PRIVACY POLICY

BUDDY PRIVACY POLICY

Effective Date: 9/9/2026
Last Updated: 9/9/2026

This Privacy Policy explains how HSW HONG KONG CO. LIMITED, operating the Buddy platform, collects, uses, stores, protects and discloses personal data.

Buddy is a global service. This Privacy Policy is designed to address applicable privacy requirements in the jurisdictions where Buddy operates, including Hong Kong's Personal Data (Privacy) Ordinance (PDPO).

Hong Kong's PDPO requires personal data collection to be lawful, fair, directly related to a function or activity, necessary and not excessive, and requires appropriate transparency about purposes and classes of transferees. It also addresses accuracy and retention.

Who We Are

Company: HSW HONG KONG CO. LIMITED
Product: Buddy
Website: ineedbuddy.app

Privacy Contact: safety@ineedbuddy.app

Information We Collect

Depending on how you use Buddy, we may collect the following categories.

Account Information

Buddy uses Firebase Authentication for account authentication.

Profile Information

You may provide:

User Content

Buddy may process:

Buddy uses Cloudflare R2 for storage of applicable photo, audio and video content.

Location Information

Buddy may process location information to provide:

Buddy uses Google location-related services for applicable location functionality.

We do not intend to publicly display your precise location to other users.

Messaging Information

Buddy uses Firebase Realtime Database and PostgreSQL for messaging-related functionality and data storage.

Messages may be processed for:

Device and Technical Information

Depending on your use of Buddy, we may process:

Analytics

Buddy uses Google Analytics to understand usage, performance and service activity.

Analytics may involve information such as:

Push Notifications

Buddy uses Firebase Cloud Messaging (FCM) to provide push notifications.

Depending on your device and settings, notification functionality may involve device/app identifiers and notification-related information.

Payment Information

Buddy Premium is planned to be purchased through:

Payment processing is handled through the applicable platform.

Buddy does not need to receive or store your complete payment card number when payment is processed through Apple or Google.

• Email address
• Account identifiers
• Authentication information
• Date of birth or age information
• Verification information.
• Display name
• Profile photo
• Age
• Biography
• Interests
• Activities
• Preferences
• Relationship intentions
• Other profile information.
• Photos
• Posts
• Comments
• Profile content
• Messages
• Audio
• Video
• Other content you upload or send.
• Nearby
• Matching
• Local discovery
• Activity discovery
• Travel-related discovery
• Location-based recommendations.
• Message delivery
• Service operation
• Security
• Abuse prevention
• Investigation of reports
• Legal compliance.
• Device type
• Operating system
• App version
• IP address
• Device identifiers
• Crash and diagnostic information
• Security logs
• Network information.
• App/website interactions
• Device information
• Technical information
• Usage events
• Performance information.
• Apple App Store
• Google Play.

How We Use Personal Data

We may use personal data to:

• Create and manage your account
• Authenticate users
• Provide Buddy features
• Provide Nearby
• Provide matching
• Deliver messages
• Display profiles and User Content
• Personalize discovery
• Provide customer support
• Process subscriptions
• Send service notifications
• Prevent fraud
• Detect abuse
• Protect users
• Maintain security
• Analyze and improve Buddy
• Diagnose technical issues
• Comply with applicable law.

Location and Nearby

Location is an important feature of Buddy.

We may use location information to determine approximate proximity and provide Nearby and matching functionality.

We aim to minimize exposure of precise location information.

You can control location permissions through your device settings. If you do not provide location permission, certain Nearby features may not be available.

Matching and Recommendations

Buddy may use information such as:

to provide recommendations and matching.

• Interests
• Preferences
• Activities
• Location
• Profile information
• Interactions
• Connection activity

Sharing Personal Data

We may share personal data with service providers that help us operate Buddy, including providers supporting:

We may also disclose information where required or permitted by law, including to regulators, courts or law enforcement.

Current Core Providers

Buddy currently uses:

We may add, replace or remove service providers as Buddy develops. Where required, this Privacy Policy will be updated accordingly.

• Authentication
• Cloud infrastructure
• Messaging
• Media storage
• Analytics
• Push notifications
• Location services
• Security
• Customer support
• Payment processing
• Legal and professional services.
• Firebase Authentication
• Firebase Cloud Messaging
• Firebase Realtime Database
• Google Analytics
• Google location-related services
• Cloudflare R2
• Apple App Store
• Google Play
• PostgreSQL infrastructure

No Advertising at Launch

Buddy does not operate an advertising program at launch.

Buddy does not currently use advertising networks to serve targeted advertisements within the Buddy App.

If this changes, we will update our privacy disclosures and implement any consent or other requirements applicable to the new activity.

International Data Transfers

Buddy is a global platform.

Your personal data may be processed or stored in countries other than your country of residence, including countries where our service providers operate.

We will use appropriate safeguards where required by applicable law.

Data Security

Buddy uses reasonable technical and organizational safeguards designed to protect personal data.

These may include:

No Internet service can guarantee absolute security.

• Access controls
• Authentication
• Encryption in transit where appropriate
• Secure storage
• Monitoring
• Security controls
• Access limitation
• Incident response procedures.

Data Retention

Buddy retains personal data only for as long as reasonably necessary for the purposes described in this Policy, including:

When personal data is no longer required, we will take reasonable steps to delete, anonymize or securely dispose of it, subject to applicable legal requirements.

This is also consistent with Hong Kong PDPO requirements concerning retention.

• Providing the Service
• Security
• Fraud prevention
• Dispute resolution
• Legal compliance
• Accounting and financial requirements.

Account Deletion

You may delete your Buddy account through the available account deletion process.

When an account is deleted, Buddy will take reasonable steps to delete associated personal data, subject to information that must or may lawfully be retained.

Apple requires account deletion to be available within apps that support account creation, and Google Play requires both an in-app and external web deletion path.

Privacy Rights

Depending on applicable law, you may have rights to:

Hong Kong's PDPO includes rights relating to access to and correction of personal data.

• Access personal data
• Correct personal data
• Request deletion
• Request information about processing
• Withdraw consent where applicable
• Opt out of certain marketing communications
• Exercise other rights available under applicable law.

Direct Marketing

If Buddy uses personal data for direct marketing, we will comply with applicable direct-marketing requirements.

For Hong Kong, direct marketing is subject to specific requirements under the PDPO.

Children

Buddy is an 18+ platform.

Buddy does not knowingly permit persons below the applicable minimum age to create or maintain accounts.

If we reasonably determine that an account belongs to an underage user, we may suspend and delete that account.

Child Safety

Buddy has zero tolerance for child sexual abuse and exploitation.

We prohibit:

Google Play currently requires Social and Dating apps to maintain published child-safety standards, provide reporting/feedback mechanisms and designate a child-safety contact.

• Child sexual abuse material
• Grooming
• Sexual solicitation of minors
• Sexual exploitation of minors
• Trafficking involving minors.

Data Breach

If Buddy becomes aware of a personal data security incident, we will assess, contain and investigate the incident and take appropriate steps under applicable law.

Where notification is required or appropriate, we may notify affected users, regulators or other relevant parties.

Third-Party Services

Third-party providers used by Buddy may process information on our behalf.

Their processing is subject to applicable contractual, legal and technical safeguards.

Changes to this Privacy Policy

We may update this Privacy Policy when our Service, technology, business practices or legal requirements change.

Material changes may be communicated through the App, Website or other appropriate means.

Contact

HSW HONG KONG CO. LIMITED
Buddy
ineedbuddy.app

Privacy: safety@ineedbuddy.app