What we collect, and exactly why.

Freeborn is operated by Coldtruths Technologies, a sole proprietorship. Coldtruths Technologies is the data controller for everything described in this policy, which means it decides why and how your personal data is processed and it is answerable for it.

Freeborn is run by one person. There is no data protection officer, because there is no team large enough to require one. That is not an excuse for less care; it means the person you contact is the person responsible. Write to support@freeborndating.com and you reach the controller directly.

The table below is the complete list. If a category of data is not in this table, we do not collect it.

We do not collect: government identification documents, national insurance or social security numbers, payment card data, contacts from your phone, precise location history, or anything from your device beyond what the table lists.

Vaccination status, health-related lifestyle information and a facial image used for identification are classified as special category data under Article 9 of the UK and EU GDPR, and receive equivalent protection under other laws including the Nigerian Data Protection Act 2023 and, in California, the CPRA. They cannot be processed on the ordinary bases. We process them on the basis of your explicit consent.

Concretely, that means:

• You are asked separately, in plain language, before either is collected. It is not bundled into accepting these terms.
• Both are optional. You can use Freeborn with an unverified profile and with no vaccination status shown. Choosing not to consent does not lock you out of matching or messaging.
• You can withdraw consent at any time from Settings. Withdrawing removes the data; it does not undo anything already lawfully done with it before you withdrew.
• Withdrawing consent for your verification image removes the teal verified seal from your profile, because the seal is a claim we can no longer support.

Discovery is controlled by you and enforced on the server, not hidden with styling. Other signed-in members can see the profile fields you published, your first or chosen display name, your age in years, your city, a distance in kilometres, and your verification status.

They cannot see, through any surface we provide:

• Your email address.
• Your full date of birth. Age is derived; the date is not published.
• Your surname, unless you chose to put it in your display name.
• Your exact coordinates. Only a calculated distance is exposed, and if you enable hide distance the value is withheld on the server rather than blurred in the browser.
• Your messages, matches, likes or reports.
• Your verification selfie. It is never served to another member through any route.
• Whether you are in incognito, paused or hidden. Those settings remove you from other members’ discovery results entirely.

Profile data is only returned to authenticated sessions that pass your discovery settings. It is not a public directory and it is not crawlable. Both profile endpoints refuse anonymous requests outright, and neither one will show you a member who is hidden, snoozed, incognito, or who has blocked you. The public discovery preview requires an account for the same reason.

Freeborn ranks and filters candidates using the preferences you set: age range, distance, genders shown, intentions, and whether to see verified members only. That is a filter you configured, applied to fields you published. It is not an opaque recommendation model, there is no compatibility percentage, and no machine learning model decides who you are shown beyond the filters you chose.

Two automated systems do make judgements about you, and you should know their limits:

• Identity verification. Two independent AI models compare your selfie to your profile photographs. The system is deliberately moderate: it hard-rejects only objective failures such as no face detected, unusable light, or a clearly different person. Anything doubtful is escalated rather than decided.
• Report triage. Two models from different providers assess reported content against observable evidence only. They never read your private conversations. A report on its own never suspends anyone.
• In both cases, anything the models do not agree on is held rather than decided. It is never resolved by whichever model answered last, and doubt is never resolved against you by default.
• There is no review queue inside the product today. An unresolved verification request sits as pending until an operator reads it, which in practice means until you write to support@freeborndating.com. That is a real limitation of a one-person platform, and it is stated here rather than dressed up as a process that does not exist.
• Every suspension can be appealed at /appeal.

This is the most sensitive thing we hold, so it gets its own clause rather than a line in a table.

An earlier version of our safety page claimed that “nothing is stored but the verdict”. That was not accurate and it has been corrected. Here is what actually happens:

• When you submit, the selfie is stored in our database and in a private storage bucket that is not publicly readable and not publicly listable.
• It is transmitted to two external AI providers so two independent models can compare it against your profile photographs. See clause 8.
• If you are approved, the image is retained while your account exists. This is not hoarding: when you later upload a new face photograph, the system re-reads your approved selfie to confirm the new photo is still the same person, and revokes the seal if a running check cannot confirm it; if the check is unavailable, verification is left untouched. Without retention that check is impossible.
• If you are rejected, the image is never written to the database at all. The verdict and the reason are kept so you can be told what failed. The face is not kept, because nothing ever reads it again: an appeal does not use it, and a retry is a fresh attempt with a fresh photograph.
• If a request is left undecided, its image is held, because it cannot be assessed without being seen. We hold at most one undecided selfie per member at any time. Starting a new attempt releases the photograph attached to the previous one and keeps only its verdict and reason.
• If you delete your account, the selfie goes with it, including the copy in the storage bucket.
• If you withdraw consent without deleting your account, the selfie is deleted and your seal is removed.

We do not build biometric templates, embeddings or face vectors, and we do not run a face recognition database across members. The comparison is a one-to-one check between your selfie and your own photographs, performed at the moment you verify.

We do not sell personal data, we do not share it with advertisers, and we do not share it with data brokers. The following processors handle data on our behalf, because a dating service cannot run without them.

Our infrastructure is in the United States. If you use Freeborn from the UK, the EU, Switzerland or Nigeria, your data is transferred out of your jurisdiction.

For transfers out of the UK and EU we currently rely on the processors’ own standard contractual terms where they offer them. For the two AI providers named in clause 8 we have no transfer mechanism in place at all, which is the same gap and the same remedy. This is stated rather than papered over with a general assurance.

We have no fixed maximum lifetime for an active account and we do not delete data from members who are simply inactive, because a person returning after a year should find their matches still there. If that changes, this clause changes with it and the version number above moves.

Depending on where you live you have some or all of the rights below. We honour all of them for everyone regardless of jurisdiction, because running two standards is how members get treated unequally.

• Access and export. Settings has a data export. It produces a scoped copy of your own data. Nothing is gated behind an email request or an identity interrogation.
• Correction. Every profile field is editable by you at any time. If something is wrong that you cannot edit yourself, email us.
• Deletion. Settings, danger zone, delete. Deletion removes your profile, photographs, messages, chat media, matches, likes, reports, security events, sessions, verification records and selfies, and it removes your authentication account, refresh tokens and identities from the auth system. It is immediate and it is not reversible.
• Withdraw consent. Turn off verification or clear your health fields in Settings at any time.
• Object and restrict. Email us. We will stop the processing you object to unless we can show a compelling legitimate ground, which we will explain to you in writing rather than assert.
• Complain. To your local regulator. In the UK that is the Information Commissioner’s Office. In the EU, your national authority. In Nigeria, the Nigeria Data Protection Commission. In California, the CPPA. You do not need our permission and we will not ask you to explain why.

To exercise any right by email, write to support@freeborndating.com. We answer within 30 days and normally much faster. We will ask you to confirm you are signed in to the account concerned, because verifying who is asking is the entire point of not handing your data to a stranger.

Covered in full in the Cookie Policy. The summary: we set authentication cookies so your session works, and we register a service worker so the app can be installed. There are no advertising cookies, no cross-site trackers and no analytics cookies.

All traffic is served over TLS with HTTP Strict Transport Security and preload enabled. Passwords are hashed by the authentication provider and are never readable by us. Database access runs through a connection pooler with TLS. Sessions use rotating refresh tokens, so a stolen refresh token is detectable. Uploads are restricted by MIME type and size, and rate limited.

Row-level security is enabled on every table in the database. The application itself connects with an administrative role that bypasses those policies, so the application code is the operative access control and we treat it accordingly.

No system is unbreachable and anyone who tells you otherwise is selling something. If we suffer a breach that creates a high risk to your rights, we will tell the relevant regulator within 72 hours of becoming aware of it and we will tell you directly, without waiting for you to notice.

Freeborn is for adults aged 18 and over. We do not knowingly collect data from anyone under 18 and the service is not directed at children.

Date of birth is required during onboarding and is validated on the server, not only in the browser, with a database-level constraint behind it. If we learn an account belongs to someone under 18 we delete the account and its data. If you believe someone under 18 is using Freeborn, tell us at support@freeborndating.com.

Version 1.1, effective 13 November 2026. Version 1.0 was first published on 19 October 2026.

1.1 changes who this policy names and where you write to us: the operator is identified by its trading name, Coldtruths Technologies, and contact moves from a personal inbox to support@freeborndating.com. Nothing changed about what is collected, why, who can see it, or how long it is kept.

When we make a substantive change we will update the version number and the effective date at the top of this page, and where the change affects how your existing data is used we will tell you in the product before it takes effect rather than after. Minor corrections to wording do not move the version number.

Coldtruths Technologies (sole proprietorship), operating Freeborn.

Email support@freeborndating.com.

If you are in the UK or EU and are not satisfied with our answer, you can complain to the Information Commissioner’s Office or your national supervisory authority. If you are in Nigeria, to the Nigeria Data Protection Commission. If you are in California, to the California Privacy Protection Agency. We will not treat any of that as hostility. A regulator exists because a platform should not be the final word on its own conduct.