TROPE — Privacy Policy
Last Updated: 10.08.2026 Version: 2.0
1. Who we are and how to contact us
TROPE is a dating application operated by FAC-Technology Limited, a company incorporated in England and Wales under company number 14446831.
FAC-Technology Limited is the data controller for the personal information described in this policy. That means we are responsible for how it is handled and accountable for it under:
the UK General Data Protection Regulation and the Data Protection Act 2018;
the EU General Data Protection Regulation;
the Swiss Federal Act on Data Protection (FADP).
In this policy, "we", "us" and "our" mean FAC-Technology Limited. "TROPE" and "the App" mean the TROPE mobile application and the services provided through it.
1.1 Contact us
Privacy and data protection enquiries: info@fac-technology.co.uk
You can write to us in English at this address, or by post to our registered office. We also accept correspondence in French and German, though our formal responses will be in English.
1.2 Our representatives
Representative for the European Union (appointed under Article 27 of the EU GDPR and Article 13 of the Digital Services Act):
César Jucker [FULL POSTAL ADDRESS IN AN EU MEMBER STATE — TO BE COMPLETED] cesar.jucker@fac-technology.co.uk
Representative for Switzerland (appointed under Article 14 of the Swiss FADP):
Fabrice Rigot [FULL POSTAL ADDRESS IN SWITZERLAND — TO BE COMPLETED] fabrice.rigot@fac-technology.co.uk
If you are in the European Union, the EEA or Switzerland, you can contact our representative in your region on any matter covered by this policy. You do not have to write to us in the United Kingdom.
2. What this policy covers
This policy explains what personal information we collect when you use TROPE, why we collect it, who we share it with, how long we keep it, and what rights you have over it.
It should be read together with our Terms and Conditions, which govern your use of the App.
By creating an account, you confirm you have read this policy. Reading it is not the same as consenting: where we rely on your consent for something, we ask for it separately and clearly (see clause 4).
3. Information we collect
3.1 Information you give us
Account information. You sign in through Apple Sign-In or Google Sign-In. From them we receive an email address and an authentication identifier. If you use Apple Sign-In and choose to hide your email, we receive a private relay address generated by Apple rather than your own address.
Profile information. To create your profile and match you with other people, you provide:
a first name or display name;
your date of birth, from which we derive your age;
your gender;
your sexual orientation (see clause 4);
your dating preferences;
your dating location;
profile photographs;
your answers to TROPE questions ("Quotes");
profile stickers.
You can change most of this at any time in the App.
Content you create. Photographs, text, Quotes, messages, videos and audio recordings you upload or send through the App.
Reasons for leaving a group. When you leave a group, we ask why. You do not have to answer, and you can leave without answering. What you tell us is visible only to our moderation team — never to the other members of the group. If you report a problem at the same time as leaving, we treat that as a report (clause 3.2 below).
Reports you make. When you report a user or content — including reporting someone you believe is under 18 — we collect what you tell us, what you are reporting, and when.
Support correspondence. If you write to us, we keep your message and our reply.
3.2 Information we collect automatically
How you use the App. Profiles you view, profiles you like, matches created, group participation, messaging activity and other interactions. We use this to operate matching, to keep the App working, and to detect abuse.
Device information. A device identifier, an advertising identifier (only where you have consented — see clause 12), and a push notification token.
Technical and security logs. Like any service running on internet infrastructure, our systems and our hosting provider generate technical logs. These include IP addresses, connection timestamps and error information.
We want to be accurate about this, because it is easy to overstate. We record this information because it is generated by the infrastructure and is necessary for security, fraud prevention and diagnosing faults. We do not use it to build profiles of you, to track you across other services, or to target advertising. Our advertising provider also receives your IP address as a technical necessity of delivering an advertisement, which is unavoidable in serving ads at all.
Location. TROPE uses location to provide matching. We do not track you continuously. We access your location only when you ask to set or update your dating location, and only with your device permission.
Other users can see the city or area you have selected and your approximate distance from them. Your exact coordinates are never shown to another user.
3.3 Information we receive from others
Apple and Google: authentication information when you sign in.
Reports from other users: if another user reports you, we receive what they tell us.
Our moderation tools: the results of automated analysis of your profile content (clause 6).
4. Sexual orientation and other sensitive information
4.1 Sexual orientation
Your sexual orientation is special category personal data under the UK and EU GDPR, and sensitive personal data under the Swiss FADP. It receives stronger legal protection than ordinary information.
Why we need it. TROPE cannot match you with people you might actually want to meet without knowing who you are interested in. It is not optional to the service; it is the service.
Our legal basis is your explicit consent (Article 9(2)(a) UK and EU GDPR; Article 6(7) FADP). We ask for that consent separately and specifically when you first provide your orientation, on its own screen, and not bundled into your acceptance of these documents or the rest of your registration.
If you would rather not give this consent, you do not have to. But because matching cannot work without it, TROPE cannot be provided to you, and you should not create an account. If you have already created one, you can delete it in the App at any time (clause 9.2).
Changing or withdrawing your consent. You can change your sexual orientation in your profile at any time.
You can also withdraw your consent entirely. Because matching cannot operate without this information, withdrawing means we can no longer provide TROPE to you: your account will be closed and deleted under clause 9.2. We tell you this clearly before you confirm, so the choice is a real one. Withdrawal does not affect anything we did lawfully before you withdrew.
To withdraw, delete your account in the App, or write to us at info@fac-technology.co.uk and we will do it for you.
Please note: removing the App from your phone is not the same as deleting your account. See clause 9.2.
4.2 Photographs may reveal more than you intend
We want to flag something users often do not consider. A photograph can reveal information about your ethnic origin, your religion (for example, visible religious dress or symbols), your health or disability, or other sensitive characteristics — even when you upload it simply as a picture of yourself.
Your photographs are analysed automatically for moderation purposes (clause 6). We do not analyse them in order to determine your ethnicity, religion, health or beliefs, we do not record inferences of that kind, and we do not use them for matching or advertising. But you should know that uploading a photograph can make such information visible to other users, and we would rather say so than leave it unsaid.
Where we process information of this kind in the course of moderating content, we rely on your explicit consent to the processing of your profile content for safety purposes and, where applicable, on substantial public interest grounds relating to the protection of users and the detection of unlawful content.
4.3 Information about criminal offences
Where we investigate a report, or preserve material relating to a suspected offence, we may process information relating to alleged criminal conduct. We do this only where necessary for the prevention or detection of unlawful acts, for the protection of users, and to meet our legal obligations.
5. Why we use your information, and our legal basis
What we do Why Legal basis Create and manage your account To let you use TROPE Performance of a contract Create and display your profile Core function of the App Performance of a contract Match you with other users Core function of the App Performance of a contract; explicit consent for sexual orientation Form and operate groups Core function of the App Performance of a contract Deliver messages, photos, video and audio Core function of the App Performance of a contract Send service notifications (matches, group activity, messages) To make the App usable Performance of a contract Moderate content and profiles To keep users safe Legitimate interests (protecting users, platform integrity); legal obligation under online safety law Investigate reports and take enforcement action To keep users safe and enforce our Terms Legitimate interests; legal obligation Detect and prevent fraud, abuse and repeat registration by banned users Safety and platform integrity Legitimate interests Keep the App secure and diagnose faults Security and reliability Legitimate interests Understand in aggregate why people leave groups To improve how matching works Legitimate interests Serve non-personalised advertising To fund a free service Consent for access to the device identifier; legitimate interests for the advertising itself Respond to your requests and exercise of your rights To help you, and to meet our obligations Legal obligation Comply with legal obligations and respond to lawful requests Required of us Legal obligation Report suspected child sexual abuse material and serious offences Protection of children and the public Legal obligation; substantial public interest
Where we rely on legitimate interests, we have considered whether our interest is outweighed by your rights and freedoms, and concluded it is not. You can ask us to explain that assessment, and you can object to that processing (clause 11).
We do not send marketing emails or promotional messages.
6. Automated processing, matching and moderation
6.1 Matching
TROPE's matching and group formation are automated. The system draws on your age and age preferences, gender and gender preferences, sexual orientation, location, dating preferences and your previous interactions with profiles.
No person decides which profiles you are shown. These are recommendations: they do not produce legal effects for you and do not otherwise significantly affect you, so they are not "solely automated decisions" of the kind regulated by Article 22 UK and EU GDPR.
6.2 Moderation tools
We use automated tools to help identify content that breaks our rules:
Amazon Rekognition — analyses uploaded photographs;
Amazon Bedrock Guardrails — analyses profile text, including Quotes.
These tools flag content for review. They do not decide by themselves to terminate your account. Decisions to suspend or terminate are taken by a person on our moderation team.
We may suspend an account automatically and temporarily, pending human review, where automated detection indicates a serious safety risk. Any such suspension is reviewed by a person, you will be told the reasons, and you can challenge it. Our Terms and Conditions explain how (clauses 10 and 12 of the Terms).
6.3 Your rights here
You can ask us for an explanation of how automated processing has affected you, ask a person to review a decision, and challenge the outcome.
7. Who we share your information with
We do not sell your personal information. We have never done so and we do not plan to.
7.1 Other users
Other TROPE users whose preferences correspond to your profile can see: your display name, age, gender, sexual orientation, photographs, Quotes, stickers, your selected city or area, and your approximate distance from them.
Members of a group you are in can see your profile and anything you share in that group.
They cannot see: your email address, your exact location, your device information, or the reason you gave for leaving a group.
TROPE profiles are visible only to signed-in users. They are not published on the open web and are not accessible without an account.
7.2 Our service providers
We use the following providers, each under a contract that restricts them to processing your information on our instructions:
Provider What they do Amazon Web Services Hosting, storage, authentication infrastructure and moderation tools (Rekognition, Bedrock Guardrails). Infrastructure is hosted in the United Kingdom Apple Authentication through Apple Sign-In; delivery of push notifications through the Apple Push Notification service Google Authentication through Google Sign-In; delivery of push notifications through Firebase Cloud Messaging; advertising through Google AdMob; consent collection through Google's consent management platform
7.3 Our moderation team
Our moderation team is internal to FAC-Technology and based in Switzerland. It is not outsourced.
Where a report is made, a moderator may review the reported profile, photographs, messages, videos and audio content, and the reasons users gave for leaving a group, to the extent necessary to assess the report. Access is limited to what is needed and is logged.
7.4 Law enforcement and legal requirements
We may disclose information where we need to:
comply with a legal obligation or a lawful request from an authority or court;
report suspected child sexual abuse material to the Internet Watch Foundation and, where appropriate, to law enforcement (clause 9.3);
report information giving rise to a suspicion of an offence involving a threat to the life or safety of a person;
protect the rights, safety or property of our users, the public, or ourselves;
establish, exercise or defend legal claims.
7.5 If our business changes
If we are involved in a reorganisation, merger or sale, your information may transfer to the new entity. We will tell you before it happens, the protections in this policy will continue to apply, and you can delete your account if you would rather not continue.
8. Sending information outside your country
Your information may be handled in countries other than the one you live in. Where that happens, we make sure a recognised legal safeguard is in place. Here is exactly what applies:
Our infrastructure is in the United Kingdom. AWS hosts TROPE in the UK.
If you are in the European Union or the EEA: your information is transferred to the United Kingdom. This relies on the European Commission's adequacy decisions for the United Kingdom, renewed on 19 December 2025 and in force until 27 December 2031. An adequacy decision is a formal finding that the UK provides a level of data protection essentially equivalent to EU law. No additional contractual safeguard is required. If those decisions were to lapse or be withdrawn, we would put Standard Contractual Clauses in place and update this policy.
If you are in Switzerland: your information is transferred to the United Kingdom, which is recognised by Switzerland as providing adequate protection.
If you are in the United Kingdom: your information stays in the United Kingdom for hosting purposes.
Access by our moderation team in Switzerland. Our moderators access UK-hosted systems from Switzerland. The United Kingdom recognises Switzerland as providing adequate protection, so this transfer is covered.
Our providers. Apple, Google and AWS are international businesses and may process limited information — such as authentication data and push notification tokens — outside the UK, EEA and Switzerland under their own transfer mechanisms, including Standard Contractual Clauses and the UK International Data Transfer Addendum.
You can ask us for more detail about any of these safeguards, and we will provide it.
9. How long we keep things
We keep information only as long as we need it.
What How long Account and profile information While your account is active Account after you ask us to delete it Permanently deleted at the end of the 30-day deletion period (clause 9.2) Messages, photographs, videos and audio in conversations Removed after 30 days Reasons given for leaving a group 12 months in identifiable form, then aggregate only. 2 years where the reason led to a moderation record Reports and moderation records 2 years, for safety, enforcement and identifying repeat breaches Irreversible hash of a terminated account, to prevent re-registration 2 years Technical and security logs 12 months Support correspondence 2 years Records of your consent choices 2 years after the consent ends, as evidence that we obtained it Material relating to a suspected criminal offence As long as necessary for reporting and any investigation, then deleted (clause 9.3)
We may keep information longer where the law requires it, or where it is necessary to establish, exercise or defend legal claims. Where we do, we keep only what is needed for that purpose.
9.1 Voice and audio content
Voice messages and audio shared in a group are removed on the same 30-day basis as other content. Where a group is closed or deleted, the audio in it is deleted with the group.
9.2 Deleting your account
You can delete your account at any time in the App, without giving a reason. When you do:
your profile becomes unavailable to other users immediately;
a 30-day deletion period begins;
you can cancel deletion at any point in those 30 days by signing back in;
at the end of the 30 days, your account and personal information are permanently deleted, apart from the limited items listed in the table above.
Removing the App from your phone does not delete your account. If you uninstall TROPE without deleting your account, your profile stays visible to other users and your information stays on our systems. To actually delete your information, use the delete function inside the App, or write to us at info@fac-technology.co.uk and we will do it for you.
9.3 Material relating to child sexual abuse
If we identify child sexual abuse material, we do not simply delete it, because doing so can destroy the only evidence that a child is being harmed. Instead we:
remove it from all user visibility immediately;
terminate the account;
hold the material in a separate, encrypted, access-controlled and logged environment, accessible only to named individuals;
report it to the Internet Watch Foundation and, where appropriate, to law enforcement;
delete it once the relevant authority confirms it is no longer needed.
10. Keeping your information secure
We take security seriously and use measures appropriate to the sensitivity of what we hold, including:
encryption of information in transit and at rest;
access controls, so that staff can reach only what their role requires;
logging of access to reported content and moderation records;
separation of sensitive material into restricted environments;
authentication handled by Apple and Google rather than by passwords we store — we never see or hold a password for your Apple or Google account.
No system is perfectly secure, and we will not claim otherwise. You can help by keeping the Apple or Google account you sign in with secure.
10.1 If something goes wrong
If a security incident affects your personal information, we will assess it promptly. Where the law requires it, we will notify the relevant supervisory authority — within 72 hours of becoming aware, where the UK or EU GDPR applies — and we will tell you directly where the incident is likely to result in a high risk to your rights and freedoms. We will tell you what happened, what information was involved, what we are doing about it, and what you can do.
11. Your rights
Depending on where you live, you have some or all of the following rights. All of them are free to exercise.
Access. Ask for a copy of the personal information we hold about you, and information about how we use it.
Correction. Ask us to correct information that is wrong or incomplete. Most profile information you can correct yourself in the App.
Deletion. Ask us to delete your personal information. You can delete your account directly in the App (clause 9.2).
Portability. Ask us to provide the information you gave us in a structured, commonly used, machine-readable format, or to send it to another service where technically feasible. This covers what you provided — your profile fields, photographs, Quotes, messages you sent and audio you recorded. It does not cover moderation records or reports about you, which you can still request under your right of access.
Restriction. Ask us to limit how we use your information while a dispute about it is resolved.
Objection. Object to processing we carry out on the basis of legitimate interests. We will stop unless we have compelling grounds to continue, and we will explain our reasoning.
Withdrawal of consent. Withdraw consent where we rely on it — including your consent to the processing of your sexual orientation (clause 4.1) and to advertising identifiers (clause 12). Withdrawal is as easy as giving consent, and does not affect processing that already took place lawfully.
Human review of automated decisions. Ask a person to review a moderation decision, and challenge the outcome.
Complain to a regulator. See clause 11.2.
11.1 How to exercise your rights
Write to info@fac-technology.co.uk, or to our representative in your region (clause 1.2).
We will respond within one month. If your request is complex, we may extend that by up to two further months, and we will tell you within the first month if we need to, along with the reason.
We may need to confirm your identity before acting — usually by asking you to write from the email address linked to your account. We ask for the minimum necessary.
If we refuse a request, we will tell you why and how to challenge that decision.
11.2 Complaining
If you are unhappy with how we have handled your personal information, please tell us first — we would rather fix it. Write to info@fac-technology.co.uk with "Data protection complaint" in the subject line. We will acknowledge your complaint, investigate it, and respond substantively within one month.
You can complain to a regulator at any time. You do not have to come to us first, and complaining to us does not limit your right to go to a regulator or a court.
United Kingdom: Information Commissioner's Office — ico.org.uk
European Union / EEA: the data protection authority in your country. A list is maintained by the European Data Protection Board.
Switzerland: Federal Data Protection and Information Commissioner — edoeb.admin.ch
12. Advertising
TROPE is free to use, and advertising is how we pay for it.
We show non-personalised advertising only. We do not build advertising profiles about you, we do not use your profile information, your messages, your photographs or your sexual orientation for advertising, and we do not allow advertisers to target you based on any of it.
Advertising is provided by Google AdMob. Even non-personalised advertising involves accessing an identifier stored on your device, and AdMob receives your IP address as a technical necessity of delivering an advertisement.
Because of that, we ask for your consent before any advertising identifier on your device is accessed. We do this through a consent management platform, presented when you first use the App.
You can change or withdraw your choice at any time in the App's settings. Withdrawing consent does not restrict your access to any part of TROPE — you will simply see advertising that does not rely on a device identifier.
Your use of AdMob is also subject to Google's own privacy terms.
13. Analytics
TROPE does not currently use analytics services such as Google Analytics or Firebase Analytics.
If we introduce analytics in future, we will update this policy, tell you before we start, and obtain your consent where the law requires it.
14. We do not use your content to train AI models
We want to state this plainly, because it is a question people rightly ask.
We do not use your content — your photographs, messages, Quotes, videos or audio — to train, fine-tune or develop artificial intelligence or machine learning models, whether our own or anyone else's. We do not give your content to third parties for that purpose.
The automated tools described in clause 6 analyse your content in order to detect content that breaks our rules. That is a different thing from training: your content is checked, not used to build a model.
This is a binding commitment, reflected in clause 7.4 of our Terms and Conditions. We will not change it without telling you in advance and, where required, asking for your consent.
15. Children
TROPE is strictly for adults aged 18 or over. By creating an account you confirm you are at least 18.
We want to be honest about how we check this. TROPE currently relies on your declaration of your age, supported by an 18+ rating on the app stores and by a dedicated in-app function that lets any user report an account they believe belongs to someone under 18. We do not currently carry out identity or facial age verification. We may introduce it, and if we do we will update this policy.
We do not knowingly collect personal information from anyone under 18. Where we have reason to believe an account holder is under 18, we suspend the account immediately while we investigate, and where we conclude they are under 18 we terminate the account and delete the information, keeping only what is needed to prevent re-registration or to meet a legal obligation.
If you believe a TROPE user is under 18, please report it. Use the in-app function or write to info@fac-technology.co.uk. You do not need proof. We treat these reports as our highest priority, and a report made in good faith will never count against you.
16. Changes to this policy
We may update this policy. When we do, we will change the date at the top.
Where a change is significant, we will tell you in advance — through the App, by email, or both — and we will explain what is changing. Where a change requires your consent, we will ask for it before the change takes effect, not afterwards.
17. Contact
FAC-Technology Limited Company number 14446831 (England and Wales) info@fac-technology.co.uk
EU representative: César Jucker — cesar.jucker@fac-technology.co.uk Swiss representative: Fabrice Rigot — fabrice.rigot@fac-technology.co.uk
Regulators: Information Commissioner's Office (UK) — ico.org.uk Federal Data Protection and Information Commissioner (Switzerland) — edoeb.admin.ch The data protection authority of your country (EU/EEA)