Privacy Policy

Effective date: October 24, 2026

This Privacy Policy explains what personal information To Be Parents collects, why, and how you can control it. It applies to our website (tobeparents.com), our mobile applications for iOS and Android, our partner portal (partner.tobeparents.com) and the TBP Partner app, and our admin portal (the "Services").

1. Who we are

To Be Parents is operated by HYPERFOCUS TECH INC. (United States). For users in the European Economic Area, the United Kingdom, or Switzerland, we act as the data controller for the information described in this Policy. For California residents, we are the "business" that collects your personal information under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA). To reach us about any privacy matter, use our contact form.

2. What we collect

We collect only the information we need to run the Services:

  • Account: email, hashed password, preferred language, role.
  • Profile: display name, date of birth, city and country, approximate coordinates, physical characteristics, background, lifestyle, and the reproductive and family-formation information you choose to share (for example, user type, willingness to donate or carry, contact preferences). Profile photos and avatar.
  • Communications: chat messages and attachments, likes, matches, profile visits, reports. Voice and video call metadata only; call media is not recorded.
  • Photo verification (free; needed only to send a new like or start a new conversation): the outcome of a verification check (approved or declined) and numeric confidence scores. The selfie, session video, and any biometric information are processed and kept by the verification provider, not by us (see «Face data (photo verification)» below).
  • Device and connection: IP address, coarse location derived from it, device model and operating system, app version, installation identifier, push-notification tokens.
  • Usage: in-app and on-site events such as screens viewed, features used, and actions taken, linked to your account identifier, used to measure and improve the Services.
  • Payments: in-app purchase receipts from the Apple App Store and Google Play. We never see your card details.

Some of the profile information, including health or fertility-related information, religion, or details from which sexual orientation can be inferred, is treated as "special category" data under GDPR / UK GDPR and as "sensitive personal information" under the CPRA. You are never required to provide it; you provide it only to be matched with compatible users, and you can remove it at any time by editing your profile. We do not use or disclose sensitive personal information for any purpose other than operating the Services for you.

Sources of personal information: we collect information (a) directly from you when you register, build your profile, or use the Services; (b) automatically from your device and browser when you access the Services; and (c) from service providers acting on our behalf (for example, the result of an identity-verification check you requested, or a city-to-coordinates lookup when you pick a city).

What happens if you do not provide data: your email and a minimum profile are required to use the Services; without them we cannot create an account for you. Everything else is optional, you can skip it and still use the Services, though some features (such as matching, identity verification, or subscriptions) may not be available.

We use privacy-respecting product-analytics and mobile-attribution providers to measure how the Services are used and to improve them; the events are linked to your account identifier. We do not use session replay, advertising pixels, or cross-site behavioural trackers, we do not sell your data, and we do not use it for cross-context behavioural advertising. On our website these analytics run only with your consent (see the Cookies section below); you can withdraw consent at any time. In the app, if you are in the EEA, the UK or Switzerland, analytics, crash reports and attribution stay off until you choose; elsewhere they are on by default, and you can turn them off at any time in Profile, Privacy settings.

Face data (photo verification)

Photo verification is optional and free. It is needed only to send a new like or start a new conversation, and it is the only feature of the Services that uses face data. It does not use Face ID, the TrueDepth camera or ARKit.

What face data is collected: when you start verification, you record a short video selfie with your camera. Our identity-verification provider, Didit, uses it to check that a live person is in front of the camera (liveness detection) and to compare your face with your main profile photo (face match), which we send to Didit for that comparison. This involves biometric information (facial geometry).

How it is used: solely to confirm that your profile photo shows you and to prevent impersonation and fraud. Face data is never used to sign you in or for any other authentication, to identify you to other members, for advertising, marketing or profiling, or for analytics.

Who receives it and where it is stored: the selfie and session video go from the app directly to Didit, which processes and stores them on its own systems as our data processor, under a data-processing agreement and only on our instructions. Didit may process this data outside the country where you live, under the safeguards described in section 6. To Be Parents never receives or stores your selfie, the session video or any facial geometry, and we discard any face-derived attributes the provider returns (such as an age estimate). Our systems keep only the verification outcome (approved or declined) and numeric confidence scores. We never sell face data and never share it with advertising platforms, analytics providers, data brokers or anyone other than the verification provider.

How long it is kept: Didit retains verification session data, including the selfie and session video, for no longer than 6 months from the verification, after which it is permanently destroyed. Our own verification records (outcome and scores) are kept while your account is active.

How to delete it: you can ask us at any time, via the support chat or our contact form, to delete your verification session, and we will instruct Didit to delete it. If you delete your account, we instruct Didit to delete your verification session as part of the final data erasure, and our own verification records are erased, within 30 days.

Consent and alternatives: verification begins only after you review this disclosure and give your consent on the verification screen. If you prefer not to undergo automated facial verification, contact us via the support chat: a manual review by our team may be available.

3. How we use it

We use your information to create and secure your account, show your profile to other users so you can match, operate chat and calls, send transactional email and push notifications, moderate uploaded photos, verify identity on request, process subscriptions, prevent fraud and abuse, respond to your requests, and comply with law.

4. Legal bases (EEA / UK / Switzerland)

We rely on contract to provide the Services, legitimate interests for security and fraud prevention, legal obligation where required, and explicit consent for optional identity verification and for any special-category information you choose to include in your profile (for example, fertility-related information, religion, or inferences about sexual orientation). You can withdraw that consent at any time by editing or deleting the information, or by deleting your account.

5. Who we share it with

We do not sell your personal information. We share it only with:

  • Other users, your public profile is visible to other logged-in users. Your email, phone, IP, exact coordinates, and payment details are never shown.
  • Service providers acting on our instructions under a data-processing agreement, in the categories of cloud hosting, content delivery and security, automated content moderation, geolocation, identity verification, push notifications, in-app payments, transactional email, and product analytics and mobile attribution. Identity verification is performed by Didit (didit.me) under a data-processing agreement, solely on our instructions. Automated photo moderation is performed by Google Cloud Vision (SafeSearch detection): each photo you upload to your profile is checked for sexually explicit content. This check does not involve face detection, face recognition or any biometric processing; Google does not store the image or use it to train its models, and we keep only the moderation result (approved or rejected). A list of specific providers is available on request via our contact form.
  • Authorities or third parties where required by law, to enforce our Terms, or to protect rights, property, or safety.
  • A successor entity in the event of a merger, acquisition, or asset transfer.

6. International transfers

Our primary servers are located in the United States (New York). If you are in the European Economic Area, the United Kingdom, or Switzerland, using the Services necessarily involves transferring your personal information to the United States, and some of our service providers operate in other countries as well. We rely on the European Commission's Standard Contractual Clauses, the UK International Data Transfer Addendum, and equivalent lawful mechanisms to protect those transfers, together with supplementary technical and organisational measures such as encryption in transit and strict access controls. You may request further information about these safeguards through our contact form.

7. How long we keep it

We keep your data while your account is active. When you delete your account, your profile, photos, and messages are immediately hidden from other users. Within 30 days, all your data is permanently erased from our systems. This includes our verification records (outcome and confidence scores); we also instruct our identity-verification provider to delete your verification session, and in all cases the provider retains verification session data for no longer than 6 months. After 30 days, the email address you used becomes available for a new account, but the new account starts fresh with no history of the previous one. If you believe your account was deleted by mistake within those 30 days, contact us via our contact form and we will assist with manual restoration. Apple Inc. is the merchant of record for in-app purchases on iOS and retains transaction history per their own retention policies. Backups are kept for up to 90 days.

8. Your rights

You can request access to, correction, deletion, or portability of your personal information. You can also restrict or object to our processing, and, where we rely on your consent, withdraw it at any time. To exercise any of these rights, submit a request via our contact form; we will respond within 30 days (or 45 days for California residents, extendable by a further 45 days on notice).

If you are in the UK, you may lodge a complaint with the Information Commissioner's Office. If you are in the EEA or Switzerland, you may lodge a complaint with your local data-protection authority.

If you are a California resident, you have the rights, under the CCPA/CPRA, to: know what personal information we collect, use, disclose, and share; correct inaccurate personal information; delete personal information we hold about you; limit our use of your sensitive personal information; opt out of any sale or sharing of personal information; and not be discriminated against for exercising any of these rights. We do not sell or share your personal information for cross-context behavioral advertising, and we have not done so in the preceding 12 months. We do not use or disclose sensitive personal information beyond the purposes permitted by California law. You can also designate an authorized agent to make a request on your behalf.

9. California residents

The rights California residents have under the CCPA and CPRA are listed in section 8 above. Two California statutes deserve their own explanation of what we actually do.

California Invasion of Privacy Act (CIPA)

CIPA protects your communications from being intercepted or recorded. Specifically:

  • We do not record voice or video calls. Recording is not enabled on the platform.
  • Messages between members are stored, so a conversation is there when you return and so it can be produced if someone reports abuse.
  • You control analytics. On our website the Statistics category in the cookie banner is off by default, and nothing is measured until you turn it on. In the app, analytics are off until you choose if you are in the EEA, the UK or Switzerland; elsewhere they are on by default. You can turn them off at any time in Profile, Privacy settings.

California Confidentiality of Medical Information Act (CMIA)

Since 2023 CMIA treats businesses offering reproductive or sexual health digital services as providers of health care. We collect information of that kind: fertility, pregnancy history, blood type, CMV status.

We do not treat your continued use of the Service as consent to any of it. Both authorizations are signed before you can use the Service at all: one covering collection, one covering what other members may see. Each is shown in full and recorded with its version and date. You may withdraw either at any time, and doing so closes your account, because we will not hold this information without your authorization. The record of the authorization and of its withdrawal is kept as proof of when your consent began and ended.

Under CMIA you have the right to access your medical information, to have it kept confidential, to require your authorization before it is disclosed, and to seek damages for unauthorized disclosure. The detail is in our Health Data Privacy Policy.

10. Partner organizations and their staff

Partners are organizations that help people become parents, such as fertility clinics, and talk with members through To Be Parents. Their staff use our partner portal (partner.tobeparents.com) and the TBP Partner app (To Be Parents: Partner in the App Store and Google Play). This section describes the personal information we handle about staff. If you are a member writing to a partner, the rest of this Policy applies to you as usual.

  • Account: work email, name, role, language, a profile photo if you add one, who invited you and when, when you joined and when you last signed in. We do not store a password: you sign in with a one-time code sent to your email.
  • Phones and sessions: for each phone signed in to TBP Partner, the platform, device model, app version, when the session started and was last used, and a push-notification token. In the browser, a session cookie keeps you signed in.
  • What you create: messages to members, internal notes, messages to colleagues and to our support team, files, tasks and appointments you add to a member's journey, and records of video meetings (who started and ended a meeting, when, and for how long). Meeting audio and video are not recorded.
  • Technical data: IP address and browser or app details in our server logs, in short-lived security counters that limit sign-in attempts, and in the audit log of account actions.

Who sees it: members see the name of the staff member who wrote to them, never their email, role or photo. Colleagues in the same organization see each other's name, role and photo, the organization's conversations and its internal notes. A chat between two colleagues is visible only to the two of them. Internal notes are never shown to members. Notifications and emails we send to staff do not contain message text or members' names. We do not use analytics or crash reporting about staff in the partner portal or in TBP Partner.

Our role: for staff accounts, and for the internal notes, assignment and status of conversations, we act as the partner's processor under our Data Processing Agreement. For everything else, the partner and we are each an independent controller. Staff data is stored on our servers in the United States (see section 6); the service providers we use for it are listed in the Data Processing Agreement.

How long we keep it: while you have access. When your organization removes your access, your sessions and push tokens are deleted at once. If you ask to delete your access (in TBP Partner or the partner portal), it is removed within 30 days, and then your name, email, photo, sessions and devices are erased. Messages, notes and files you created stay in your organization's conversations without your name, because records about patients belong to the organization. When a partner's account is deleted, its staff accounts are deleted with it. The audit log of account actions is kept for up to one year, backups for up to 90 days.

Your rights: you have the rights described in section 8; use our contact form. Where we act as your organization's processor, we pass your request to the organization and help it respond.

11. Security

We protect your data with transport-layer encryption, bcrypt password hashing, short-lived session tokens, rate-limiting and bot-challenge on sensitive endpoints, role-based access control, and audit logging of administrative actions. No online service can guarantee absolute security; if a breach affects your personal information, we will notify you and the relevant authorities as required by law.

12. Cookies

Strictly necessary first-party cookies always run so the Services work: a session cookie to keep you signed in, a CSRF-protection token, and a locale preference cookie. With your consent, we also use first-party analytics and attribution cookies to measure product usage and how visitors first reached us; you choose these in our cookie banner and can change your choice at any time. We do not use advertising cookies, and we do not sell your data or use it for behavioural advertising.

13. Children

The Services are strictly for adults aged 18 and over. If you believe a minor has created an account, report it via our contact form and we will remove it.

14. Automated decision-making

We do not make decisions with legal or similarly significant effects based solely on automated processing. Catalog ranking and photo moderation affect only your visibility and the status of individual photos; you can request human review of any moderation or account-status decision. Photo verification involves an automated comparison of your selfie with your profile photo; if verification is declined, you can request human review by our moderation team via the support chat.

15. Changes

We may update this Policy from time to time. When we make material changes, we will update the effective date above and, where appropriate, notify you by email or in-app notice before the change takes effect.

16. Contact

For any privacy question, request, or complaint, reach out through our contact form.