Privacy Policy

This Privacy Policy explains how Odds Made Us (OMU) (the “App”) and its associated website and services (collectively, the “Service”) collect, use, store, disclose and protect personal data. The Service is operated by Odds Made Us(“OMU”, “we”, “us” or “our”). This Privacy Policy should be read together with our Terms of Service. By using the Service, you acknowledge the data practices described here. Where applicable law requires a separate notice or consent, your use of the Service alone will not replace that requirement.

The Service is intended for people aged 18 or over. The English version of this Privacy Policy is the authoritative version.

1. Scope and Definitions

1.1 Personal Data. “Personal Data” means information relating to an identified or identifiable individual. It may include account details, profile information, communications, game activity, technical information and other information described below.

1.2 Anonymised Data. “Anonymised Data” means information processed so that an individual can no longer reasonably be identified. Information that is merely pseudonymised, such as information linked to a replaceable account identifier, may still be Personal Data.

1.3 Applicable law. Odds Made Us primarily operates with Hong Kong users in mind. Our handling of Personal Data is subject to the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong (“PDPO”) and other laws where they apply.

2. Information We Collect

2.1 Registration and account details. We collect information necessary to create, authenticate and operate your account, including your login identifier, the information made available by your chosen sign-in method, and your birth date or age confirmation. Account and age-related information required by the registration process must be provided to create an account; without it, we may be unable to offer the Service.

2.2 Profile information. We collect the details you enter or upload to your profile, including photos, display name, age, gender, city, hometown, height, education, degree, school, occupation, biography, self-introduction answers, relationship goal, dating style, interests, values, personality and lifestyle preferences. Except for information expressly required by the App, providing additional profile information is optional, but omitting it may affect how parts of the Service work.

2.3 Public and private profile fields. Depending on where your profile appears within the Service, other users may see the following fields that you choose to provide: profile photos, display name, age, gender, city, hometown, height, education, degree, school, occupation, biography, self-introduction answers, relationship goal, dating style, interests, values, personality, exercise habits, and smoking and drinking preferences. Your ethnicity, religion, whether you have children, marital status, private filter and deal-breaker preferences, and login credentials are not displayed as public profile fields. Your filters may affect which profiles the Service shows you. Blocking another user restricts future visibility within the Service but cannot undo information already seen or copied by that person.

2.4 Games and Sync Scores. We process the rooms you join, the game level, questions displayed, answers selected, participation records and resulting Sync Scores. A Sync Score represents the proportion of matching answers to questions both players answered in the same game. If there are too few common answers or a player leaves early, a score may not be produced. A Sync Score is a game result, not an assessment or guarantee of personality or relationship compatibility.

2.5 User interactions. We process hearts sent and received, user connections (called “Soulmates” in the App), blocks, reports and relevant interaction records. “Soulmate” is an in-app label, not a certification or representation of compatibility.

2.6 Messages, reports and safety information. We store and process chat messages to deliver them and maintain conversation history. We may access and review relevant messages, game records, account records and reports when reasonably necessary to investigate suspected fraud, impersonation, harassment, abuse, safety incidents, complaints or breaches of our Terms of Service, and to protect users, the Service and our legal interests. Such access is restricted to authorised persons and service providers with a need to know.

2.7 Technical and usage information. We may automatically collect device and operating-system information, App version, language and settings, IP address, sign-in and security events, feature-use records, crash reports and diagnostic logs, to operate, secure and improve the Service. An IP address may indicate an approximate network location; this is different from the optional device-location processing described in Section 3. We do not use technical logs to retain a history of Nearby grid cells or exact distances between users.

2.8 Communications and support. We collect information you provide when contacting us, reporting a problem, exercising a privacy right or responding to a Service notice, including your contact details and the content of the correspondence.

2.9 Data we do not routinely request. The Service does not currently offer paid features, and we do not request identity documents or payment-card details as part of ordinary registration. If those practices change, we will update our disclosures as required.

Please avoid disclosing phone numbers, home addresses, identity documents or other sensitive information in public fields or messages unless you are comfortable with the associated risks.

3. Device Location and Nearby

3.1 Current availability. Nearby is not part of the currently available Service. The provisions below explain its intended privacy protections if it is introduced; we will update this Policy as necessary before release. Simply using the currently available Service does not activate Nearby or require device-location permission.

3.2 Optional and mutual participation. If introduced, Nearby will be off by default and will require both an in-app opt-in and the relevant device permission. Only users who have also enabled Nearby will be eligible to appear to one another through that feature.

3.3 Location processing. The intended design checks device location only while the App is open and the user accesses Explore, without background location tracking. The device converts precise coordinates locally into an approximate grid cell of about 1 km; only the grid-cell identifier is intended to reach our servers, not the precise coordinates.

3.4 What other users see. The intended feature displays approximate distance bands only: within about 10, 20, 40, 80, 160, 240, 320 or 500 km. Other users will not be shown your precise coordinates, grid-cell identifier or exact distance. Estimates can be inaccurate, including because of grid boundaries or altered device locations.

3.5 Retention and control. Under the intended design, only the latest grid-cell record is retained in active systems, is valid for 24 hours and is removed from active systems within 25 hours. Turning Nearby off, withdrawing permission when detected, or deleting your account will trigger removal from active Nearby use. Backup handling is described in Section 7.6. The shorter Nearby retention rule will not be replaced by the general 12-month post-closure rule.

4. How We Use Personal Data

We use Personal Data, to the extent necessary and permitted by law, to:

• register, authenticate and manage accounts, including age eligibility;
• operate game rooms, questions, results, Sync Scores, Explore recommendations, hearts, connections, blocks and chat;
• show suggested profiles based on the relevant interests, relationship goals and filters provided through the App;
• detect, investigate and prevent fraud, spam, harassment, impersonation, abuse, technical attacks and other prohibited conduct;
• review reports, enforce our Terms of Service, manage bans, resolve disputes and preserve evidence where reasonably necessary;
• maintain security, diagnose faults, measure performance and develop or improve the Service;
• handle support requests and send necessary account, safety and service communications;
• comply with legal obligations, respond to lawful requests and establish, exercise or defend legal claims; and
• perform other purposes directly related to the purposes notified to you, or other purposes for which any legally required consent has been obtained.

We do not represent Sync Scores or profile suggestions as determinations of real-world compatibility, and do not use them to make decisions producing legal or similarly significant effects. We will not use or provide Personal Data for direct marketing without first meeting applicable legal notice and consent requirements. Optional marketing communications, if offered, will have an appropriate opt-out process.

5. Analytics and Similar Technologies

5.1 We may use analytics, diagnostic tools and pseudonymous identifiers to understand aggregate feature usage, service performance and errors. Pseudonymised data remains subject to this Policy where it can reasonably be linked to an individual. We do not place device-derived Nearby grid cells, precise coordinates or exact inter-user distances in analytics datasets.

5.2 The App may use on-device storage and similar technologies for authentication, preferences, operation and security. If our website uses cookies or comparable technologies, relevant notices and choices will be provided as required by law.

5.3 We do not sell Personal Data. We do not use cross-app tracking or disclose Personal Data to advertising networks for targeted advertising as part of the currently described Service. If advertising or tracking practices change, we will provide any required disclosures or choices before introducing them.

6. Disclosure and Sharing of Personal Data

6.1 Other users. Users can view the public profile fields made available to them, game results and Sync Scores shared through the App, relevant hearts and connections, and messages sent to them. Information you disclose to another user may be copied, saved, captured or shared outside the Service. We cannot control independent actions by recipients after disclosure, although we may take reasonable steps in response to reported misuse. Nothing in this clause excludes our own obligations under applicable law.

6.2 Service providers. We may provide Personal Data to service providers supporting hosting, databases, account authentication, communication delivery, security, crash reporting, analytics, customer support and content moderation. They are required, through appropriate contractual or other safeguards, to process the data for authorised purposes and protect it. We remain responsible for obligations imposed on us by applicable law.

6.3 Safety, legal matters and authorities. We may preserve, use or disclose relevant information where reasonably necessary and permitted or required by law to comply with a valid legal process or request, investigate suspected unlawful conduct or policy violations, prevent fraud and threats to safety, protect the rights or property of Odds Made Us or others, or establish, exercise or defend legal claims. Disclosures will be assessed against applicable legal requirements.

6.4 Business transactions. Information may be disclosed under appropriate safeguards in connection with a proposed or completed merger, acquisition, corporate restructuring, financing, asset sale or transfer of the Service, where relevant and lawful. A successor operator must handle transferred Personal Data in accordance with applicable law and relevant privacy obligations.

6.5 External services. Links to independent websites or apps are governed by their own terms and privacy practices. We do not control those independent services and are not responsible for their independent acts or omissions, except to the extent applicable law provides otherwise.

6.6 No sale. We do not sell your Personal Data.

7. Retention, Inactivity and Account Deletion

7.1 General principle. We retain Personal Data only for as long as reasonably necessary for the purpose for which it was collected, related purposes, protection of users and legitimate business interests, or compliance with applicable law. Retention is reviewed by data category and purpose; this Policy does not require us to keep every item for the maximum period.

7.2 Closure after 24 months of inactivity. We may close an account that has not been logged into for a continuous period of 24 months (the “Inactivity Period”). We will send a notice to the email address registered or associated with the account at least 30 days before closure, allowing you to log in and keep the account active. If the account is closed, Section 7.3 applies.

7.3 Standard 12-month post-closure retention. Following account closure, including closure requested by you, closure for inactivity or a ban, our standard post-closure retention period for relevant Personal Data is 12 months. During that period, we may retain records reasonably necessary to investigate unlawful or improper use, prevent repeat abuse or fraud, address reports and complaints, protect users and our business, enforce our Terms of Service, and establish, exercise or defend legal claims. Data no longer needed for a lawful purpose will be erased or effectively anonymised earlier where appropriate. Retained records will be subject to restricted access and will not be used to reactivate a deleted public profile. The specific shorter rule for Nearby in Section 3 takes precedence.

7.4 Extended legal retention. We may retain specific Personal Data beyond 12 months where reasonably necessary for actual or reasonably anticipated legal proceedings, regulatory investigations or enforcement; the establishment, exercise or defence of legal claims; or compliance with a valid subpoena, court order or binding request by a competent authority. We will limit the retained data and retention period to what remains necessary or legally required, review the need periodically and delete or effectively anonymise it when that basis ends.

7.5 Account deletion requests. You may request account deletion using the in-app deletion function, including its confirmation step, or by contacting us here. We will close access to your account and remove the public profile from active discovery, then delete or anonymise associated Personal Data in accordance with our deletion procedures, except for specifically necessary and lawful retention under Sections 7.3 and 7.4. Deactivation alone is not treated as account deletion. Messages already delivered may remain in other users’ conversation histories or copies they retained, depending on the relevant functionality and applicable law. Data preserved solely for investigations or legal purposes will remain access-restricted.

7.6 Backup copies. Residual information may remain in encrypted or access-restricted operational backups until they are securely overwritten or deleted under our backup lifecycle. Backups are used for recovery, security and continuity, not for ordinary user access. If a backup is restored, we will reapply relevant deletion restrictions. An active-system deletion deadline, including any Nearby deadline, does not by itself guarantee removal from all backup copies by the same time.

7.7 Category-specific retention. Account and profile records, game participation and scores, chats and interaction records are generally maintained while relevant to an active account and Service functionality, then handled under Sections 7.3–7.5 after closure. Reports, ban records and evidence are retained only for necessary safety, enforcement or legal purposes. Technical and diagnostic records are retained for operational and security needs and removed or anonymised when no longer required. Nothing in this Section overrides a shorter category-specific limit or an applicable legal duty.

7.8 Anonymised data. We may retain and use genuinely anonymised and aggregated information that can no longer reasonably identify anyone for statistics, research, security analysis, product development and Service improvement. Pseudonymised information that remains reasonably identifiable continues to receive applicable Personal Data protections.

8. Security

We use reasonable technical and organisational measures appropriate to the nature of the data, such as encrypted data transmission, authentication safeguards, restricted staff and service-provider access, security monitoring and data minimisation. No network or storage system is entirely secure, and we cannot guarantee absolute security. We will respond to security incidents and make notifications to affected individuals or authorities where required by applicable law.

9. Your Rights and Choices

9.1 Subject to applicable law, you may request access to, or correction of, Personal Data we hold about you; request account deletion; and withdraw consent where processing is based on consent. You may edit available profile fields and manage blocks and other in-app preferences. Withdrawing consent for an optional feature will not, by itself, remove access to unrelated features. If essential account data can no longer lawfully be processed, we may be unable to continue the relevant Service.

9.2 You may contact us here to exercise your rights. We may ask for reasonable identity verification. We will respond within the time required by applicable law; under the PDPO, data access and correction requests generally must be handled within 40 days, subject to lawful exceptions. A fee for a data access request may be charged only where permitted by law.

9.3 Where direct marketing is offered, you may opt out in accordance with applicable law. You may lodge a complaint with the Office of the Privacy Commissioner for Personal Data in Hong Kong, or another competent supervisory authority where applicable.

10. Underage Users

The Service is for individuals aged 18 or over. We do not knowingly allow persons under 18 to register. If we become aware that an account belongs to a minor, we may suspend or close it and remove the associated information, subject to necessary safety, legal and record-preservation obligations. Concerns about underage users may be reported through the App or here.

11. International Data Processing

The Service is primarily intended for users in Hong Kong. Providers supporting the Service may access, store or process Personal Data outside Hong Kong. Where cross-border processing occurs, we will take reasonable contractual, technical and organisational measures appropriate under applicable law. Using the Service from outside Hong Kong does not remove rights or protections that mandatory local law provides.

12. Changes, Governing Law and Disputes

12.1 Changes to this Policy. We may revise this Privacy Policy to reflect changes in the Service, business operations, security practices, data processing or law. If we make material changes, we will post the revised Privacy Policy on the relevant page and update its effective date. You are responsible for checking this Privacy Policy regularly for updates. We do not promise advance individual or in-app notice of every revision unless applicable law requires it. Where a change requires separate notice, consent or another legal step, we will comply with that requirement before relying on the change.

12.2 Governing law. To the extent permitted by applicable law, this Privacy Policy is governed by the laws of Hong Kong. Questions or disputes about our handling of Personal Data should first be directed here so that we have an opportunity to address them in good faith. If a dispute cannot be resolved, the courts of Hong Kong will have jurisdiction, subject to any mandatory rights or forums provided by applicable law. Nothing here limits your right to complain to a regulator, seek urgent relief or exercise non-excludable statutory rights.

End of Privacy Policy