Privacy Policy
This Privacy Policy applies from December 8, 2025.
1. Who We Are
The company responsible for your data (the “data controller”) is:
Overtone Studios, Inc.
809 Washington St
New York, NY 10014
2. Where This Privacy Policy Applies
This Privacy Policy applies to websites, apps, events and other services we operate under the Overtone brand. Whether you're searching for your soulmate or something less serious, this Policy has got you covered. For simplicity, we just refer to all of our platforms and offerings as our “service” in this Privacy Policy.
If for some reason, one of our services requires its own separate privacy policy, then that policy will be made available to you and that policy -- not this Privacy Policy -- will apply.
3. Data We Collect
It goes without saying, we can’t help you develop meaningful connections without you providing some information about yourself, like basic profile details and the types of people you’d like to meet. Using our service also generates some information, such as when you logged in and how you used the service, as well as the insights and inferences we generate based on the content you provide.
We also collect data from third parties, like when you access the service through an account you have on another platform (e.g., Google or Apple) or when you upload information from your account on another platform to complete your profile. If you're interested in all the details, be sure to check out the table below.
| Data you give us | |
|---|---|
| Categories | Description |
| Account Data | When you sign up for our waitlist or create an account, you give us basic information that enables us to operate and manage the waitlist and set up your account, such as your phone number, email address, date of birth, and password. |
| Profile Data | When you complete your profile, you share additional details about you, such as your gender, interests, preferences, approximate location, etc. Some of this data may be considered sensitive or special in certain countries, such as details about sexual orientation, sexual life, health, racial or ethnic origins, religious beliefs or political affiliations. If you choose to provide this data, you consent to us using it as laid out in this Privacy Policy. |
| Content | When you use our service, you share photos, videos, audio, text and other types of content, such as your chats with other members. |
| Purchase Data | When you make a purchase or request a refund, we keep the details of the transaction (e.g., what you purchased, the date of the transaction, and the price). The exact data depends on the payment method you choose. When you pay directly with us (rather than through a platform such as iOS or Android), you provide your debit or credit card number or other financial information. |
| Marketing, Survey and Research Data | We sometimes run (i) surveys, focus groups, or market studies for research purposes and (ii) promotions, events or contests for marketing purposes. When you choose to participate, you give us information to process your entry and participation, as well as your responses to our questions and your feedback. |
| Third-Party Data | When you choose to share information about other people (for example, if you use the contact details of someone you know for a given feature or if you submit a query or report involving a member), we process this data on your behalf to complete your request. |
| Customer Support Data | When you contact us, you provide us with information that is necessary to help address your enquiry. Other people can also submit queries or reports involving you. Finally, our moderation tools and teams collect additional data as part of their investigations. Where legally allowed, we also receive information about suspected or confirmed bad actors from third parties as part of our efforts to ensure our members’ safety and security. |
| Data generated or automatically collected | |
|---|---|
| Categories | Description |
| Usage Data | Using the service generates data about your activity, including how you use it (e.g., when you logged in, features you’ve been using, actions taken, information shown to you, referring webpages, ads you interacted with) and how you interact with others (e.g., searching, matching, communicating). We also receive data related to interactions you have with our ads on third party websites or apps, if applicable. |
| Technical Data | Using the service involves the collection of data from and about the device(s) you use to access our service, including hardware and software information such as IP address, device ID, device type, operating system and configurations, network information, as well as app settings and characteristics, app crashes, advertising IDs and identifiers associated with cookies or other technologies that can uniquely identify a device or browser. For more information about cookies, see our Cookie Policy. |
| Insights and Inferences | Using the service involves the generation of insights and inferences, drawn from your interactions and the information and content you provide, reflecting, e.g., your preferences, characteristics, predispositions, behavior, and attitudes. |
| Other data we collect with your permission/consent | |
|---|---|
| Categories | Description |
| Geolocation Data | If you give us permission, we collect your geolocation (latitude and longitude) from your device. If you decline permission, certain features that rely on precise geolocation will not be available to you. |
| Face Data | You may choose to participate in certain of our features that involve the collection of face geometry data, which may be considered biometric data in some jurisdictions. |
| ID Data | You may choose to provide us with a copy of your government-issued ID to help us check that you’re who you say you are. |
4. Why and How We Use Your Data
The main reason we process your data is to provide our service to you and improve it over time. That includes connecting you with members who might make your heart skip a beat, personalizing your experience, and just helping you make the most of our service. We also process your data to keep our service, you, and others safe and secure. We take this responsibility very seriously and we’re always working to improve the safety and security of our systems and processes. Read on for a more detailed explanation.
For information on how we process personal data through “profiling” and “automated decision-making”, please see our FAQ.
| Purposes for processing your data | Grounds for processing your data | Categories of data processed (Those are described in Section 3 of this Policy) |
|---|---|---|
| To operate and manage our waitlist, including: Enabling you to join the waitlist Confirming your place on the waitlist Maintaining the waitlist Contacting you when you are eligible to create an account or when the service becomes available in your region | Performance of our contract with you Your consent (where necessary to send you, e.g., SMS messages or similar communications regarding your place on the waitlist or the availability of the service in your region) | Account Data Usage Data Technical Data |
| To enable you to use our service, including: Creating and maintaining your account and profile on our service Operating and maintaining the various features on our service Recommending other members to you and recommending you to them Organizing sweepstakes and contests Responding to your requests and questions Monitoring the well functioning of our service and troubleshooting and fixing issues as needed | Performance of our contract with you Your consent (where sensitive data or other type of data that requires consent is processed) | Account Data Profile Data Content Purchase Data Marketing, Survey and Research Data Third Party Data Customer Support Data Usage Data Technical Data Insights and Inferences Geolocation Data Face Data |
| To enable your purchases on our service, including: Processing payments Offering discounts and promotions, customizing prices | Performance of our contract with you Our legitimate interest: it is in our legitimate interest to offer discounts and promotions and customize prices, where and as legally permissible | Account Data Profile Data Technical Data Purchase Data Usage Data Insights and Inferences |
| To operate advertising and marketing campaigns, including: Performing and measuring the effectiveness of advertising campaigns run on our service Performing and measuring the effectiveness of marketing campaigns promoting our own service on third-party platforms Communicating with you about products and services we believe may interest you | Consent (where required under applicable law) and otherwise our legitimate interest. It is in our legitimate interest to promote our service and to show ads to our members which are tailored to their interests, as a way to improve their experience and help fund the parts of our service which are free | Account Data Profile Data Usage Data Marketing, Survey and Research Data Technical Data Insights and Inferences |
| To improve our service and create new features and services, including: Running focus groups, market studies and surveys Analyzing how our service is used Reviewing interactions with customer care teams to improve service quality Developing and improving new features and services, including through machine learning and other technologies, and testing them out Conducting research and publishing research papers | Performance of our contract with you Our legitimate interest: It is in our legitimate interest to improve our service over time Consent where required under applicable law (e.g., we may process data deemed sensitive or special in certain countries to help make sure that the various communities using our service are being treated fairly and equitably and that our service remains diverse and inclusive) | Account Data Profile Data Content Purchase Data Marketing, Survey and Research Data Third Party Data Customer Support Data Usage Data Technical Data Insights and Inferences |
| To keep you and other members safe on our service and across our services, including: Preventing, detecting and fighting against violations of our Terms, fraud and other illegal or unauthorized activities Developing and improving tools to prevent, detect and fight against violations of our Terms, fraud and other illegal or unauthorized activities Preventing recurrences, notably by preventing individuals who violate our Terms from creating a new account Letting individuals know what we’ve done about reports they submit or potential safety risks we identify Verifying your identity Securing payments and fighting against financial fraud | Performance of our contract with you Our legitimate interest: It is in our legitimate interest and that of our members to keep them safe Protection of your vital interests and that of other members Ensuring your security and the prevention of fraud in the processes of identification and authentication in electronic systems Compliance with legal obligations that apply to us such as taking down illicit content or notifying users who have interacted with a user whose account is banned The processing is necessary for the protection of substantial public interest: it is in the substantial public interest that we prevent, detect and fight against illegal activities on and off our platforms and cooperate with law enforcement authorities on such matters Your consent (where sensitive data or another type of data that require consent is processed) | Account Data Profile Data Content Purchase Data Third Party Data Customer Care Data Usage Data Technical Data Insights and Inferences ID Data |
| To comply with applicable law, establish, exercise and defend legal claims & rights, including: Preserving data to comply – and evidence compliance – with applicable law Supporting investigations and defending potential or ongoing litigation, regulatory action or dispute Responding to lawful requests from law enforcement, courts, regulators, and other third parties Reporting illegal or infringing content to law enforcement, government or other authorities Establishing, exercising, or defending ongoing or threatened claims Sharing data with law enforcement or partners to combat abusive or illegal behavior | Our legitimate interest: It is in our legitimate interest to comply with applicable law and protect ourselves, our members and others, including as part of investigations, legal proceedings and other disputes Protection of your vital interests and that of other members Compliance with legal obligations applying to us such as responding to law enforcement requests for information | The categories of data shared will vary based on the specific circumstances surrounding each obligation, compelling interest or dispute |
Since our goal is to help you make meaningful connections, some of your information is of course visible to other members on the service. We also share data with service providers and partners who assist us in operating the service, with other affiliated companies for the reasons laid out below and, in some cases, for legal and related reasons. Read on for more details.
| Recipients | Reasons for sharing | Categories of Personal Data |
|---|---|---|
| Other members | You share data with other members when you voluntarily disclose information on the service for others to see (e.g., your public profile). If someone submits a report involving you (such as a claim you violated our Terms of Use), we may let the reporter know what actions we took, if any, as a result of their report. The same applies if you submit a report involving another member. | Profile Data Content Third Party Data Customer Support Data Usage Data Insights and Inferences |
| Service providers/partners | We share data with vendors and partners who help us operate, promote and improve our service. They provide us services such as data hosting and maintenance, SMS messaging, analytics, customer care, marketing, advertising, payment processing, legal support, and security operations. Where permitted by applicable law, we may also share data with partners (such as companies facing similar threats), and they may share data with us, when necessary to promote the safety, security, and integrity of our service, our Members, our employees, and others. | Depending on the service provided by the vendor or partner, it may include: Account Data Profile Data Content Purchase Data Marketing, Survey and Research Data Third Party Data Customer Support Data Usage Data Technical Data Insights and Inferences Geolocation Data Face Data ID Data |
| Advertising partners | We publish ads about third-party advertisers’ products and services on our service, and publish ads promoting our own service on third-party sites and apps. To help improve the relevance of these ads, we provide certain info about you to third parties, including advertising partners, or allow them to collect such data from our services (such as via cookies, SDKs, or similar technologies). Some of our advertising partners enable us to transform your email address, advertising identifiers or phone number into an identifier that can’t be used to identify you personally and then use that unique identifier to either exclude you from our marketing campaigns, or to target our ads at an audience that is similar to you in terms of background, interests or app usage. If you live in the United States, some of the activities described in this section may constitute “targeted advertising,” “sharing,” or “selling” under applicable laws. You have the right to opt-out, as described in Section 7. | Account Data Profile Data Usage Data Technical Data Insights and Inferences |
| Affiliates | We share data with affiliates or receive data from them to allow us to take necessary actions, including closing your account or preventing you from creating an account on our service or our affiliates’ services. | The categories of data will vary based on the reason for sharing, but it may include:. Account Data Profile Data Content Purchase Data Marketing, Survey and Research Data Third Party Data Customer Support Data Usage Data Technical Data Insights and Inferences Geolocation Data Face Data ID Data |
| Law enforcement authorities | We may disclose your data to: (i) comply with a legal process, such as a court order, subpoena or search warrant, government / law enforcement investigation or other legal requirements; (ii) assist in the prevention or detection of crime; (iii) protect the safety of any person; and (iv) establish, exercise or defend legal claims. | The categories of data shared will vary depending on the specific circumstances surrounding the request, but it often can include: Account data Profile Data Content Purchase Data Customer Support Data Third Party Data Usage Data Technical Data Insights and Inferences Geolocation Data ID Data |
| In the context of merger and acquisition, with our Affiliates or new owner(s) | We may transfer your data if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control. | The categories of data shared will vary based on the type of corporate transaction. It may include the entire organization data or only a specific subset such as Purchase Data. |
| When profile sharing functionality is used | You may choose to share other members’ profiles and they may share yours with people outside of our service, using the sharing functionality. | Profile Data Content |
6. Cross-Border Data Transfers
Because we operate a global service, the sharing of your data laid out in Section 5 involves cross-border data transfers to our Affiliates and service providers (other third parties) in third countries that have different privacy laws. When we transfer data to a third country, we use appropriate mechanisms. For example, we rely on:
- Adequacy decisions relied on by competent authorities under applicable laws. We transfer personal data to our Affiliates to perform important functions, as outlined in Section 6, by storing, accessing, or otherwise processing data, and to third parties in countries with adequacy decisions for the purposes outlined in Section 5.
- Standard Contractual Clauses or similar contractual data transfer mechanisms approved by competent authorities under applicable laws. These contractual data transfer mechanisms are commitments between companies transferring personal data, binding them to protect the confidentiality and security of your data and ensuring adequate level of protection in third countries. We rely on such mechanisms to transfer personal data to our Affiliates to perform important functions, as outlined in Section 6, by storing, accessing, or otherwise processing data, and to third parties, for the purposes outlined in Section 5, in countries without adequacy decisions, such as the United States of America. Contact us for a copy.
7. Your Rights
We want you to be in control of your data, so we want to remind you of the following rights, options and tools available to you. Depending on where you live, these rights may not apply to you or they may be named differently. If you have any questions on your rights and how to exercise them, please contact us at the address below.
| Your Rights | How to exercise it |
|---|---|
| Access, Portability or To Know Right to be informed of the personal data we process about you and/or ask for a copy of it | You can access and review some data directly by logging into your account. You can also retrieve a copy of your data by contacting us at contact@overto.ne. |
| Rectification or Correction Right to amend or update your personal data where it’s inaccurate or incomplete | You can update your data directly within the service by simply updating your profile. If you wish to rectify other data, please contact us at contact@overto.ne. |
| Deletion or Erasure Right to delete personal data | You can request that we remove you from our waitlist and delete the corresponding personal data by contacting us at contact@overto.ne. You can also delete some of the data you provided us directly within the service. You can also close your account and we’ll delete your data as laid out in this Privacy Policy. In any event, you can always contact us at contact@overto.ne. |
| Objection (Opt-out) or Restriction Right to object to us processing personal data or to request that we temporarily or permanently stop processing personal data | You can directly opt-out from certain of your personal data processing in your account settings. Otherwise you can contact us at contact@overto.ne should you wish to object to or restrict a data processing we’ve listed throughout this Privacy Policy. |
| Consent Withdrawal Right to withdraw a consent you’ve given us to process your personal data for a specific purpose | You can opt out of receiving waitlist-related SMS or similar notifications by following the specified instructions for opting out (e.g., by directly replying “STOP” to an SMS message) or by contacting us at contact@overto.ne. You can directly withdraw consent you’ve given us either by updating your account setting or removing Device Permissions you’ve agreed to in your device settings (e.g., access to specific types of device data such as phone contacts, pictures, advertising identifiers and location services or consent to receive push notifications). When you withdraw consent, certain services may lose functionality. You can always contact us at contact@overto.ne for more information. |
For your protection and the protection of all of our members, we may ask you for information to verify your identity or authority to act on behalf of a member before we can answer the above requests. We wouldn’t want someone else to get in control of your data!
Keep in mind, we can reject requests, including if we are unable to authenticate you, if the request is unlawful or invalid, or if it could infringe on trade secrets or intellectual property or the privacy or other rights of someone else. If you wish to receive information relating to another member, the other member will have to make a request themselves.
Residents of Indiana, Kentucky, Rhode Island, Maryland, Tennessee, Minnesota, Delaware, Iowa, Nebraska, New Hampshire, New Jersey, Texas, Oregon, Montana, Virginia, Colorado, or Connecticut, USA, if we deny your privacy request, you can appeal by contacting us at contact@overto.ne, and explicitly referencing “Privacy Request Appeal.” If you have concerns about the result of your appeal, you can contact the attorney general for your state.
In certain countries, including the United Kingdom, you have a right to a judicial remedy and to lodge a complaint with the appropriate data protection authority if you have concerns about how we process your personal data. You can find information about your data protection regulator in the United Kingdom here. The data protection authority you can lodge a complaint with can be that of your habitual residence, where you work or where an alleged infringement took place.
8. How Long We Retain Your Data
We want the connections you make through our service to last forever, but we keep your personal data only as long as necessary for legitimate business reasons (as laid out in Section 4) and as permitted by applicable law.
We retain your waitlist information only as long as needed to manage the waitlist and notify you of account availability, unless you request deletion sooner.
If you decide to stop using our service, you can close your account and your profile will no longer be visible to other members, but we may retain your personal data after you close your account for the period of time needed to pursue legitimate business interests and in accordance with applicable law. For example, we may retain your personal data as necessary to evidence our compliance with applicable legal data retention obligations (including tax and accounting legal requirements), support our customer care decisions, enforce our rights and defend ourselves in the event of a claim or potential claim (including payment disputes), comply with a valid legal subpoena or request to preserve data, and prevent members who were banned from opening a new account.
Where appropriate and as legally permitted, we may maintain and use data that, by itself, cannot identify or be attributed specifically to you for the purposes described in the Privacy Policy, including to improve our service, create new features, technologies and services, including through machine learning, and keep our services safe.
9. Children's Privacy
Our service is restricted to individuals who are 18 years of age or older. We do not permit individuals under the age of 18 on our platform. If you suspect that a member is under the age of 18, please use the reporting mechanism available on the service.
10. Privacy Policy Changes
This policy will change over time. We’re always looking for new and innovative ways to help you build meaningful connections and strive to make sure explanations of our data practices remain up-to-date. We will notify you before material changes take effect so that you have time to review the changes.
11. How to Contact Us
If you have questions about this Privacy Policy or would like to make a complaint, you have different options below:
By email:
contact@overto.ne
By post:
Overtone Studios, Inc.
809 Washington St
New York, NY 10014
