LEGAL
Privacy Policy
Last updated: April 11, 2026
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Cupler Limited Company number: 16384230 Registered address: 3 Lower Park Crescent, Poynton, Stockport, England, SK12 1EF Contact: support@cupler.co.uk
1. Introduction
Cupler Limited ("we", "us", "our") is committed to protecting your personal data. This Privacy Policy explains how we collect, use, store, and share your information when you use:
Our website at cupler.co.uk ("the Website") The Cupler mobile application available on iOS and Android ("the App")
Please read this policy carefully. By using either the Website or the App, you confirm that you have read and understood how we handle your personal data.
If you have any questions, contact us at support@cupler.co.uk.
2. Who We Are
Cupler Limited is the data controller for all personal data collected through the Website and the App. We are registered in England and Wales under company number 16384230.
We are subject to the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. All data protection queries should be directed to support@cupler.co.uk.
3. Website — What We Collect and Why
When you visit cupler.co.uk, we collect limited data to understand how the site is being used and to improve your experience. We do not require you to create an account to browse the Website.
3.1 Analytics Data (with your consent)
If you accept analytics cookies, we collect the following via Google Analytics 4:
Pages visited and time spent on each page Approximate location (city and region level — not precise GPS) Device type, browser type, and operating system Traffic source (e.g. Google Search, direct visit, social media)
This data is anonymised and aggregated. It does not identify you personally. We use it solely to understand audience interest and improve the Website.
Lawful basis: Consent (UK GDPR Article 6(1)(a))
3.2 Newsletter Sign-Up
If you choose to sign up for updates or a newsletter, we collect your email address solely to send you the communications you requested.
Lawful basis: Consent (UK GDPR Article 6(1)(a))
You can unsubscribe at any time by clicking the link in any email we send or by emailing support@cupler.co.uk.
3.3 Contact and Support Enquiries
If you contact us via email or a contact form, we collect your name, email address, and the contents of your message to respond to your enquiry.
Lawful basis: Legitimate interests (UK GDPR Article 6(1)(f))
3.4 What We Do Not Collect on the Website
We do not collect precise GPS or location data We do not use advertising or remarketing cookies We do not collect payment information We do not sell or share your data with third parties for their own marketing purposes
For full details of cookies used on the Website, please see our Cookie Policy at cupler.co.uk/cookie-policy.
4. App — What We Collect and Why
4.1 Account Registration
To use the App, each partner must create an individual personal account. Two personal accounts are then linked together using a unique couple ID to form one joint couple profile. We collect:
First name Email address Date of birth (to verify you are 18 or over) Password (stored in encrypted form — we never see your plain-text password)
Lawful basis: Contract (UK GDPR Article 6(1)(b))
4.2 Couple Profile
Once linked, you and your partner build a shared couple profile. We collect:
Profile photos uploaded by you Shared interests and activity preferences selected by you Any bio or profile text you choose to add
Lawful basis: Contract (UK GDPR Article 6(1)(b))
4.3 Location Data
To power the distance filter and show you relevant couples nearby, the App collects your location when the App is open and in use (foreground only), provided you grant location permission on your device. We do not track your location in the background when the App is closed.
Your approximate location is used to calculate distances between couples and surface relevant matches. We do not store a continuous log of your movements.
Lawful basis: Consent (UK GDPR Article 6(1)(a)) — you can withdraw location permission at any time via your device settings. Withdrawing permission will limit the App's matching functionality.
4.4 In-App Communications
All messaging within the App takes place in a 4-way group chat that includes both partners from both matched couples. There are no private one-to-one messages. Chat content may be reviewed by Cupler if reported for misconduct, nudity, or inappropriate content.
Lawful basis: Contract and legitimate interests (UK GDPR Article 6(1)(b) and 6(1)(f))
4.5 Reported Content
If content is reported by a user, we may retain that content for the purposes of investigating the report, taking action, and preventing future harm. This may include photos or messages from the reported account.
Lawful basis: Legitimate interests (UK GDPR Article 6(1)(f))
4.6 Usage and Technical Data
We collect technical data to keep the App running smoothly, including:
Device type and operating system App version Crash reports and error logs Feature usage patterns (anonymised)
Lawful basis: Legitimate interests (UK GDPR Article 6(1)(f))
4.7 Push Notifications
If you grant permission, we may send you push notifications relating to matches, messages, and App updates. You can withdraw this permission at any time via your device settings.
Lawful basis: Consent (UK GDPR Article 6(1)(a))
4.8 Future Services
As the App grows, we may introduce additional features such as in-app payments, premium subscriptions, or third-party integrations. Where these involve new data collection, we will update this policy and, where required, seek your consent before processing begins.
5. How We Share Your Data
We do not sell your personal data. We share data only in the following circumstances:
Matched couples — your couple profile (photos, interests, profile text, and approximate distance) is shown to other couples as part of the matching process. This is the core function of the service.
Service providers — we work with trusted third-party providers who process data on our behalf to help us operate the Website and App. These providers are contractually bound to process data only on our instructions and in accordance with UK GDPR.
Legal requirements — we may disclose your data to law enforcement or regulatory authorities where required by law or where necessary to protect the safety of our users or the public.
Business transfers — in the event of a merger, acquisition, or sale of assets, your data may be transferred to the new entity. We will notify you in advance if this occurs.
Sponsors and partners (future) — we may in the future share non-personally identifiable, aggregated data with trusted commercial partners for sponsorship or marketing purposes. We will never share your private contact information with third parties for their own marketing without your explicit consent. We will update this policy before any such sharing begins.
6. Data Retention
Website analytics data — as configured in GA4 (minimum 2 months) Newsletter email address — until you unsubscribe Support and contact enquiries — 12 months from last contact App account data — for the duration of your account, plus 30 days following deletion request Location data — not stored beyond the active session Reported content — up to 12 months following resolution of the report Crash and error logs — 90 days
When you request account deletion, all personal data will be removed from our active systems within 30 days. Some data may be retained for longer where required by law or for legitimate safety purposes.
7. Your Rights
Under UK GDPR, you have the following rights:
Right of access — you can request a copy of the personal data we hold about you Right to rectification — you can ask us to correct inaccurate data Right to erasure — you can ask us to delete your data (subject to legal obligations) Right to restrict processing — you can ask us to limit how we use your data Right to data portability — you can request your data in a machine-readable format Right to object — you can object to processing based on legitimate interests Right to withdraw consent — where processing is based on consent, you can withdraw it at any time without affecting the lawfulness of prior processing
To exercise any of these rights, contact us at support@cupler.co.uk. We will respond within one month.
8. International Data Transfers
Google Analytics data may be processed in the United States. Google LLC is certified under the UK Extension to the EU–US Data Privacy Framework, which provides appropriate safeguards for international transfers.
Where we use other third-party providers that process data outside the UK, we ensure appropriate transfer mechanisms are in place in accordance with UK GDPR.
9. Children
The App and Website are intended for users aged 18 and over. We do not knowingly collect personal data from anyone under 18. If you believe a person under 18 has provided us with their data, please contact us at support@cupler.co.uk and we will delete it promptly.
10. Security
We use industry-standard measures including encryption of passwords, secure data transmission (HTTPS), and access controls to protect your personal data. However, no method of transmission over the internet is completely secure and we cannot guarantee absolute security.
11. Changes to This Policy
We may update this Privacy Policy from time to time. When we do, we will update the date at the top of this page. For significant changes, we will notify you via the App or by email where appropriate.
11. Contact and Complaints
Cupler Limited 3 Lower Park Crescent, Poynton, Stockport, England, SK12 1EF Email: support@cupler.co.uk
You also have the right to lodge a complaint with the Information Commissioner's Office (ICO): Website: ico.org.uk Phone: 0303 123 1113