Biometric Information & AI Transparency Policies

Abby is an AI System

Abby is an artificial-intelligence (AI) assistant, not a human. When you talk to or chat with Abby, you are interacting with an AI system. Abby is identified as AI within the App at the point of interaction. Abby is not a member of the Service, and the Service does not use fake or impersonated human profiles. We provide this disclosure consistent with the transparency obligations of the EU Artificial Intelligence Act (Regulation (EU) 2024/1689, Art. 50) and the California Bolstering Online Transparency (B.O.T.) Act.

Compatibility Modeling

Our AI matchmaking system uses automated processing (including machine-learning and rule-based techniques) to model compatibility between users. The system analyzes structured profile information and preferences to estimate how compatible two users may be. AI generation of match rankings and summaries and the Abby chat and voice assistant are provided with the help of third-party AI providers, namely OpenAI (Abby chat and real-time voice assistant, match compatibility rankings, and match summaries) and Anthropic (Anthropic PBC). Anthropic performs generative AI processing under contract, for two purposes: (1) generating the written match summaries shown to members, from their profile and onboarding answers; and (2) an internal staff analytics assistant in the admin panel, which receives only aggregate statistics — never a member's name, contact details, account identifier, or free text. These providers process the relevant content as our service providers under contract and do not use your content to train their own models for their own purposes.

Inputs

Our compatibility models consider the following categories of inputs:

• Explicit Profile Information: Information you provide directly, including demographics, preferences, values, interests, lifestyle choices, relationship goals, and answers to onboarding and compatibility questions.
• Inferred Attributes: Characteristics inferred from your profile data and interactions, including personality traits, communication style, attachment style, values alignment, and emotional intelligence indicators.
• Verified Data: Data obtained through verification processes, including identity verification (selfie matching), age verification, and location verification.
• Behavioral Signals: Patterns of interaction with the Service, including response times, engagement levels, communication patterns, and match feedback.

Approximate Weighting

While exact weights are dynamic and adjusted by the model, the approximate relative importance of different factors in our compatibility algorithm is as follows:

• Values and Psychological Compatibility: approximately 40%
• Shared Interests and Lifestyle: approximately 25%
• Geographic Proximity: approximately 15%
• Other Factors (behavioral signals, engagement, timing): approximately 20%

Important Notes

• Biometric Data Limited Use: Biometric data (facial geometry) is used exclusively for identity verification and safety purposes. It is not used as an input to the compatibility matching algorithm.
• AI-Assisted Processing: Matching and the Abby assistant rely on automated processing assisted by AI. We design our matching with the goal of treating users fairly and not discriminating on the basis of protected characteristics beyond the preferences you yourself state. We do not claim, and you should not infer, that any specific independent fairness-audit or bias-certification program is currently in place.
• Human Involvement in Specific Decisions: Certain consequential decisions, such as account suspensions for safety or policy violations, may involve human review. We do not represent that every automated output is individually reviewed by a person. Where applicable law (including GDPR Art. 22) gives you the right to obtain human intervention, express your point of view, or contest a decision based solely on automated processing, you may exercise that right by contacting us at legal@uniquedatingcompany.com.

Your Rights Regarding AI Processing

You have the right to:

• Opt Out of Location-Based Matching: You may opt out of the use of precise geolocation data in matching by disabling location services for the App.
• Request Deletion: You may request deletion of your data, including all inferred and derived data, at any time by contacting legal@uniquedatingcompany.com.
• Object to Automated Profiling: Where applicable law provides the right to object to solely automated decision-making, you may exercise that right by contacting us.

EU AI Act Classification

Under the EU Artificial Intelligence Act (Regulation (EU) 2024/1689), Abby is an AI system intended to interact directly with natural persons. We are subject to the transparency obligations applicable to such systems (Art. 50): we inform you, in a clear and distinguishable manner, that you are interacting with an AI system, and we provide meaningful information about how our AI matchmaking works and how it affects you (set out in this Part 1). Our matchmaking is not used for any purpose prohibited under Art. 5 of the Act, and we will update this classification if our use of AI changes or as further regulatory guidance is issued.

1. Retention Schedule

The Company shall retain biometric identifiers and biometric information only for as long as necessary to fulfill the purposes for which they were collected, as described in our Biometric Information Notice and Consent (Part 3), or as required by law. In no event shall biometric data be retained longer than the earlier of:

• The date the purpose for collecting the biometric data has been satisfied; or
• Three (3) years from the individual's last interaction with the Service.

In practice, facial-geometry data processed by our identity-verification provider for a verification check is retained only for as long as needed to reach and record the verification decision (including, where a verification is flagged for manual review, the completion of that review), after which the purpose is satisfied and the data is destroyed; the three-year last-interaction limit operates as an outer bound, never as a target retention period.

2. Destruction of Biometric Data

The Company shall permanently destroy biometric identifiers and biometric information when any of the following conditions is met:

• The user deletes their account;
• Three (3) years have elapsed since the user's last interaction with the Service;
• The user withdraws consent for the collection and use of biometric data;
• The initial purpose for collecting the biometric data has been fulfilled and the data is no longer necessary.

Destruction is accomplished by permanent deletion of the biometric data from the systems of our identity-verification provider — effected through the provider's data-deletion interface as soon as a triggering condition above is met — and by deletion of any corresponding records from our own systems. We hold no copies of biometric data on our own storage media. No biometric data survives account deletion; the only record retained thereafter is a salted one-way hash of the verification session identifier, which is not biometric data and cannot be used to reconstruct any biometric identifier.

3. Security Measures

During the retention period, biometric data shall be protected using security measures that are at least as stringent as those used to protect other confidential and sensitive information, including:

• Encryption: All biometric data is encrypted at rest (AES-256) and in transit (TLS 1.2+).
• Access Controls: Access to biometric data is restricted to authorized personnel on a strict need-to-know basis, with all access logged and audited.

What is Biometric Information?

As defined by BIPA, "biometric identifier" means a retina or iris scan, fingerprint, voiceprint, or scan of hand or face geometry. "Biometric information" means any information, regardless of how it is captured, converted, stored, or shared, based on an individual's biometric identifier used to identify an individual.

When you use our selfie verification feature, our identity-verification provider, iDenfy, collects a scan of your face geometry on our behalf. This scan generates temporary mathematical templates (faceprints) that represent your facial features. These templates are encrypted and used solely for the purpose described below.

Purposes of Collection

We collect and use biometric information for a single purpose:

• Identity Verification: To verify that you are who you claim to be through a one-to-one comparison of your verification selfie against the photograph on your government-issued identity document. The verification outcome (not the biometric data itself) is then used to mark your account as verified, which is a safety requirement for using the Service.

We do not currently use biometric data for any other purpose. In particular, we do not perform biometric liveness detection, duplicate-account detection, biometric watchlist screening, or any other form of biometric fraud screening, and we do not use biometric data — in any form — for service improvement, analytics, or model training. If we introduce any additional biometric processing in the future, we will update this notice and our Privacy Policy first and seek any additional consent required by law before it takes effect.

Retention and Destruction

Your biometric data will be permanently destroyed when the first of the following occurs:

• The purpose for which it was collected (your verification decision) has been satisfied — if your verification is flagged for manual review, this occurs when our team resolves that review;
• You delete your account;
• Three (3) years elapse since your last interaction with the Service;
• You request deletion of, or withdraw your consent to, your biometric data.

For full details, please see our Biometric Data Retention and Destruction Policy (Part 2 above).

Disclosure

We do not sell, lease, trade, or otherwise profit from your biometric information. We do not disclose your biometric information to third parties except:

• To our identity-verification provider, iDenfy (UAB iDenfy, Lithuania), which performs the one-to-one face-match identity verification on our behalf as our processor, subject to contractual obligations to protect the data and use it only for the specified verification purpose;
• As required by law, regulation, or legal process;
• With your explicit written consent.

Your Consent

Before any biometric data is collected, the Service presents you with a dedicated in-app biometric-consent screen that discloses the purpose of the collection and how long the data will be retained, and asks you to affirmatively agree. The app asks for — and records in our systems — your explicit, affirmative consent on that screen before the verification capture is launched. By providing that consent, you acknowledge that you have read this Biometric Information Notice and Consent, and you provide your informed, written release (as required by BIPA, including electronic signature) authorizing the Company to collect, store, use, and process your biometric identifiers and biometric information as described herein. We record each consent — including the version of this notice you agreed to and the time of your agreement — in our consent records.

You may withdraw your consent at any time by deleting your account through the App or by contacting us at legal@uniquedatingcompany.com. Upon withdrawal of consent, we will permanently destroy your biometric data in accordance with our Biometric Data Retention and Destruction Policy.