Privacy Policy

1. Introduction

At Lureva ("we," "our," or "us"), we take your privacy seriously. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you use our premium matchmaking services.

This Privacy Policy complies with:

• Canada's Personal Information Protection and Electronic Documents Act (PIPEDA)
• The California Consumer Privacy Act (CCPA)
• The General Data Protection Regulation (GDPR) for European users
• Other applicable data protection laws

2. Information We Collect

2.1 Information You Provide Directly

When you submit an application or use our Services, we collect:

• Personal Information: Full name, year of birth, gender, sexual orientation, email address, phone number
• Relationship Information: Relationship status, relationship goals, dealbreakers, partner preferences
• Personal Characteristics: Religion, genotype (optional), children status
• Citizenship & Location: Citizenship status, location information
• Professional Information: Employment status, industry, job role, salary range
• Availability: Preferred dates and times for meetings
• Documents: Government-issued ID, Vulnerable Sector Check or equivalent background screening
• Psychological Evaluation: Results and notes from licensed therapist consultations
• Communication Data: Video interview recordings, notes, feedback, and correspondence

2.2 Information We Collect Automatically

When you access our website or services, we automatically collect:

• IP address and device information
• Browser type and version
• Operating system
• Pages visited and time spent on our website
• Referring website addresses
• Cookies and similar tracking technologies (see Cookie Policy below)

2.3 Information From Third Parties

We may receive information from third-party service providers such as:

• Background check providers
• Banking and payment institutions used for Interac e-Transfer
• Licensed therapists and counselors
• Verification services

3. How We Use Your Information

We use your personal information for the following purposes:

• Matchmaking Services: To evaluate compatibility, create matches, and facilitate introductions
• Verification & Safety: To verify your identity, conduct background checks, and ensure user safety
• Communication: To contact you about your application, matches, appointments, and service updates
• Service Improvement: To analyze and improve our matchmaking algorithms and services
• Payments: To arrange and reconcile Interac e-Transfer payments and prevent fraud
• Legal Compliance: To comply with legal obligations and protect our rights
• Marketing: To send newsletters and promotional content (only with your consent)

4. Legal Basis for Processing (GDPR)

We process your personal data based on the following legal grounds:

• Contractual Necessity: Processing is necessary to provide our matchmaking services
• Consent: You have given explicit consent for processing sensitive data (e.g., sexual orientation, psychological evaluations)
• Legitimate Interests: Processing is necessary for our legitimate business interests (e.g., fraud prevention, service improvement)
• Legal Obligation: Processing is required to comply with applicable laws

5. How We Share Your Information

We do not sell your personal information. We may share your information with:

5.1 Service Providers

• Licensed therapists and psychological evaluators
• Background check providers
• Banking and payment institutions used for Interac e-Transfer
• Cloud hosting providers
• Email service providers, including Resend, which processes our application notifications and newsletter emails on our behalf

5.1a Newsletter and Email Consent Records

If you subscribe to our newsletter, we record your email address, the date and time of your consent, the page you subscribed from, and the version of the consent wording you agreed to. We use a confirmation link (valid for 48 hours) to verify that the address is yours; unconfirmed subscriptions are not emailed further and are removed. Confirmed subscribers are stored with our email provider so newsletters can be delivered. Every newsletter contains an unsubscribe link, and unsubscribing takes effect immediately. Consent and unsubscribe records are retained only as long as needed to prove compliance with Canadian anti-spam and comparable privacy laws.

5.2 Potential Matches

With your consent, we share limited information with potential matches to facilitate introductions. We do not share photos until you meet in person.

5.3 Legal Requirements

We may disclose your information if required by law, court order, or to protect our rights and safety.

6. Data Security

We implement industry-standard security measures to protect your personal information:

• Encryption: All data is encrypted in transit (SSL/TLS) and at rest
• Access Controls: Only authorized personnel have access to personal data
• Secure Storage: Documents are stored on secure, encrypted servers
• Regular Audits: We conduct regular security audits and assessments
• Employee Training: All staff are trained on data protection and privacy
• Incident Response: We have procedures in place to respond to data breaches

7. Data Retention

Automatic Deletion Policy:

Active Users: For active clients using our matchmaking services, we retain your data for the duration of your membership plus 90 days after termination.

Legal Requirements: Some data may be retained longer if required by law or for legitimate business purposes (e.g., financial records for tax purposes).

8. Your Privacy Rights

Depending on your location, you have the following rights:

8.1 Right to Access

You can request a copy of all personal data we hold about you.

8.2 Right to Rectification

You can request correction of inaccurate or incomplete data.

8.3 Right to Erasure (Right to be Forgotten)

You can request deletion of your personal data. Note: We may be required to retain certain information for legal or legitimate business purposes.

8.4 Right to Data Portability

You can request your data in a structured, machine-readable format to transfer to another service.

8.5 Right to Object

You can object to processing based on legitimate interests or for marketing purposes.

8.6 Right to Withdraw Consent

You can withdraw consent at any time where processing is based on consent.

8.7 CCPA Rights (California Residents)

• Right to know what personal information is collected
• Right to know if personal information is sold or disclosed
• Right to say no to the sale of personal information (we do not sell data)
• Right to access your personal information
• Right to equal service and price

9. Cookie Policy

We use cookies and similar tracking technologies to enhance your experience on our website.

9.1 What We Store and Measure

• Essential storage: Required for the website to function (e.g., session management, security, and remembering your measurement choice)
• Website measurement (only with your consent): We record anonymous activity on our own systems — the event name (such as an application being started or submitted), the page address, the website that referred you, campaign parameters in the link you followed, and a random identifier that lasts only for your visit

Our measurement is first-party: it is not shared with advertising networks, and we do not use advertising or cross-site tracking technologies. Application answers, names, contact details, uploaded documents, and free-text responses are never included in measurement records.

9.2 Your Choice

When you first visit our website you will see a banner asking whether we may measure anonymous activity. You can choose:

• Accept: Allow anonymous website measurement as described above
• Decline: Nothing is measured; only storage essential to the website is used

We also honour the "Do Not Track" setting in your browser: when it is enabled, nothing is measured even if consent was previously given. You can clear your browser storage at any time to be asked again.

10. Children's Privacy

Our Services are not intended for individuals under 20 years of age. We do not knowingly collect personal information from anyone under 20. If we learn that we have collected data from someone under 20, we will delete it immediately.

11. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence. We ensure appropriate safeguards are in place to protect your data in accordance with this Privacy Policy and applicable data protection laws.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by email or through our website. The "Last Updated" date at the top of this policy reflects when it was last modified.

13. How to Exercise Your Rights

To exercise any of your privacy rights, please contact us:

We will respond to your request within 30 days (or as required by applicable law). We may need to verify your identity before processing your request.

14. Data Protection Officer

If you have questions or concerns about how we handle your personal data, you can contact our Data Protection Officer at: hi@lureva.ca

15. Right to Lodge a Complaint

If you believe we have not handled your personal data properly, you have the right to lodge a complaint with a supervisory authority:

• Canada: Office of the Privacy Commissioner of Canada (www.priv.gc.ca)
• California: California Attorney General (oag.ca.gov)
• EU: Your local Data Protection Authority