Legal

JustThen Privacy Policy

Effective date: this Privacy Policy was last updated on 15 August 2026.

Welcome to the JustThen Privacy Policy (“Policy”)! This explains how we collect, store, protect, and share your information, and with whom we share it. We suggest you read this in conjunction with our Terms and Conditions of Use.

Whilst you’re enjoying the JustThen mobile application (including the desktop version) (“App”), our websites and microsites (such as justthen.app) or using our digital products and services (such as our competitions or surveys) (together, referred to in this Privacy Policy as our “Sites”), we collect some information about you. In addition, you may choose to use the App or Sites to share information with other users, including your friends and contacts (“Users”). We may also need to share your information sometimes.

The App and Sites are global, and your information will be sent to and used in India regardless of the country you reside in. This Policy explains how we protect your personal data when we transfer it overseas, so please read very carefully!

Who we are

The App and Sites are operated by the “JustThen Group”. The JustThen Group has designated a Data Protection Officer and they can be reached by emailing support@justthen.app.

Contents

Collection of Information
Use of Your Information
Disclosure of Information
What Others May See About You
Our Policy Towards Age
Security
Linking Other Accounts to JustThen
Your California Privacy Rights
Your Rights
Child Safety Commitment
Data Retention and Deletion
Changes to This Policy

1. Collection of Information

Registration Information

When you download the App and create an account (“Account”), we may collect certain information (“Registration Information”) about you, such as:

Name;
Username;
Email address;
Mobile number;
Gender identity;
Date of birth;
Sexual preference;
Photographs;
Location; and
Login information for social media accounts that you connect to your JustThen Account (this could include, for example, your Facebook and Instagram accounts). For more information about this, see “Linking Other Accounts to JustThen” in section 7 below.

Once you register, you will be able to review and change this information at any time just by logging in to JustThen (other than your date of birth and location (which, if you have given JustThen access to your location in your device settings, is automatically updated based on the location of your device)). It is your responsibility to ensure that your account details are kept up to date. If your phone number changes, please ensure that you update this in your account.

The information we collect helps to enhance the App and verify our Users (robots are not welcome!). Registration Information such as your sexual preference, name and username may be visible to other Users who view your profile page.

For Users who are California residents, the data we may collect falls within the following categories of “personal information”, as defined by the California Consumer Privacy Act (CCPA):

Identifiers, such as name and location;
Personal information, as defined in the California customer records law, such as contact (including email and telephone number) and financial information;
Characteristics of protected classifications under California or federal law (if you choose to provide them), such as age, gender identity, marital status, sexual orientation, race, ancestry, national origin, religion, and medical conditions;
Commercial information, such as transaction information and purchase history;
Biometric information (see “Profile Verification Information” below);
Internet or network activity information, such as browsing history and interactions with our Sites and App;
Geolocation data, such as mobile device location;
Audio, electronic, visual and similar information, such as photos, videos and voice recordings;
Professional or employment-related information, such as work history and prior employer;
Non-public education information; and
Inferences drawn from any of the personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.

Profile Information

We recommend and encourage you (and all our members) to think carefully about the information you disclose about yourself. We also do not recommend that you put email addresses, URLs, instant messaging details, phone numbers, full names or addresses, credit card details, national identity numbers, drivers’ licence details and other sensitive information which is open to abuse and misuse on your profile.

When you post information about yourself or use the messaging function to communicate with other Users, the amount of personal information you share is at your own risk. Please see Section 4 below for more information on who can access what you post on JustThen.

Voice Notes and Voice Features

If you record a voice note for your profile, we collect and store that recording so that it can be played by other Users who view your profile. You can re-record or remove your voice note at any time in the App. If you use voice-based features such as Vibe Check calls, we process the connection and usage data necessary to provide the feature.

Profile Verification Information (Including Biometric Information)

For safety and security and to ensure you have the best possible user experience, we require Users to verify their accounts and, in some instances, we might also ask that you carry out photo verification. We want to make sure you are not a robot! And we also want to avoid fake JustThen accounts being created which can be used for malicious activities and cybercrime – they threaten the JustThen network and spoil things for everyone. This verification might be required by us for the prevention of fraud. You can also verify your photo on a voluntary basis (to add the blue ‘verified’ badge to your profile).

If you choose to verify your profile photo, we will scan each photo that you submit. The scan may include the use of facial recognition technology so that we can compare the photo you submit to your profile photo, to help ensure that you are who you say you are. We do not add the verification photos to your profile. We retain the scans so that we can verify you in the future and for our record-keeping purposes until we no longer need them for such purposes or for three years after your last interaction with us, whichever occurs first. After the applicable retention period expires, we take commercially reasonable steps to permanently and securely delete the scans from our systems.

Purchases Information

If you decide to purchase any of our premium services, we will process your payment information and retain this securely for the prevention of fraud and for audit/tax purposes.

JustThen uses automated decisions to prevent fraudulent payment transactions being processed as part of its anti-fraud procedures. In order to do this, our systems check payment transactions for behaviour that indicates breaches of our Terms and Conditions of Use. If a transaction meets certain criteria that demonstrate that the Terms and Conditions of Use are likely to have been breached and the transaction is likely to be fraudulent, the relevant transaction may automatically be blocked. Where a transaction is blocked, the user will be notified that their transaction cannot be processed and affected Users can contact JustThen to contest the decision.

Geolocation Information

If you have given JustThen access to your location in your device settings, when you use your mobile, we will collect information about WiFi access points as well as other location information about your longitude and latitude and may save your device’s coordinates to offer certain features to you. This information helps us identify your physical location and we use it to personalise the App and make it easier for you to interact with other Users, by enabling the general locality information to be displayed to Users seeing your profile and showing you the profiles of other Users who are near you.

If you have given JustThen access to your location, but wish to turn this off, you can do so by the following methods:

iPhone app — Settings, Privacy, Location Services, JustThen
Android — Settings, Location, JustThen, Permissions, Location

Device Information

We may collect information about your device when you use the App including the unique device identifier, device model, operating system, and MAC address, for a number of purposes, as set out in this policy.

Links

We may keep track of how you interact with links available on JustThen including third party services by redirecting clicks or through other means. We may share aggregate click statistics such as how many times a particular link was clicked on.

JustThen Success Stories, Surveys and Other Contributions

From time to time, we run surveys for research purposes and we may contact you to find out if you would like to take part. We may also contact you to find out if you would like to provide feedback, a testimonial or take part in marketing campaigns (for example, if you let us know that you have found a match on the App, we may contact you to ask if you would be happy to feature in advertising for JustThen). Such surveys and marketing campaigns are optional and more information will be provided at the point of contact. If you do not wish to be contacted to take part in a survey or marketing campaign, please contact our Customer Support Team via support@justthen.app.

When You Contact Customer Support

If you contact our Customer Support team, we will receive your email address, and may track your IP address, as well as the information you send to us to help resolve your query. We will keep records of our communications with you, including any complaints that we receive from you about other Users (and from other Users about you) for 6 years after deletion of your account.

Cookies and Similar Technologies

When you visit our Sites or when you use our App, we may collect personal data from you automatically by using cookies or similar technologies. A cookie is a small file that can be placed on your device or browser that allows us to recognise and remember you.

2. Use of Your Information

Our main goal is to ensure your experience on JustThen is an enjoyable one and you don’t end up getting stung! In order to deliver an enjoyable experience to you, we may use your Registration and other information to:

offer you our services and features;
contact you with information about the App (e.g., updates and new features);
personalise the App/Sites and the content we deliver to you;
conduct research and analytics about how you use and interact with the App/Sites;
resolve disputes, troubleshoot problems and to enforce our Terms & Conditions;
investigate fraud, protect our legal rights, and to enforce our Terms & Conditions;
send you information about the promotions and offers we have available — if you’ve signed up for our communications or otherwise told us it’s OK (you can withdraw from marketing at any time via Settings in the App or by using the opt-out mechanisms and links provided in each message); and
protect our Users and third parties from harm.

Moderation Practices

We use a combination of automated systems and a team of moderators to monitor and review accounts (including photos and any other information uploaded onto user profiles) and messages for content that indicates breaches of our Terms and Conditions of Use. If an account or message meets certain criteria that demonstrate that the Terms and Conditions of Use are likely to have been breached, the relevant account will be subject to a warning and the user’s access restricted and/or blocked. Affected Users can contact JustThen to contest the decision.

If you post anything that is inconsistent with our Terms and Conditions of Use, we reserve the right to terminate or restrict access to your Account.

Lawful Basis

Under EU and UK data protection laws, we are required to tell you our lawful basis for using your data and we have set this out in the table below. Where the legal basis is consent, you can withdraw consent at any time. Where the legal basis is legitimate interests, you have a right to object to our use of your data. We explain in the relevant sections in this Policy how you can withdraw consent or opt-out of certain data uses (where applicable).

Purpose for which data is used	Data	Source	Legal basis
To provide you with the JustThen social networking service	Name, email address, date of birth, location (CCPA Categories A and B)	You provide your name, email address and date of birth to us. We obtain location data from the device that you use to access the service	Contractual necessity
To facilitate networking opportunities on the JustThen App	Optional information that you choose to provide in your profile, including through profile verification, or adding JustThen badges, which may include information about your sexual preferences, non-binary gender, religion, ethnic background, photos etc. (CCPA Categories C, H, I, J)	You provide this information to us	Consent
To verify your identity and prevent fraud and to ensure the safety and security of Users	Phone number and if requested or permitted, photo provided as part of profile verification and for users based in countries where age verification is required by law: photo of Government ID + geolocation and device information (CCPA Categories A, B, C, F, G and H)	You provide this information to us, except for the geolocation and device information, which we obtain from the device that you use to access the service	Legitimate interests – it is in our legitimate interests to ensure that accounts are not set up fraudulently and to safeguard Users of the site
To take payment for premium services (not applicable for Users making payments via the Apple App Store)	Payment card details (CCPA Categories B and D)	You provide this information to us	Contractual necessity
To send you marketing information about our events, offers and services	Name, email address, postal address, Instagram handle and mobile phone number (CCPA Categories A and B)	You provide this information to us	Consent or legitimate interests and in accordance with the laws applying to our marketing activities. We have a legitimate interest in promoting our business and products
To carry out research and analysis to help us improve the App	Log and usage data, including IP address, browser type, referring domain, pages accessed, mobile carrier and search terms, images and video (CCPA Categories F and H)	You provide photos and videos to us. We obtain the log and usage information from the device that you use to access the service	Legitimate interests – it is in our interests to analyse the way in which Users are accessing and using our services so that we can further develop the App, implement security measures and improve the service
To respond to correspondence and queries that you submit to us, including social media queries	Email address and IP address, social media name, phone number (CCPA Categories B and F)	You provide your email address, social media name and phone number to us when you contact us and we obtain your IP address from the device that you use to contact us	Legitimate interests – it is in our legitimate interests to respond to your queries to ensure that we provide a good service to Users and troubleshoot problems
To investigate and block Users for reported infringements of our Terms and Conditions of Use	Name and user registration details, profile information, content of messages and photographs + usage and device data such as IP address and IP session information (CCPA Categories A, B, C, F, and H)	You provide your registration details, profile information, messages and photographs to us. We obtain the other information from the device that you use to access the service.	Legitimate interests – it is in our legitimate interests to prevent unauthorised behaviour and to maintain the safety and integrity of our services
To enable Users to create and enhance their JustThen profile and log into the App via third party accounts	Data from Facebook and other third-party accounts (see section 7 of this Privacy Policy for more details) (CCPA Categories A, B, C, and H)	We obtain this information from Facebook, or the providers of any other accounts you use to log in or connect with your JustThen account	Legitimate interests – it is in our legitimate interests to facilitate access to our services
To block payment transactions as part of our anti-fraud procedures	Name, IP address, email address, mobile number, cardholder name, payments received, type of payment, user ID, country (CCPA Categories, A, B, and D)	You provide your name, email address, mobile number and card details to us. We obtain your IP address from the device that you use to contact us. We obtain your payment information from your interactions with our service	Legitimate interests – it is in our legitimate interests to prevent fraudulent transactions and to maintain the security of our services
To serve promo cards and advertisements on the App	Location, gender, age, and information that you have optionally provided us with via your profile (CCPA Categories A, C and G)	We obtain age, gender and profile information from you, and location data from the device that you use to access the service	Legitimate interests – it is in our legitimate interests to target advertisements so that Users see relevant advertisements and to allow us to generate income from advertising revenue
To serve advertisements on third party networks and measure the effectiveness of such ads	Data about your visit to our Sites or App and action taken on those (for example if you downloaded our App or created an account with JustThen), IP address (and your estimated location based on your IP address), age and gender, device ID (CCPA Categories B, C, G, F and K)	We obtain age and gender from you and we obtain other information from the device or browser that you use to access the service	Consent – as indicated by you in your Privacy Settings/Cookies Settings preferences and via your browser or device privacy preferences (where required by your device manufacturer, for example Apple devices using iOS 14.5)
To contact you in order to run surveys for research purposes and to obtain feedback, and to find out if you want to take part in marketing campaigns	Email address and mobile phone number (CCPA Category B)	You provide this information to us	Legitimate interests – it is in our legitimate interests to carry out research so that we can further develop the app and improve the service
To defend legal claims, protect legal rights and to protect people from harm	This could include any information that is relevant to the issue	This information may be obtained directly from you, from your device or from third parties, depending on the information involved	Legitimate interests – it is in our legitimate interests to protect our legal rights, defend legal claims and to protect our Users and third parties from harm

3. Disclosure of Information

Our policy is to not disclose your Registration Information or personal data, except in the limited circumstances described here:

Circumstances where data may be disclosed	Disclosed data
Service Providers – We engage certain trusted third parties to perform functions and provide services to us. We may share your Registration Information or personal data with these third parties, but only for the purposes of performing these functions and providing such services. More information about this is available directly below.	This could include all data, including all CCPA Categories listed above
Moderators – To monitor activity on the App and approve content.	Name and user registration details, profile information, content of messages and photographs (CCPA Categories A, B, C, and H)
Payment Processing and Telecommunications Companies – To facilitate payments for our premium services.	Cardholder name, cardholder address, card number, payment amount, transaction date/time (CCPA Categories A, B, and D)
Law and Harm – As we mentioned in the Terms & Conditions, we think it is very important that all Users behave whilst using the App. We will cooperate with all third parties to enforce their intellectual property or other rights. We will also cooperate with law enforcement enquiries from within or outside your country of residence where we are required to by law, where there is an investigation into alleged criminal behaviour or to protect the vital interests of a person. This may include preserving or disclosing any of your information, including your Registration Information, if we believe in good faith that it is necessary to comply with a law or regulation, or when we believe that disclosure is necessary to comply with a judicial proceeding, court order, or legal request; to protect the safety of any person; to address fraud, security or technical issues e.g. through anti-spam providers to protect the service from criminal activity or to protect our rights or property or those of third parties. In such cases we may raise or waive any legal objection or right available to us.	This could include any personal data that JustThen holds about you, depending on the nature of the request or the issue that we are dealing with, including all CCPA Categories listed above
Business Transfers – In the event that a JustThen Group entity or any of its affiliates undergoes a business transition or change of ownership, such as a merger, acquisition by another company, re-organisation, or sale of all or a portion of its assets, or in the event of insolvency or administration, we may be required to disclose your personal data.	This could include all personal data that JustThen holds about you, including all CCPA Categories listed above
Marketing Services Providers – To help us serve marketing and advertising on third party websites and applications and measure the effectiveness of our advertising campaigns. More information on this is available below.	Advertising identifier associated with your device (Device ID), estimated location (based on your IP address), age, gender and data about your visit to our Sites or App and action taken on those (for example if you downloaded our App or created an account with our App), hashed email address (for ‘custom audiences’ only) (CCPA Categories B, C, G, F and K)
Anti-Spam and Anti-Fraud – Your data may be shared with other JustThen Group companies, for example, to block accounts and suspected fraudulent payment transactions as part of our anti-spam and anti-fraud procedures.	Email address, phone number, IP address and IP session information, social network ID, username, user agent string, and transaction and payment data (CCPA Categories B, F and D)
Aggregated Information – We may share aggregated information with third parties that includes your personal data (but which doesn’t identify you directly) together with other information including log data for industry analysis and demographic profiling.	Aggregated, non-identifying information

JustThen does not sell your data and has not sold your personal data in the previous 12 months.

More Information About Disclosures

Sharing your personal data with Service Providers

We engage certain trusted third parties to perform functions and provide services to us (“Service Providers”). The suppliers with which JustThen shares User personal data vary depending on a variety of factors, such as which of our App, Sites and services a User engages with. For example, to provide our services to Users, we typically use the following suppliers:

Billing services – to allow customers to purchase paid features of our App (for example, Google Play)
Authentication services – to allow customers to authenticate their account (for example, Twilio)
Social media providers – to allow customers to create/connect their JustThen account with their account(s) on such platforms (for example Facebook, Instagram or Spotify)
Product improvement and market research – we use third party platforms (such as Typeform) and agencies (such as Kantar) to carry out customer surveys and market research to improve our products and services
IT services – some of the third-party software providers used in the operation of our business may process Users’ personal data (for example, if a User contacts us via social media with a support inquiry, their inquiry is processed by our community management software provider)

We carry out due diligence on all Service Providers we engage to ensure they have adequate data protection and information security measures in place and only provide them with the personal data necessary to the service they are providing. Measures are taken to ensure that the data shared is non-attributable to the greatest extent possible and our suppliers are also subject to extensive obligations under our contractual arrangements, including strict data retention limits.

Sharing your personal data with Marketing Services Providers

We partner with providers of marketing services (such as Facebook for example) (“Marketing Services Providers”) to help us market and advertise our App and services on third party websites and applications and measure the effectiveness of our advertising campaigns. For example:

to exclude you from advertising campaigns aimed at finding new users, if you already have a JustThen account;
to show JustThen adverts to users who have visited the JustThen App/Sites but haven’t yet created a JustThen account;
to create an audience for our advertisements of other potential users who have similar characteristics to you based on the information the Marketing Service Providers holds about you (also known as a Lookalike Audience); or
to include you in a ‘custom audience’ that will receive JustThen advertising content (a custom audience is essentially a list of people who we think are most likely to be interested in a particular advertisement).

We share a limited amount of your personal data with these Marketing Services Providers, such as:

the advertising identifier associated with your device (this is a random number assigned by your mobile device manufacturer (for example Apple or Google) to your device to help advertisers (including the manufacturer) know when an ad has been viewed or clicked in an app, and when an ad causes a ‘conversion’ (for example, downloading the app advertised to you))
your estimated location (based on your IP address)
age and gender
data about your visit to our Sites or App and action taken on those (for example if you downloaded our App or created an account with our App)
a hashed* version of your email address (to create ‘custom audiences’).

*Hashing is a way of encrypting information by turning it into a combination of random numbers and letters — this code cannot be traced back to the email address. When hashed email addresses are sent to a Marketing Service Provider, they’re then matched against the Provider’s own existing list of their own users’ hashed information and our ads are served to those of our users who have successfully been matched with the Provider’s. Matched and unmatched hashes are then deleted by the Provider.

Some platforms require user consent before JustThen is permitted to use data gained through the platform for advertising purposes and where this is the case, JustThen will only use this data where the necessary consent has been obtained. Through your device’s privacy settings, you also have the option to prevent or limit device identifiers being shared with third party advertisers and what use is made of the device identifiers. Please review your device manufacturer’s privacy settings for more information about these choices.

In some cases, these third parties will also use the data that they collect for their own purposes, for example they may aggregate your data with other data they hold and use this to inform advertising related services provided to other clients.

4. What Others May See About You

We think our Users are awesome, and we want you to share how awesome you are with the world, so we have built certain features to enable this. Our App is designed to make it easier for you to connect with other Users and to interact with them.

When using the JustThen App, you should assume that anything you post or submit on the App may be publicly-viewable and accessible, both by Users and non-users of the App. We want our Users to be careful about posting information that may eventually be made public.

Please be careful about posting sensitive details about yourself on your profile such as your religious denomination and health details. You may also choose to add sensitive information about yourself when you add certain JustThen badges to your profile, such as your religion and political leanings. While you may voluntarily provide this information to us when you create your profile, including your sexual preferences, there is no requirement to do so. Please remember that photographs and voice notes that you post on JustThen may reveal information about yourself as well. When you upload and choose to tell us sensitive information about yourself, including through the addition of badges to your profile, you are explicitly consenting to our processing of this information and making it public to other Users.

Your JustThen profile and other information you make available via the App, including certain information added to your profile through third party accounts (such as Facebook, Instagram or Spotify – see section 7 of this Privacy Policy for more information about this) may be viewed and shared by Users with individuals who may or may not be users of the App. For example, a User may recommend you as a match to his or her Facebook friend(s) by taking a screenshot of your profile picture and sharing it, regardless of whether such friend(s) is also a User of the App.

Please also note that in certain countries (currently, South Korea only), Users are provided with functionality enabling them to download a copy of their conversation history (as this is required by local laws) and that JustThen has no control over how users may then publish or use that information.

If you log in to or access the App through your Facebook account or another third-party account on a device which you share with others, remember to log out of the App and the relevant third-party account when you leave the device in order to prevent other users from accessing your JustThen account.

5. Our Policy Towards Age

Although we want as many people as possible to enjoy our creation, you have to be at least 18 years old to use the App. JustThen does not knowingly collect any information about or market to children, minors or anyone under the age of 18. If you are less than 18 years old, we request that you do not submit information to us. If we become aware that a child, minor or anyone under the age of 18 has registered with us and provided us with personal information, we will take steps to terminate that person’s registration.

6. Security

Here at JustThen, we pride ourselves on taking all appropriate security measures to help protect your information against loss, misuse and unauthorised access, or disclosure. We use reasonable security measures to safeguard the confidentiality of your personal information such as secured servers using firewalls.

Unfortunately, no website or Internet transmission is ever completely 100% secure and even we cannot guarantee that unauthorised access, hacking, data loss or other breaches will never occur, but here are some handy tips to help keep your data secure:

Please make sure you log out of your Account after use as you never know who may stumble onto your Account!
Please don’t share the password you use to access your JustThen Account with anyone else!
Change your password periodically.

7. Linking Other Accounts to JustThen

Using your social media details to sign in to JustThen

When you sign in to our App using your Facebook account, you give permission to Facebook to share with us your name and profile picture. Unless you opt-out, you also give permission to Facebook to share with us your email address (if there is one associated with your Facebook account), date of birth, profile photos, gender, Page likes and current town/city.

If you register or sign in with your Apple ID, you give Apple permission to share your Apple login, a name (that can be edited by you) and an email (you can choose to hide your email and Apple will create a random email address so your personal email can stay private). This email address will be linked to your JustThen account and will be used to retrieve your JustThen account.

We will then use this personal data to form your JustThen account. If you remove the JustThen app from your Facebook settings, or from your Apple ID, we will no longer have access to this data. However, we will still have the personal data that we received when you first set up your JustThen account using your Facebook or Apple ID (you must delete your JustThen account entirely for us to no longer have access to this data).

Linking social media accounts to your JustThen account

This allows you to share some information from those accounts directly to your JustThen account (for example, Instagram photos, or your top Spotify artists).

We only receive the limited information that Instagram or Spotify permits to be transferred (as detailed by Instagram/Facebook/Spotify and agreed by you when you first connect your account from such platforms with your JustThen account).

If you no longer want to link your JustThen account to your Instagram, Facebook or Spotify account, please visit the settings in your Instagram, Facebook or Spotify account and follow the instructions to remove the JustThen app access permissions. Please note that any information already added to your JustThen account from those platforms will not be deleted unless you delete it within your JustThen account as well.

8. Your California Privacy Rights

For Users who are California residents, you have the following rights (in addition to those listed at section 9 below) under the California Consumer Privacy Act, and you have the right to be free from unlawful discrimination for exercising your rights under the Act:

You have the right to request that we disclose certain information to you and explain how we have collected, used and shared your personal information over the past 12 months.
You have the right to request that we delete your personal information that we collected from you, subject to certain exceptions.

California’s “Shine the Light” law, Civil Code section 1798.83, requires certain businesses to respond to requests from California customers asking about the businesses’ practices related to disclosing personal information to third parties for the third parties’ direct marketing purposes. From time to time, as part of a joint promotion with a third party, we may, if you participate in such promotion, disclose your contact information to the third party to allow them to market their products or services to you. Where this is a condition for participation in a promotion, we will always let you know before you enter the promotion. Please follow the instructions provided to you by third parties to unsubscribe from their messages.

In addition, under California law, operators of online services are required to disclose how they respond to “do not track” signals or other similar mechanisms that provide consumers the ability to exercise choice regarding the collection of personal information of a consumer over time and across third party online services, to the extent the operator engages in that collection. At this time, we do not track our Users’ personal information over time and across third-party online services. This law also requires operators of online services to disclose whether third parties may collect personal information about their users’ online activities over time and across different online services when the users use the operator’s service. We do not knowingly permit third parties to collect personal information about an individual User’s online activities over time and across different online services when using the App.

9. Your Rights

Privacy laws applicable in your country may give you the following rights:

Right to be informed: what personal data an organisation is processing and why (we provide this information to you in this Privacy Policy).
Right of access: you can request a copy of your data.
Right of rectification: if the data held is inaccurate, you have the right to have it corrected.
Right to erasure: you have the right to have your data deleted in certain circumstances.
Right to restrict processing: in limited circumstances, you have the right to request that processing is stopped but the data retained.
Right to data portability: you can request a copy of certain data in a machine-readable form that can be transferred to another provider.
Right to object: in certain circumstances (including where data is processed on the basis of legitimate interests or for the purposes of marketing) you may object to that processing.
Rights related to automated decision-making including profiling: there are several rights in this area where processing carried out on a solely automated basis results in a decision which has legal or significant effects for the individual. In these circumstances your rights include the right to ensure that there is human intervention in the decision-making process.

The particular rights which are applicable to you (which might include other rights not listed above) may vary depending on your country. You should make yourself aware of the rights you have under applicable privacy laws in your country.

To exercise any of these rights, contact us at support@justthen.app. To delete your account and data, see our Data Deletion page.

10. Child Safety Commitment

At JustThen, ensuring the safety of children is our highest priority. We strictly prohibit any form of child sexual abuse and exploitation (CSAE) on our platform. Below are the key measures we have implemented to comply with child safety standards and ensure the security of our users:

1. Strict Age Policy

JustThen is a platform exclusively for individuals aged 18 years and older. We verify the age of users during the registration process to prevent underage access.

2. CSAE Reporting and Action

If any content related to CSAE is detected or reported, JustThen will take immediate action, including:

Removing the reported content promptly.
Terminating accounts involved in such activities.
Reporting the incident to the relevant law enforcement authorities.

Our team monitors the platform actively to detect and address such violations, ensuring a safe environment for all users.

3. Published Standards

All users are required to adhere to JustThen’s Child Safety Standards. Violations, such as sharing harmful content or engaging in inappropriate behavior, will lead to account suspension or termination.

4. In-App Reporting Tools

We have provided multiple ways for users to report inappropriate content or behavior directly within the app:

Use the “Report” button available on profiles or messages.
Submit a concern through the in-app Feedback Form.
Contact us via email at support@justthen.app.

Our support team reviews all reports and takes appropriate action promptly.

5. Data Retention for Safety

Reports related to CSAE or other violations are securely retained for a minimum of six years to assist with investigations and legal compliance.

6. Compliance with Child Safety Laws

JustThen complies with global child safety laws and follows the guidelines established by the Tech Coalition’s Child Safety Standards. Our policies are designed to protect children and create a safer community for all users.

If you have concerns about child safety or need assistance, please contact us at support@justthen.app.

11. Data Retention and Deletion

We keep your personal information only as long as we need it for the legal basis relied upon (as set out in Section 2 above) and as permitted by applicable law. Please see “Profile Verification Information (Including Biometric Information)” in Section 1, above, to learn about our retention policy with respect to biometric information.

When you delete your Account, or it is deactivated by us, we make sure it is no longer viewable in the App. For up to 28 days, it is still possible to restore your Account if it was accidentally deleted or wrongfully deactivated. After 28 days, we begin the process of deleting your personal information from our systems, unless:

we must keep it to comply with applicable law (for instance, if you make purchases within the App, some personal data may be kept for tax and accounting purposes);
we must keep it to evidence our compliance with applicable law (for example, if an account is blocked, we keep some account information and a record of the behaviour that led to the block — this information is retained for evidential purposes in case of queries or legal claims concerning the block);
there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or
the information must be kept for our legitimate business interests, such as fraud prevention and enhancing Users’ safety and security (for example, information may need to be kept to prevent a user who was banned for unsafe behaviour or security incidents from opening a new account).

For step-by-step instructions on deleting your account and data, please see our Data Deletion page.

Warning: Even after you remove information from your profile or delete your Account, copies of that information may still be viewable and/or accessed to the extent such information has been previously shared with others, or copied or stored by others. We cannot control this, nor do we accept any liability for this. If you have given third party applications or websites access to your personal information, they may retain such information to the extent permitted under their terms of service or privacy policies.

Thanks for reading, we hope we didn’t drone on for too long!

12. Changes to This Policy

As JustThen evolves, we may revise this Privacy Policy from time to time. The most current version of the policy will govern our use of your information and will always be available at justthen.app/privacy.html. If we make a change to this policy that, in our sole discretion, is material, we will notify you, for example, via an email to the email associated with your Account or by posting a notice within JustThen.