

This Privacy Policy explains how Cwtch collects, uses, stores and protects personal information when you use our website, application and services.

It should be read together with our Terms & Conditions and Cookie Policy.

2. Information we collect

We collect information:

directly from you;
automatically when you use Cwtch;
from your interaction with shared couple features;
from payment and subscription activity;
from customer-support interactions; and
from third parties where permitted by law and relevant to providing Cwtch.

3. Relationship and conversation information

The central purpose of Cwtch is to provide personalised relationship experiences.

This means that information you choose to provide may be used to understand your preferences, relationship goals, experiences and interactions with Cwtch.

We recognise that this information may be highly personal.

Our systems are designed around the principle that personal information provided privately by one partner will not become accessible to the other partner.

4. Legal bases

Depending on the purpose, we may rely on one or more lawful bases under applicable data-protection law, including:

performance of a contract;
compliance with a legal obligation;
legitimate interests; and
consent.

Where special category data is processed, we will also identify an applicable condition under UK data-protection law.

The applicable basis will depend on the specific processing activity.

5. Personalisation and profiling

Cwtch may use information about your interactions with the Service to personalise your experience.

We may use information such as your stated relationship goals, preferences, previous activities and interactions to determine which content, questions or activities may be relevant to you.

We will not use solely automated decision-making to make decisions about you that produce legal or similarly significant effects unless the law permits this and appropriate safeguards are in place.

6. AI processing

Cwtch uses artificial intelligence to generate personalised content and responses.

Depending on the feature and technical architecture, information may be processed by third-party AI providers.

We will take appropriate contractual and technical steps to ensure that such processing is consistent with our instructions and applicable data-protection requirements.

Where a provider processes information outside the UK, we will assess the applicable international-transfer requirements and use an appropriate safeguard where required.

7. Research and product improvement

We may use information to understand and improve Cwtch.

Where appropriate, we may use aggregated, anonymised or pseudonymised information for analysis and research.

Where identifiable information is needed for a specific research project, we will assess the appropriate legal basis and provide any additional information or obtain consent where required.

Participation in research will not be a condition of using the core Cwtch service unless clearly stated.

8. Sharing information with your partner

Cwtch may provide shared couple features.

Before information is made available to your partner, the product should indicate whether the information or activity is shared.

We will not deliberately disclose information that we have identified as private to your partner unless:

you ask us to do so;
you have intentionally submitted it to a shared feature;
disclosure is required by law; or
disclosure is necessary to protect someone's vital interests or for another legally permitted reason.

9. Service providers

We may appoint third-party processors to provide services on our behalf.

These may include providers for:

hosting;
databases;
artificial intelligence;
payments;
analytics;
communications;
customer support;
security;
monitoring; and
infrastructure.

We will seek appropriate contractual and technical protections from these providers.

10. International transfers

Some service providers may process personal information outside the UK.

Where a transfer is subject to UK international-transfer rules, we will use an appropriate legal mechanism and safeguards.

These may include adequacy regulations or approved contractual safeguards, depending on the circumstances.

11. Security

We use appropriate technical and organisational measures to protect personal information.

These measures may include encryption, access controls, authentication, monitoring, secure development practices, backups and incident-management procedures.

Further information is provided in our Security Policy.

12. Data retention

We maintain internal retention rules designed to ensure that information is not kept for longer than reasonably necessary.

Retention periods may depend on:

the type of information;
why it was collected;
whether your account remains active;
legal requirements;
security requirements; and
whether information is required to resolve a dispute or enforce an agreement.

13. Deletion

You may request deletion of your account and personal information, subject to legal or other legitimate reasons why certain information may need to be retained.

Deleting your account may also affect shared couple experiences and information.

We will explain the consequences of deletion where relevant.

14. Cookies and similar technologies

We may use cookies and similar technologies to operate the website, understand usage and improve the Service.

Where consent is legally required, we will request it before placing or using the relevant cookies.

Further information will be provided in our Cookie Policy.

15. Marketing

We may send service communications that are necessary to operate Cwtch.

Where required by law, we will obtain consent for marketing communications.

You can unsubscribe from marketing communications at any time.

16. Business transfers

If Cwtch is involved in a merger, acquisition, investment, restructuring or sale of assets, personal information may be transferred as part of that transaction, subject to applicable law and appropriate safeguards.

17. Your rights

You may have rights under applicable data-protection law including rights of access, correction, deletion, restriction, objection, portability and withdrawal of consent.

To exercise a right, contact: