DOWN: The Casual Dating App

"We collect and store data about the computer or mobile device you use to access our Services, including your mobile device's unique ID number (e.g., IMEI, AD ID), your geographic location, the hardware model, operating system and version."

Down collects persistent device identifiers like IMEI and advertising IDs along with hardware details, which goes beyond what a dating app needs for core functionality and enables cross-device tracking.

"We collect and store data about the computer or mobile device you use to access our Services, including your mobile device's unique ID number (e.g., IMEI, AD ID), your geographic location, the hardware model, operating system and version."

Down collects and stores geographic location data from your device without specifying whether this is continuous, how precise it is, or the specific limitations on its use beyond general service provision.

"We share the data we collect from you, including aggregated together with non-PII data, with third party service providers. This may include: Payment processors and facilitators; Technology providers (e.g., cloud storage providers); Consultants, lawyers, accountants and other professional service providers; Data analytics providers; and Marketing service providers."

Down shares user data with a broad range of third parties including data analytics providers and marketing service providers, with no specific limitations on what data each category receives.

"These technologies can remember that your device has visited a website, and may also be able to track your device's browsing activity on other sites or services other than Down. We may use these technologies to understand, improve, and research our Services."

Down explicitly acknowledges that their tracking technologies can follow users' browsing activity across other websites and services beyond Down's own platform.

"Down will maintain data related to the foregoing, which may include transaction history, for seven (7) years. Thereafter, Down will delete such data in accordance with applicable laws."

Even after you request account deletion, Down retains certain personal data for seven years, citing regulatory and compliance obligations but defining the scope of retained data broadly.

"You may request deletion of your account at any time by emailing Down at feedback@downapp.com and making such request. Upon receipt of a request to delete your account and data, Down will delete your account within forty-eight (48) hours after request."

Account deletion requires emailing support rather than offering an in-app self-service option, creating friction. There is also a 48-hour waiting period and a mandatory deactivation step before permanent deletion.

"This Privacy Policy may change from time to time (see Changes to this Privacy Policy). Your continued use of our Services after we make changes is deemed to be acceptance of those changes, so please check the Privacy Policy periodically for updates."

Down treats continued use of the service as acceptance of any privacy policy changes, though they do commit to 15 days email notice for material changes, which partially mitigates this concern.