Privacy
Policy.

01

Who We Are

Never Strangers Pte. Ltd. is a company incorporated in Singapore and is the data controller responsible for your personal data.

• Registered Name: Never Strangers Pte. Ltd.
• UEN: 202546215N
• Address: 60 Paya Lebar Road #06-28, Paya Lebar Square, Singapore 409051
• Data Protection Contact: hello@thisisneverstrangers.com

02

Personal Data We Collect

We collect personal data that you provide to us directly, as well as data generated through your use of our platform and attendance at our events.

2.1 Registration & Identity Data

• Full legal name and date of birth
• Email address and phone number
• Profile photograph
• Government-issued photo ID (e.g. NRIC, passport, or driver's licence)
• Selfie photograph submitted for identity verification
• Gender and other profile information you choose to provide

2.2 Booking & Transaction Data

• Event booking history and attendance records
• Payment information processed via Stripe (we do not store card details)
• Refund and cancellation history
• No-show and late cancellation records

2.3 Communications Data

• Messages exchanged through our in-platform messaging feature
• Emails and correspondence with our team
• Support enquiries and feedback submitted to us

2.4 Marketing Preferences

• Your opt-in or opt-out status for marketing and event communications
• Email engagement data (open rates, click-throughs) collected by our email platform

2.5 Technical & Usage Data

• Device type, operating system, and browser information
• IP address and approximate location data
• Pages visited, features used, and time spent on the platform
• Login timestamps and session data

2.6 Safety & Conduct Data

• Reports made about or by you in relation to conduct at events
• Account suspension or ban records

2.7 Profile & Preference Data

• Responses to questionnaires and profile questions
• Interests, hobbies, and lifestyle information
• Occupation and professional background
• Music and entertainment preferences
• Personality and social preference indicators
• Matching preferences and the outcomes of matches
• Feedback and ratings you provide about events

03

How We Use Your Data

We collect and use your personal data only for the purposes set out below, and only to the extent necessary for those purposes.

• Account Registration & Vetting: To create and manage your account, verify your identity, and determine your eligibility to join the Never Strangers community.
• Event Management: To process bookings, manage attendance, communicate event details, and administer refunds or cancellations.
• Identity Verification & Safety: To verify your identity, prevent fraud and impersonation, and maintain a safe environment for all members.
• Payment Processing: To facilitate secure payment of booking fees through our payment processor, Stripe.
• Communications: To send booking confirmations, event reminders, account notifications, and policy updates. These are transactional and not subject to marketing opt-out.
• Marketing & Event Updates: Where you have given explicit consent, to send you information about upcoming events, offers, and news. You may withdraw this consent at any time.
• Platform Improvement: To analyse usage patterns and improve the quality and functionality of our platform and events.
• Legal Compliance: To comply with applicable laws, regulations, and lawful requests from regulatory or law enforcement authorities in Singapore.
• Community Safety & Conduct: To investigate reports of misconduct, enforce our Terms & Conditions, and protect the safety of our members.
• Research & Aggregated Insights: To analyse your responses and usage patterns, together with those of other members, in order to understand social and lifestyle trends, improve our events and platform, and produce aggregated, anonymised research. Where such research is published or shared with partners, it is always aggregated and anonymised, and never identifies you.

04

Legal Basis for Processing

Under the PDPA, we rely on the following bases for collecting and using your personal data:

• Consent: For account registration, identity verification, and (separately) marketing communications. You may withdraw consent at any time, though this may affect your ability to use our services.
• Contractual Necessity: For processing bookings, managing your account, and facilitating event attendance, being processing necessary to fulfil our agreement with you.
• Legitimate Interests: For platform security, fraud prevention, safety monitoring, and service improvement, where our interests are not overridden by your rights.
• Legal Obligation: Where we are required to process or disclose data to comply with Singapore law or a lawful order from a public authority.
• Business Improvement & Research: For analysing member information to improve our services and to produce aggregated, anonymised insights, as permitted under the business improvement and research provisions of the PDPA.

05

Disclosure to Third Parties

We do not sell your personal data. We may share your data with the following categories of third parties, strictly for the purposes described.

5.1 Payment Processing: Stripe

Booking fees are processed by Stripe, Inc. Your payment card details are submitted directly to Stripe and are not stored by Never Strangers. Stripe is PCI-DSS compliant and processes data in accordance with their own privacy policy. stripe.com/en-sg/privacy

5.2 Email Communications Platform

We use a third-party email platform (such as Mailchimp or equivalent) to send transactional and marketing communications. Your name and email address are shared solely for this purpose. Data may be processed outside of Singapore.

5.3 Venue Partners

For certain events, we may share limited attendee information (such as name and dietary requirements) with venue partners to facilitate the event. Venue partners are not permitted to use this data for any other purpose.

5.4 Legal & Regulatory Authorities

We may disclose your personal data to law enforcement agencies, regulatory bodies, or other public authorities in Singapore if required by law, court order, or where we reasonably believe disclosure is necessary to prevent harm or illegal activity.

5.5 Business Transfers

In the event of a merger, acquisition, or sale of assets involving Never Strangers, your personal data may be transferred to the relevant third party. We will notify you of any such transfer and any changes to how your data is handled.

5.6 Aggregated & Anonymised Insights

We may share aggregated, anonymised insights with partners. This information is statistical and cannot be used to identify any individual. We apply minimum group sizes and suppress small groups so that no individual can be re-identified. Aggregated insights are not personal data under the PDPA, and sharing them is not a sale of your personal data.

06

Cross-Border Data Transfers

As we use cloud-based services and third-party platforms (including Stripe and our email provider), some of your personal data may be transferred to, stored in, or processed in countries outside of Singapore, including the United States and the European Union.

Where personal data is transferred outside Singapore, we take reasonable steps to ensure the receiving party provides a standard of protection comparable to that under the PDPA. This may include contractual arrangements or use of service providers subject to binding data protection frameworks (e.g. EU GDPR).

By using Never Strangers, you consent to your personal data being transferred internationally in the manner described above.

07

Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by law.

• Active account data: Retained for the duration of your account, plus 3 years after account closure or last activity.
• Identity verification documents: Retained for 1 year after account closure or rejection, then securely deleted. If your account is suspended or banned, data may be retained for up to 5 years.
• Booking and transaction records: Retained for 7 years from the date of transaction, in accordance with Singapore's record-keeping requirements.
• Conduct and safety records: Retained indefinitely where a serious incident occurred, to protect the safety of our community.
• Marketing consent records: Retained for as long as needed to evidence consent or withdrawal of consent.

When personal data is no longer required, it is securely deleted or anonymised.

08

Data Security

We implement reasonable organisational and technical measures to protect your personal data from unauthorised access, disclosure, alteration, or destruction, including:

• Restricted access to personal data on a need-to-know basis within our team.
• Secure transmission of data using industry-standard encryption (SSL/TLS).
• Use of reputable, security-certified third-party service providers.
• Regular review of our data handling and security practices.

No method of electronic transmission or storage is completely secure. In the event of a data breach likely to result in significant harm, we will notify the Personal Data Protection Commission (PDPC) and affected individuals within 3 calendar days of becoming aware of the breach, in accordance with the PDPA's mandatory breach notification obligations.

09

Your Rights Under the PDPA

As a data subject under the PDPA, you have the following rights with respect to your personal data:

• Right of Access: You may request a copy of the personal data we hold about you and how it has been used or disclosed in the past year.
• Right of Correction: You may request that we correct any inaccurate or incomplete personal data we hold about you.
• Right to Withdraw Consent: You may withdraw your consent to any use of your personal data at any time. Withdrawal of consent to essential processing will result in termination of your account. Withdrawal of consent to marketing will not affect your ability to use the service.
• Right to Data Portability: In certain circumstances, you may request that we provide your personal data in a structured, machine-readable format.

To exercise any of these rights, contact us at hello@thisisneverstrangers.com. We will respond within 30 days. We may ask you to verify your identity before processing your request. There is no charge for reasonable requests; however, we reserve the right to charge an administrative fee for excessive or repetitive requests.

10

Cookies & Tracking Technologies

Our platform may use cookies and similar tracking technologies to enhance your experience, analyse usage, and support marketing activities. We may use the following types of cookies:

• Essential cookies: Necessary for the platform to function. These cannot be disabled.
• Analytics cookies: Help us understand how members use our platform so we can improve it.
• Marketing cookies: Used to deliver relevant communications and track the effectiveness of our campaigns.

You may control cookie settings through your browser. Disabling certain cookies may affect the functionality of the platform.

11

Minors

Never Strangers is strictly for individuals aged 21 and above. We do not knowingly collect personal data from anyone under the age of 21. If we become aware that we have inadvertently collected data from a person under this age, we will delete that data promptly. If you believe we may have collected data from an underage individual, please contact us immediately at hello@thisisneverstrangers.com.

12

Marketing Communications

We will only send you marketing communications where you have given your explicit, separate consent during the registration process, in accordance with the PDPA's requirements on consent for marketing.

You may unsubscribe at any time by clicking the unsubscribe link in any marketing email, or by emailing us at hello@thisisneverstrangers.com. Unsubscribing from marketing does not affect transactional communications such as booking confirmations and account notices.

13

Third-Party Links & Services

Our platform may contain links to third-party websites or services (such as venue websites or social media pages). We are not responsible for the privacy practices of those third parties. We encourage you to review their privacy policies before submitting any personal data to them.

14

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or the services we offer. When we make material changes, we will update the Last Updated date at the top of this document and notify you by email or through the platform.

Your continued use of Never Strangers after any such changes constitutes your acknowledgement of the updated Policy. We encourage you to review this Policy periodically.

15

Complaints & the PDPC

If you have a concern about how we have handled your personal data and are not satisfied with our response, you have the right to lodge a complaint with Singapore's Personal Data Protection Commission (PDPC).

• Personal Data Protection Commission (PDPC)
• Website: www.pdpc.gov.sg
• Helpline: 1800-PDPA-LAW (1800-7372-529)

16

Contact Us

For any questions, concerns, or requests relating to this Privacy Policy or your personal data, contact us at hello@thisisneverstrangers.com.