Privacy Policy

Effective Date: [●], 2026 · Version: v1

Introduction

Psycura Inc. ("Psycura", “Psycura.ca”, "we," "us," or "our") a Canadian corporation, is deeply committed to safeguarding your privacy and protecting your personal information. This Privacy Policy (the "Policy") details how we collect, use, disclose, store, process, and protect your information when you access and use our services, website, and applications (collectively referred to as the "Services" or "Platform").

By accessing or using our Services, you signify that you have read, understood, and agree to the terms outlined in this Privacy Policy. This Policy is incorporated by reference into our Terms of Use and forms an integral and legally binding part of your agreement with Psycura.

1. Information We Collect

We collect information to provide, improve, and secure our Services. We collect only the information reasonably necessary to provide compatibility-based matching and safety features. The types of information we collect fall into three main categories:

1.1. Information You Provide:

This includes personal data you actively submit to us during your interactions with our Services:

Account Details:

Profile Information:

Preferences and Compatibility Data:

Sensitive Personal Information:

About sensitive data for matching: We require ethnicity, political leaning, religion/faith, and sexual orientation information to provide our service safely and effectively. Psycura is fundamentally a compatibility matching service—we cannot produce safe, compatible matches without understanding these core dimensions of who you are and who you're looking for. Ethnicity, political leaning, and religion are sensitive personal information under PIPEDA and are used as Layer 1 hard filters — they directly determine which users appear in your matchable pool. While this information is required for the compatibility-based nature of our Service, in jurisdictions where sensitive data protections apply, we rely on your explicit consent to process it. If you choose not to provide or later withdraw consent, we may be unable to provide the Service.

About religion specifically: We collect your broad religious identity (mandatory) and your denomination or tradition within that religion (mandatory for self-identification where applicable; each denomination list includes "Non-denominational / No specific tradition" so no one is forced into a box that doesn't fit). If you choose to filter matches by specific denominations, this may significantly reduce the number of potential matches available to you. You may also provide a free-text description of your beliefs, which is shown to your matches for context but is not used by the matching algorithm.

Personality & Psychological Profile

Payment Information:

Credit card details, billing address, or other payment methods for subscriptions, purchases, or transactions. This data is primarily processed by secure third-party payment processors, and we do not store full payment card numbers on our servers.

Refund Requests and Billing Support:

You may request billing support, including refund consideration where permitted under our Terms of Use or applicable law, through Psycura’s in-app customer support tool or by emailing support@psycura.ca. We may process information you provide in that request, including account identifiers, payment-related records, support conversation content, and the reason for your request, to verify your identity, evaluate the request, comply with legal obligations, prevent fraud, and maintain records of our decision. Submitting a request through the in-app customer support tool does not expand any refund right beyond what is provided in the Terms of Use or applicable law.

Communications:

Behavioral Data

Self Reflection Data:

If you use our Self-Reflection feature (available after certain moderation actions), we collect your written responses during reflection sessions and engagement indicators such as time spent, depth of reflection.

1.2. Information We Collect Automatically

When you access or use our Services, certain information is automatically collected through technology:

• Device Information: Details about the devices you use to access our Services, including IP addresses, browser types and versions, operating systems, device identifiers, mobile network information, and crash data. This helps us optimize our services for various devices and troubleshoot issues.
• Usage Data: Information on how you interact with our Services, such as pages visited, features utilized, time spent on the platform, clickstream data, search queries, and interactions with other users' profiles or content. This data helps us understand user engagement and improve platform functionality.
• Location Data: Approximate location based on your device's IP address. If you enable location services on your device or within the app, we may collect more precise geolocation data to offer location-based features (e.g., finding nearby users). You can disable location services through your device settings at any time.

Cookies and Tracking Technologies: Information collected through cookies, web beacons, pixels, local storage, device identifiers, and other tracking technologies. This includes data such as session IDs, language preferences, login status, and user behavior patterns.

1.3. Information You Provide to Us:

Includes all information you provide for publication or display on public areas of Platform such as photos, messages etc..

1.4. Information from Third Parties

We may receive information about you from other sources, including:

• Social Media Platforms: Data obtained if you link your Psycura account to platforms like Facebook, Apple, Google, or any other social media platform. The information we receive depends on your privacy settings on those platforms.
• Publicly Available Sources: Information that is publicly accessible, such as profiles on social networking sites or public records, where permitted by law.
• Other Users: Other users may provide information about you in their communications or reports of misconduct.

When you use Psycura Services, certain third parties that help Psycura provide the Services collect information about your or your device. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, apps and other online services.

2. How We Use Your Information (Purposes and Lawful Bases)

We use your information to provide, maintain, enhance, and secure our Services, and for other legitimate business purposes. Our legal bases for processing personal data, include:

We can use the information that we collect for the following purposes, including:

• The purposes for which you provided it (e.g. to match you with compatible partners and friends);
• To provide or to facilitate providing you with the Services, including disclosure of any relevant information to facilitate the Services to you;
• To provide the Platform to you, including any notifications or updates relating to the Platform;
• To respond to your inquiries and comments (for example, regarding support or other requests);
• To send you information about your relationship with us;
• To notify you about changes to the Platform, our policies, terms or any products or services we offer or provide though it;
• To improve the Platform or to develop new Services;
• To identify you as a user of the Platform;
• To customize our marketing;
• For testing, research, analysis and product and service development that we or a third party can perform regarding the Platform.
• To create anonymous data or de-identified data, which we may use strictly for internal purposes and share with third parties in accordance with Section 8.3;
• To aggregate data, which we or a third party can compile, and which we or a third party can do and can use in accordance with Section 8.3;
• To analyze how you use the Platform and to analyze the Platform, which we or a third party can do;
• To allow us to personalize and enhance your experience using the Platform;
• To contact you via telephone, email, text message, Platform notifications, or any other electronic communication;
• To allow you to participate in interactive features on our Platform;
• To carry out our obligations and enforce our rights arising from any agreements entered into between you and us;
• To investigate, and deter against fraudulent, unauthorized, or illegal activity and otherwise protect our users;
• To administer and troubleshoot the Platform;
• Conduct safety and abuse prevention audits;
• As otherwise stated in this Policy.

Legal Basis:

In jurisdictions where a legal basis for processing is required (such as under the European Union's General Data Protection Regulation or the UK GDPR), our legal basis will generally be one or more of the following:

• Your consent;
• The performance of a Services for you;
• Compliance with a legal obligation;
• Protection of safety (imminent harm situations); or
• Our legitimate interests, including to operate, improve, and market our services, provided such interests are not overridden by your fundamental rights and freedoms. Where we rely on legitimate interests, those interests include operating and securing the Platform, preventing fraud and abuse, improving matching quality, defending legal claims, and ensuring user safety. We assess these interests against potential risks to individuals and implement safeguards to minimize impact.

Consent:

For certain services, features, or data processing activities (e.g., non-essential cookies, specific marketing communications, or processing of sensitive personal information), where required by law. Where consent is the legal basis, you may withdraw your consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.

Processing of Sensitive (Special Category) Data:

Certain information we collect (such as religion, ethnic origin, political opinions, and sexual orientation) may be considered sensitive or special category data under applicable law. Where required by law (including in the European Union and United Kingdom), we process such information based on your explicit consent. You may withdraw this consent at any time. However, because this information is central to our compatibility-based matching model, withdrawing consent may limit or prevent your ability to use certain features of the Service.

Use of AI Technologies:

Psycura employs artificial intelligence (AI) and automated systems across its platform to enhance functionality, improve user experience, and protect community integrity. These systems are used for:

• Matchmaking and User Recommendations: To suggest connections based on your profile, preferences, and interactions.
• Automated Content Moderation and Flagging: To identify and flag content that violates our Terms of Use or Community Guidelines (e.g., inappropriate images, hate speech).
• Spam and Fraud Detection: To identify and prevent fraudulent activities, spam, and other prohibited conduct.
• Platform Optimization and Quality Assurance: To analyze user behavior and system performance to continuously improve our Services.
• Internal Test or Verification Accounts: To deploy non-user system or test accounts generated or managed by automated systems for internal use only (e.g., for monitoring purposes, quality control). These are not real users and are not intended for relationship-building. We make efforts to prevent and minimize user-facing interaction with these accounts.
• Automated Decision-Making: Psycura uses automated systems to suggest compatible matches. This is core to our service—our matching algorithm analyzes your profile, preferences, and ConnectionSignature to identify potential partners. Matching decisions are made by our algorithm, not by humans manually reviewing profiles. The algorithm considers factors including preferences, personality compatibility, communication style, and past match outcomes. No single factor determines a match; the algorithm weighs multiple signals.

Psycura ensures that the deployment of AI systems respects data protection and fairness principles, is continuously monitored for bias, discrimination, or misuse, and is subject to oversight and escalation procedures when risk is detected.

3. Sharing Your Information

We do not sell or share your personal data for monetary or other valuable consideration. Ever. This includes anonymized or aggregate data derived from your use of Psycura. We may share your data in the following circumstances and for the purposes outlined below:

3.1. With Your Consent:

We share content with AI providers to power matching, safety detection, signal extraction, photo moderation, and other automated features. AI providers receive interview responses, chat content, reflection content, support conversations, retention assessments, and photos for moderation purposes. Identifying user IDs are not transmitted alongside this content. No data is shared for advertising purposes. Beyond AI providers and operational service providers, content is reviewed only by staff for moderation, policy enforcement, or legal-process purposes.

3.2. With Service Providers (Third-Party Data Processors):

We engage trusted third-party service providers to support various aspects of our operations. These include, but are not limited to, vendors assisting in:

These partners are contractually bound to handle personal data solely on Psycura’s behalf, in accordance with our instructions, and in compliance with applicable privacy and data protection laws. All such processors are required to:

• Process personal data only for specified, legitimate purposes.
• Implement adequate technical and organizational safeguards.
• Notify Psycura of any data breach or security incident without undue delay.
• Not sell or use your data for their own independent purposes.

3.3. With other Users:

Before both users complete the post-date check-in: When you're matched, your match can see limited information about you:

First name, age, gender, approximate distance, relationship goals, and the relationship style they are seeking.

This gives enough context for meaningful conversation without revealing your full profile.

After both users complete the post-date check-in: Once you've both met in person and completed the check-in, your match can see:

• Your photos
• Your full bio/description
• Detailed profile information
• Information you choose to share in messages

4. International Data Transfers and Data Hosting

Your personal data may be stored, processed, and transferred to countries outside your country of residence. Please be aware that some of these countries may not offer the same level of data protection as your home country. Psycura currently stores its primary application data in Toronto, Ontario Canada, while certain service providers, including our transactional email provider, may process limited personal data in the United States or other countries.

By using the Psycura platform, you understand and explicitly consent to the transfer, storage, and processing of your personal data to countries outside of your country of residence, which may have data protection rules that are different from those of your country. However, where required by applicable law, we rely on appropriate safeguards, such as contractual clauses or equivalent mechanisms, to protect international data transfers.

5. How we can Disclose your Information

We can disclose information to third parties in accordance with this Policy:

5.1. Third Parties:

We can use third parties or service providers to perform functions in connection with the Platform (for example, providing products or services, data analysis, enhancing the information collected from or about you, etc.). We can use third parties or service providers to perform any of the actions or activities allowed under this Policy. We can share information about you that they need to perform their functions and in accordance with our agreements with them.

5.2. Subsidiaries and Affiliates:

We can also share your information with any subsidiary or affiliate of ours for purposes consistent with this Policy. Any subsidiary or affiliate of ours will be required to maintain that information in accordance with this Policy.

5.3. Business Change:

If we become involved in a merger, acquisition, sale of assets, divestiture, joint venture, securities offering, financing, bankruptcy, reorganization, liquidation, dissolution, or other transaction or if the ownership of all or substantially all of our business otherwise changes, we can share or transfer your information to a third party or parties in connection therewith and it can be used subsequently by such third party or parties.

5.4. Investigations and Law

Regardless of any choices you make regarding your information (as described below) and to the extent permitted by applicable law, we can disclose information about you to third parties to:

• Comply with law, in response to subpoenas, warrants, or court orders, or in connection with any law or legal process or cooperate with government or law enforcement officials or private parties;
• Protect our rights, reputation, safety and property or in an emergency, or that of our users or others;
• To resolve disputes;
• Protect against legal liability;
• Establish or exercise our rights to defend against legal claims; or
• To investigate, prevent or take action regarding suspected illegal activities, suspected fraud, the rights, reputation, safety or property of us, users or others, our policies or agreements or as otherwise required by law.

5.5. Website Analysis:

We or a third party can analyze how you use the Platform and can analyze the Platform.

5.6. At Your Request:

We can share your information with any other individual or third party or service provider at your request.

5.7. With Your Consent:

We can share your information other than as described in this Policy if we notify you and you consent to the sharing thereof.

5.8. For Any Other Purpose Disclosed by Us:

For any other purpose we describe to you.

5.9. Third Party Payment Processor:

We use third-party payment processors to process payments securely on our behalf. These processors may collect and store payment information and are responsible for ensuring the security and confidentiality of such information. We encourage you to review our payment processor’s privacy policy for details on their data practices. We do not store your full payment card information on our servers.

6. Data Security and Breach Notification

Psycura endeavors to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to prevent your personal information from loss and unauthorized access, collection, use, disclosure, copying, modification, disposal or destruction. While we take reasonable administrative, technical and physical measures to protect the information you submit via the Platform help protect the information you submit via the Platform from accidental or unlawful destruction, loss or alteration and from unauthorized access, use, or disclosure, we cannot guarantee its absolute security. No Internet or electronic communication transmission is ever fully secure or error free. Internet or electronic communications, including those sent through the Platform, may not be secure. Unfortunately, we cannot guarantee complete security: for example, (i) unauthorized access use, or disclosure, (ii) hardware or software failure, and (iii) other events may compromise the security of your personal information at any time. You should use caution whenever submitting information through the Platform and take special care in deciding which information you provide us with. Personal information collected by Psycura is primarily stored or processed in Canada, but may also be processed in the United States or other jurisdictions by service providers acting on our behalf, including our transactional email provider. While located in these jurisdictions, your information may be accessible to law enforcement and regulatory authorities in accordance with the laws of those jurisdictions. We take reasonable measures to ensure that any such transfers comply with applicable privacy legislation and agree and acknowledge that your personal information may be stored or viewed by Psycura and other authorized parties outside of Canada.

6.1. User Responsibilities for Data Security:

As a user of the Platform, you also play a crucial role in protecting your data. You agree to:

• Keep your login credentials (username and password) confidential and secure.
• Avoid sharing your account with others.
• Notify Psycura immediately at security@psycura.ca of any unauthorized use of your account or suspected security breach.

You are responsible for any activity conducted under your account unless it is proven to result from a Psycura system compromise.

6.2. Data Breach Notification:

In the unfortunate event of a data breach that compromises the confidentiality, integrity, or availability of your personal information, Psycura will notify affected users and, where required, relevant regulatory authorities in accordance with applicable data protection laws.

Notifications may be delivered via email, in-app message, or other appropriate means, and will include relevant details about: the nature and scope of the breach; what data was affected; the steps we are taking to mitigate harm; what actions you can take to protect yourself; and how to contact us for more information.

7. Data Retention

Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances we may anonymize or aggregate your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate internal operations and Service improvement purposes without further notice to you or your consent. Retention decisions are based on the sensitivity of the information, the purposes for which it was collected, applicable legal limitation periods, and safety considerations. We periodically review retained information to assess whether continued storage remains necessary for the stated purposes.

8. Cookies and Tracking Technologies

Psycura uses cookies, web beacons, pixels, local storage, device identifiers, and other tracking technologies to enhance platform functionality, improve user experience, analyze user behavior, enhance security, personalize your experience, and detect and prevent fraud. These technologies may collect data such as device type, browser settings, user interactions, and session behavior. We may also use third-party tools, such as analytics or advertising services, in accordance with this Policy.

By using the Psycura platform, you consent to the use of these technologies as described in this Policy, except where explicit consent is required by law. In jurisdictions where required (e.g., the European Union, United Kingdom, Canada, Brazil, and California), users will be presented with a cookie consent banner and given the option to accept or manage their preferences before non-essential cookies are activated.

8.1. Types of Cookies and Technologies We Use:

8.2. Managing Your Cookie Preferences:

You can modify or withdraw your cookie consent at any time by:

• Clicking on the “Cookie Settings” link available on our website or within the app (if applicable).
• Adjusting your browser settings to block or delete cookies.

We request your consent for non-essential cookies (analytics) when you first use Psycura. You can change your cookie preferences at any time in your account settings. Essential cookies cannot be disabled as they are required for the service to function. Please note that disabling cookies may affect the functionality and performance of our Services.

8.3. Analytics:

We use analytics to understand how Psycura is used—what features work, where people get stuck, how to improve. We track:

• Page views and feature usage
• Onboarding completion rates
• Aggregate outcome correlations (what predicts successful matches)

What we don't track:

• Individual surveillance profiles
• Data for advertising
• Anything that identifies you personally in analytics

Our analytics are pseudonymous. We use hashed identifiers that can't be linked back to your profile. We care about patterns across all users, not watching any individual. We may use third-party analytics tools (e.g., for error tracking, performance monitoring). These tools receive only anonymized or pseudonymized data and are prohibited from using it for their own purposes.

9. Children's Privacy

Psycura is not intended for use by children or minors. We do not currently use government ID verification, AI-based age estimation, or other third-party software to ensure users are of legal age. Our Services are strictly prohibited for anyone under the age of 18. By using our Services, you represent that you are at least 18 years old.

If you believe a minor is using the Platform in violation of these terms, or if you become aware that your child has provided us with personal data, please report it to us immediately at privacy@psycura.ca. We will promptly delete such information and take additional steps as required by applicable laws.

10. Accessing and Correcting Your Personal Information

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes. By law you have the right to request access to and to correct the personal information that we hold about you.

You can review and change your personal information by logging into the Platform and visiting your account profile page.

If you want to review, verify, correct, or withdraw consent to the use of your personal information you may also send us an email at privacy@psycura.ca to request access to, correct, or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

If you are concerned about our response or would like to correct the information provided, you may contact our Privacy Officer at privacy@psycura.ca.

If you delete your user account on the Platform, copies of your account may remain viewable in cached and archived pages or might have been copied or stored by other Platform users.

11. Withdrawing your Consent

Where you have provided your consent to the collection, use, and transfer of your personal information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us at privacy@psycura.ca. Please note that if you withdraw your consent, we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you make your decision.

12. Data Deletion

When you request account deletion, your profile is immediately removed from the matching pool. Your account is marked for deletion and enters a 30-day grace period during which you can recover the account if you change your mind. Active matches continue during this grace period so that recovery preserves your match. After the grace period expires, your data is deleted including active match relationships, and the deletion becomes irreversible.

Limited retained information may remain only to:

• Comply with legal obligations;
• Enforce our Terms of Use;
• Investigate and resolve dispute;
• Detect, prevent, or address fraud, abuse, harassment, or security incidents; and
• Prevent ban evasion or repeat misconduct.

What may not be deleted is such retained information such as:

• Account identifiers;
• Device or network information;
• User reports and investigation and consent records;
• Communication associated with reported conduct or legal disputes; and
• Any data required to be held under applicable law.

13. Shared Communications

Communications on Psycura involve more than one participant. If a communication is reasonably required for safety, legal, compliance, or dispute resolution purposes relating to another user’s account or an active investigation, we may retain that information in accordance with this Policy.

14. Links to Other Websites

This Policy applies only to the Platform. The Platform may contain links to other websites to which this Policy does not apply. The links from the Platform do not imply that we endorse or have reviewed these websites. The policies and procedures we describe here do not apply to these websites. We can neither control nor are responsible for the privacy practices or content of these websites. We suggest reviewing the privacy policies of these websites.

15. Updates to This Policy

We may update this Privacy Policy periodically to reflect changes in our data practices, applicable laws, or technological advancements. Material changes will be posted on our website with a revised effective date. Where required by applicable law, Psycura will provide advance notice of material changes to this Privacy Policy.

Your continued use of our Services after changes are posted and notice periods (if applicable) have elapsed constitutes your acceptance of the updated policy. If you do not agree with the revised Policy, you must stop using the platform and may request account closure.

16. Contact Us

For any questions, concerns, or requests regarding this Privacy Policy, your personal data, or to exercise your privacy rights, please contact us at:

Email: privacy@psycura.ca

We aim to respond to all inquiries within 5 business days. Privacy rights requests (access, deletion, etc.) are handled within 30 days as required by law.

We are committed to resolving any concerns you may have regarding your privacy and our data practices.