Kuwboo Privacy Policy

Effective date: 15 April 2026 · Last updated: 15 April 2026

1. Who we are

Kuwboo is operated by Guess This Ltd, a company registered in the United Kingdom. In this policy, "Kuwboo", "we", "us", or "our" refers to Guess This Ltd.

Guess This Ltd is the data controller for personal data processed through the Kuwboo mobile app and website. Contact details are in Section 13.

2. What we collect

We collect only what we need to run Kuwboo. The categories below reflect the features enabled in your account.

CategoryExamplesWhen collected
Account identifiersPhone number, email address, Apple/Google sign-in ID, username, date of birthAt sign-up and when you sign in
Profile contentDisplay name, bio, photos, interests, module preferences (video, marketplace, dating, social)When you complete your profile
User-generated contentVideos, images, posts, marketplace listings, comments, reviewsWhen you post
CommunicationsChat messages, group conversations, voice notes, reports you file against other usersWhen you use chat or moderation tools
Location dataApproximate city (IP-derived) always; precise GPS only with your explicit permission (used for nearby discovery and event proximity)While the app is in use
Transaction dataPurchase history, listing prices, payment timestamps. We do not store card numbers — payments are processed by our payment providerAt checkout
Device and log dataDevice model, OS version, app version, crash logs, IP address, session timestamps, languageAutomatically, for security and reliability
Age assurance signalsSelf-declared age, optional age-estimation signals (if you opt in to photo-based verification)Per UK and US child-safety law (see Section 9)
Biometric-derived dataFace-match templates, if you opt in to photo verification. Raw photos are not retained after template generation.Only if you enable photo verification
Cookies and similarSession cookies on our website. The mobile app does not use web cookies.When you visit our website

We do not sell personal data, and we do not collect sensitive categories of data (race, religion, political opinions, health) unless you voluntarily post them as profile content.

3. How we use your data

Under UK GDPR, each processing activity needs a lawful basis:

5. Who we share data with

We require all processors to meet UK GDPR / EU GDPR standards via data-processing agreements. We do not sell or rent personal data to advertisers, data brokers, or any third party.

6. How long we keep data

Data typeRetention
Active account dataFor as long as your account exists
Deactivated account (partial deletion)Up to 30 days, then moves to full deletion unless you reactivate
Deleted account — personal identifiersPurged within 30 days of full-deletion request
Deleted account — legal/financial records6 years (UK Companies Act / HMRC requirement for transaction records)
Deleted account — messages sent to othersRemain in the recipient's inbox, attributed to "Deleted user". Your identifier is removed.
Content under active moderation or legal holdUntil the investigation closes, then per the row it belongs in
Aggregated, anonymised analyticsIndefinitely — no longer personal data
Device and log data90 days, then purged or anonymised
Crash reports90 days

7. Your rights (UK GDPR / EU GDPR)

You have the right to:

To exercise any of these rights, email us at neildouglas33@hotmail.co.uk. We respond within 30 days; complex requests may take up to 90 days with notice.

8. Deleting your account

You can delete your Kuwboo account at any time. We offer two options:

Full instructions and the in-app path are on our Delete Account page.

9. Children and age verification

Kuwboo is not for children under 13 (USA, COPPA) or under 16 for certain features in the UK and EU. We apply age assurance per the UK Online Safety Act and the ICO Age Appropriate Design Code:

10. US state privacy rights

If you are a resident of California, Colorado, Connecticut, Virginia, Utah, or other US states with comprehensive privacy laws, you have rights similar to those in Section 7: to know what we collect, to delete it, to correct it, to receive a copy, and to opt out of any sale or sharing for targeted advertising. We do not sell personal data and do not share it for cross-context behavioural advertising.

If you are a resident of Illinois and you opt in to photo-based verification, you are consenting to the collection and use of biometric-derived data under the Illinois Biometric Information Privacy Act (BIPA). Biometric templates are deleted within 3 years of your last login or when you delete your account, whichever is sooner. You may revoke this consent at any time in the app settings or by emailing us.

To exercise US rights, email neildouglas33@hotmail.co.uk. We verify your identity before acting on the request.

11. Security

We protect your data with TLS in transit, encryption at rest (AES-256), scoped-access credentials managed in AWS Secrets Manager, and least-privilege access controls. Chat messages are transport-encrypted; they are not end-to-end encrypted at this time. No system is perfectly secure — if we ever have a breach that affects you, we will notify you and the ICO as required by UK GDPR (within 72 hours).

12. International transfers

Our primary data residency is the United Kingdom (AWS eu-west-2, London). Some processors (e.g., Apple, Google, Firebase) may process data in the United States. We rely on UK International Data Transfer Agreements and EU Standard Contractual Clauses for these transfers, together with the provider's own safeguards.

13. Contact

Guess This Ltd
Email: neildouglas33@hotmail.co.uk
Data Protection Officer enquiries: same email, subject line "DPO".

For complaints you can also contact the UK Information Commissioner's Office: ico.org.uk/make-a-complaint.

14. Changes to this policy

We may update this policy from time to time. If we make a change that materially affects your rights, we will notify you in the app and by email. The "Last updated" date at the top of this page always shows the current version. Previous versions are available on request.