BeeBaby
⚠️ Draft — not yet legal-reviewed. Before publishing: fill every [PLACEHOLDER], confirm the data practices below match what the app actually does, work through the pre-publication checklist at the end, and have a qualified privacy lawyer review it (the biometric/face, third-party AI, and cross-border transfer sections in particular). Then delete this banner and the checklist.

Privacy Policy

Last updated: 2026-06-20  ·  Effective: 2026-06-20

BeeBaby (“BeeBaby”, “we”, “us”, “our”) is an AI-assisted social and dating service. Your personal AI “twin” autonomously breaks the ice and holds early conversations on your behalf, and we bring forward the people worth meeting so you can take the conversation from there. This Privacy Policy explains what personal data we collect, how and why we use it, who we share it with, and the rights and choices you have.

This Policy applies to the BeeBaby mobile apps, websites, and related services (together, the “Service”). Because this is a dating service, some information you provide is personal or sensitive and may be visible to other users. Please read this together with our Terms of Service.

Contents
  1. Who we are & how to contact us
  2. Data we collect
  3. Sensitive information
  4. Face & liveness data
  5. Your AI twin & LLM processing
  6. How & why we use your data
  7. What other users can see
  8. How we share data
  9. International data transfers
  10. Retention & deletion
  11. Your privacy rights
  12. Security
  13. Age requirement (18+)
  14. Push & marketing choices
  15. Changes to this Policy

1. Who we are & how to contact us

The data controller responsible for your personal data is BeeBaby HK Limited, a company registered in the Hong Kong Special Administrative Region at RM 603 6/F LAWS COML PLZ 788 CHEUNG SHA WAN RD, CHEUNG SHA WAN.

2. Data we collect

Information you give us

Information generated through your use of the Service

Information from third parties

We use Firebase, a Google service, for two purposes: (a) Firebase Cloud Messaging to deliver push notifications, and (b) Google Analytics for Firebase to understand aggregate app usage and improve the Service. Through Firebase, Google may process identifiers such as a push-notification token, an app-instance identifier, device and event data, and approximate (IP-derived) location. We use this for product analytics, reliability, and notifications — not for third-party advertising; we do not use cross-app advertising SDKs or advertising identifiers. Our website serves static pages and sets no cookies and no analytics or advertising trackers. [PLACEHOLDER: counsel to reconcile the Firebase / Google Analytics data above with your Apple “App Privacy” labels and Google Play “Data safety” answers before publishing.]

3. Sensitive information

Some data we process may be sensitive / special-category under applicable law, including biometric or biometric-derived liveness data, photos and selfies, who you are interested in and other dating preferences, political opinions, religious or philosophical views, and the causes you care about (where you choose to share them), message content, location, personality and values data, and inferences about compatibility or attraction. Where the law requires it, we ask for your consent before processing sensitive data. You can withdraw consent where legally available, but some features may not work without the data needed to provide them.

4. Face & liveness data

To keep the community real and reduce impersonation, we ask you to take a selfie and complete a liveness check, performed using Amazon Web Services (AWS) Rekognition Face Liveness. This may involve processing face geometry derived from your image, which is treated as biometric / special-category personal data in many jurisdictions. We process it only:

What we keep, and for how long. Your selfie and liveness capture are stored for up to 1 month and then automatically deleted by an automatic storage-lifecycle expiration rule. From the check we retain a liveness reference image and related face-check metadata (such as a face bounding box and image-quality data), which we use to verify that photos you upload later are really you. We keep this reference data for as long as your account is active and we need it for verification, and we delete it — both the reference image and its face metadata — when you delete your account. We use this data only for liveness and identity verification — never for advertising — and your selfie is not displayed anywhere in the app.

U.S. biometric laws (Illinois, Texas, Washington). If you are in a state with a biometric privacy law, the following applies. We collect and store biometric identifiers and biometric information (face geometry derived from your selfie and liveness capture) only after you give a written release (your written consent), and solely to verify you are a live, real person and that later photo uploads are really you. We do not sell, lease, trade, or otherwise profit from your biometric data. We protect it using a reasonable standard of care and retain it only as long as needed for verification: the selfie and liveness capture for up to 1 month, and the liveness reference image and face metadata until you delete your account or within 3 years of your last interaction, whichever comes first — after which it is permanently destroyed. [DRAFT — counsel to finalize the standalone written release / consent flow (separate from this Policy, shown before capture), the exact retention schedule, and the destruction timeline required by BIPA, Texas CUBI, and Washington’s biometric law (RCW 19.375).]

5. Your AI twin & LLM processing

Your AI twin is generated and operated using automated systems, including third-party large-language-model (LLM) providers. To generate its messages and assess compatibility, we send relevant inputs — prompts, your profile and personality context, training history, AI-twin instructions, and conversation context — to those providers, which return generated text, evaluations, or structured output. They process the data to provide the service to us under contractual confidentiality and security terms.

AI output can be imperfect. We use technical and policy controls to reduce unsafe or misleading behavior, but you should review important messages and decisions yourself. We do not promise that AI-generated compatibility or chemistry scores, or handoff recommendations, predict any relationship outcome.

Our current LLM provider is Google (the Gemini API), and avatar images are generated using Google’s Gemini image model. We use the paid Gemini API, under which Google does not use the data we submit to train its models and processes it only to provide the service. LLM providers may process data in countries outside your own (see Section 9). [PLACEHOLDER: confirm Google’s then-current Gemini API data-governance retention window before publishing, and update this section if you add or change LLM providers.]

6. How & why we use your data

Purpose Examples Legal basis (EEA/UK)
Provide the Service Create your account, build your AI twin, show profiles, run dispatches, produce match handoffs, deliver messages, maintain coins/gifts/subscriptions, and sync across devices. Contract; consent for optional/sensitive features where required.
Personalize matching & AI twin behavior Use profile, training, values, preferences, and conversation signals to improve icebreakers, chemistry scoring, and handoff quality. Contract; legitimate interests; consent for special-category data where required.
Liveness, trust & safety AWS Rekognition liveness checks, abuse/scam detection, moderation, prompt-injection and manipulation defenses, account integrity, report handling, and fraud prevention. Consent where required for biometrics; legitimate interests; legal obligations.
AI / LLM processing Send relevant prompts, profile context, training content, and conversation context to third-party LLM providers to generate or evaluate AI-twin output. Contract; legitimate interests; consent where required for sensitive data.
Communications Service notices, push notifications, match updates, safety notices, support replies, and (where allowed) product/marketing announcements. Contract; legitimate interests; consent where required.
Improve & debug Analyze logs, traces, crashes, aggregate usage, feature performance, and quality outcomes. Legitimate interests; consent where required.
Legal, compliance & enforcement Enforce our Terms, respond to legal requests, prevent harm, comply with tax/payment obligations, and protect rights and safety. Legal obligations; legitimate interests; vital interests where applicable.

You can withdraw any consent at any time (Section 11); this doesn’t affect processing already carried out.

7. What other users can see

A dating service necessarily shares some information with others. Depending on the feature, other members may see your profile photos, display name, age or age range, city or approximate location, bio, interests, lifestyle fields, occupation, values, selected prompts, AI-twin icebreakers, featured quotes, messages you send, gifts, and match/handoff context. Don’t share information you don’t want others to see, save, or re-share. Our Terms prohibit misuse of other members’ content, but we can’t control everything others do.

8. How we share data

We do not sell your personal information, and we do not share it for cross-context behavioral advertising, as those terms are defined by California law. [PLACEHOLDER: counsel to confirm against the final analytics/SDK inventory — including Firebase / Google Analytics — and whether that analytics use implicates “sharing” under California law before publishing.]

9. International data transfers

We and our service providers may process information in the United States, the European Economic Area, the United Kingdom, Hong Kong, and other countries where we or our providers operate. Privacy laws there may differ from those where you live. For EEA, UK, and Swiss users, where required we rely on appropriate transfer mechanisms such as adequacy decisions, Standard Contractual Clauses, or the UK International Data Transfer Addendum. In particular, our processing involves Google (Gemini API, Firebase) and AWS (Rekognition liveness and storage), which may process data in the United States and other regions; for transfers out of the EEA, UK, or Switzerland we rely on the Standard Contractual Clauses (and the UK Addendum) that these providers incorporate into their data-processing terms. [DRAFT — counsel to confirm each provider’s operating regions and that the executed SCCs / UK IDTA are in place before publishing.]

10. Retention & deletion

We keep personal data only as long as needed to provide the Service, comply with law, resolve disputes, enforce agreements, maintain safety, and prevent fraud — then delete or de-identify it. Indicative periods:

Data Retention
Account, profile, AI twin, matches, messages, coins/gifts/subscriptions While your account is active; after deletion, retained during a 30-day deletion cooldown, then deleted or de-identified (typically by our daily purge process)
Selfie / liveness capture Up to 1 month, then automatically deleted (see Section 4)
Liveness reference image & face metadata While your account is active and needed to verify your later photo uploads; deleted when you delete your account (see Section 4)
Purchase / tax / accounting records De-identified where possible; where Hong Kong law requires (Inland Revenue business-record retention), kept for at least 7 years, then deleted
Safety / moderation / banned-account & fraud records De-identified where possible and retained longer to keep banned users off the Service — up to 2 years
Support correspondence & logs Up to 24 months
Backups Rolling backups, overwritten within 30–90 days

You can delete your account at any time in the app at Settings → Delete account, or by emailing us at support[AT]beebaby.ai. Deleting your account starts a 30-day deletion cooldown during which you cannot sign in or sign up again with the same account; after that, we delete or de-identify the personal data associated with your account, except where we must keep certain data for legal, safety, fraud-prevention, dispute, or accounting reasons.

11. Your privacy rights

Depending on where you live, you may have the right to access, correct, delete, port, restrict, or object to certain processing; withdraw consent; opt out of any “sale”/“sharing” or targeted advertising; limit use of sensitive personal information; and appeal a denied request. To make a request, contact support[AT]beebaby.ai or use in-app settings where available. We may need to verify your identity, and authorized agents may submit requests where permitted by law.

California & other U.S. state rights

California and certain other U.S. residents may have rights to know the categories of personal information collected, the sources, purposes, recipients, and retention, and whether information is sold or shared; and to access, delete, correct, opt out, limit sensitive-information use, and not be discriminated against for exercising rights.

In the past 12 months we have collected the following categories of personal information (as defined under the CCPA/CPRA). Their sources, business purposes, and retention are described in Sections 2, 6, and 10, and the categories of recipients in Section 8. We have not sold, and have not shared for cross-context behavioral advertising, any of these categories. [DRAFT — counsel to verify the categories, recipients, and sale/share status against the final SDK/vendor inventory.]

CCPA/CPRA category Examples we collect Disclosed to (categories of recipients) Sold / Shared?
IdentifiersName, email, account ID, device/installation ID, app-instance ID, IP address, push tokenSign-in, analytics & push providers (Google), hosting/infrastructure, payment partnersNo
Customer records (Cal. Civ. Code §1798.80)Photos; phone number (if phone sign-in is enabled)Hosting/storage; other members (profile photos)No
Protected classification characteristicsAge / date of birth, gender, who you’re interested inOther members; hostingNo
Commercial informationCoins, gifts, subscription status, purchase/refund recordsApp stores & payment partners (Apple, Google); hostingNo
Biometric informationFace geometry / liveness data; liveness reference imageLiveness provider (AWS Rekognition); storageNo
Internet / network activityFeature interactions, usage and diagnostic logs, analytics eventsAnalytics provider (Google / Firebase); hostingNo
Geolocation dataCity/region you select; approximate (IP-derived) locationHosting; analytics providerNo
Audio / visual & similar informationSelfie and liveness capture; profile photosLiveness / storage providers; other members (profile photos)No
Professional / employment informationOccupation, industryOther members; hostingNo
Education informationEducation levelOther members; hostingNo
InferencesPersonality (e.g. Big Five), values, compatibility / chemistry signals, AI-twin personaLLM provider (Google Gemini); hostingNo
Sensitive personal informationFace / biometric data; sexual orientation and dating preferences; religious or philosophical beliefs and political opinions (where you share them); message content; account access tokens; personality and values dataAs above, by category; used only to provide the Service and for safetyNo

We use and disclose sensitive personal information only to provide the Service, ensure security and integrity, and for the other purposes in Section 6 — not to infer characteristics about you for any incompatible purpose. Where required, you may ask us to limit our use of sensitive personal information, subject to the features that depend on it. [DRAFT — counsel to confirm the sensitive-PI categories and the limit-use mechanics.]

EEA, UK & Swiss rights

You may have GDPR-style rights, including access, rectification, erasure, restriction, portability, objection, and consent withdrawal, and the right to lodge a complaint with your local supervisory authority. We’d appreciate the chance to address your concern first.

12. Security

We use reasonable technical and organizational measures designed to protect personal data — including access controls, encryption in transit where appropriate, logging, monitoring, and limited internal access. No online service is completely secure, and we cannot guarantee absolute security. If we become aware of a personal-data breach that affects you, we will investigate, act to mitigate it, and notify affected users and the relevant regulators where and within the timeframes required by applicable law (for example, without undue delay and, where the GDPR applies, within 72 hours of becoming aware). [DRAFT — counsel to confirm the notification thresholds and timeframes for each jurisdiction.]

13. Age requirement (18+)

The Service is for adults only — you must be at least 18 (or older where your jurisdiction’s age of majority is higher). We do not knowingly collect data from anyone under 18. If you believe an underage person is using the Service, contact us and we will investigate and delete where appropriate.

14. Push & marketing choices

Control push notifications through your device and in-app settings, and unsubscribe from marketing emails using the link in those emails. We may still send essential service and safety messages.

15. Changes to this Policy

We may update this Policy from time to time. If changes are material, we will notify you in the app or by another appropriate method before they take effect. The “Last updated” date shows when this Policy was last revised.

Pre-publication checklist (remove before publishing)