Privacy Policy

1. Introduction

This Privacy Policy explains how Problaq Consulting (Pty) Ltd, trading as Verly, collects, uses, discloses, and protects personal information when you use the Verly mobile application and website at verly.co.za (collectively, the “Service”).

Because Verly’s users are located in South Africa and internationally, this Policy is designed to meet the requirements of the South African Protection of Personal Information Act 4 of 2013 (“POPIA”), the EU/UK General Data Protection Regulation (“GDPR”), and the California Consumer Privacy Act as amended by the California Privacy Rights Act (“CCPA/CPRA”). Section-specific rights for each region are set out below.

By creating an account or otherwise using the Service, you acknowledge that you have read and understood this Policy. If you do not agree with this Policy, please do not use the Service.

2. Information we collect

Information you provide to us

• Account information: name, email address, phone number (if you use phone sign-in), and authentication credentials.
• Profile content: profile photo, bio, connection intent, distance preference, current activity, and optional video introduction.
• Faith-room information: the community room you join and answers you choose to provide, such as faith affiliation, born-again status, denomination, and connection goal. These answers may reveal religious or philosophical beliefs.
• Communications: messages posted in Sneeky, safety reports, blocked-member records, and correspondence with our support or safety team.
• Early-access enquiries: if you choose to send an email request, we receive your email address and the message you send. The public request page does not submit a form or create a member profile. Launch marketing requires a separate optional opt-in; you can withdraw by replying STOP or emailing info@verly.co.za.
• Subscription information: subscription product, purchase status, and purchase token processed through Google Play. Verly does not receive or store your full card number.

Information collected automatically

• Device and usage data: IP address, device identifiers, operating system, browser type, app interactions, crash logs, and log timestamps.
• Cookies and similar technologies on our website (see Section 14).

Information from third parties

• If you register or log in with Google, we receive the account information Google provides for authentication.
• We use service providers such as Google Firebase for authentication, data storage, analytics, and app infrastructure.

3. Optional profile media

You may choose to upload a profile photo or short video introduction. These files are stored using Firebase Storage and are used to present your profile to other members.

• Uploading profile media is optional.
• Do not upload another person’s image or content you do not have permission to use.
• Profile media is deleted when you complete in-app account deletion, subject to lawful retention requirements.

4. How we use your information

• To create and manage your account and provide matching and messaging features.
• To provide profile discovery and personalize suggestions using the preferences you enter.
• To provide faith and values rooms and remember your private room-entry answers.
• To provide the subscriber-only Sneeky room and restore subscription access.
• To receive reports, apply blocks, and maintain trust and safety.
• To respond to enquiries and communicate about your account. We send promotional launch emails only when you separately opt in; you can withdraw by replying STOP.
• To detect, investigate, and prevent fraud, impersonation, underage use, harassment, and other violations of our Terms and Community Guidelines.
• To comply with legal obligations and respond to lawful requests from public authorities.
• To analyze usage trends and improve the Service.

5. Legal basis for processing

Where required by applicable law (including GDPR), we rely on the following legal bases:

6. How we share information

We do not sell your personal information to third parties for money. We may share information with:

• Other users: your profile information (excluding contact details you have not chosen to share) is visible to other users as part of the Service.
• Room participants: messages and display name you post in a community or Sneeky room are visible to participants. Your private room-entry questionnaire answers are not displayed in the room.
• Service providers: Google Firebase for authentication, storage, database, and analytics, and Google Play for subscription billing.
• Legal and safety purposes: law enforcement, regulators, or other third parties where required by law, to protect the rights and safety of our users, or to investigate policy violations.
• Business transfers: in connection with a merger, acquisition, or sale of assets, subject to confidentiality commitments.

7. International data transfers

As Verly serves users both inside and outside South Africa, your information may be transferred to and processed in countries other than your own, including countries that may have different data protection laws. Where we transfer personal information internationally, we use appropriate safeguards such as standard contractual clauses, or rely on adequacy decisions, consistent with POPIA Section 72 and GDPR Chapter V requirements.

8. Data retention

We retain personal information for as long as your account is active and as necessary to provide the Service. Following account deletion, we generally delete or anonymize personal information within 90 days, except where we are required to retain it for legal, safety, tax, or dispute-resolution purposes. Records related to a safety report or fraud investigation may be retained longer.

See the account deletion page for how to request deletion.

9. Security

We implement technical and organizational measures designed to protect your personal information, including encryption in transit, access controls, and regular security reviews. No method of transmission or storage is 100% secure, and we cannot guarantee absolute security. If we become aware of a data breach affecting your personal information, we will notify you and the relevant regulator(s) as required by applicable law (including POPIA’s Information Regulator and, where applicable, GDPR’s 72-hour breach notification requirement).

10. Your rights

Subject to applicable law, you generally have the right to:

• Access the personal information we hold about you.
• Correct inaccurate or incomplete information.
• Request deletion of your personal information.
• Object to or restrict certain processing (for example marketing).
• Request a portable copy of your data.
• Withdraw consent at any time, where processing is based on consent.
• Lodge a complaint with the relevant supervisory authority (see regional sections below).

You can exercise most of these rights directly in the app under Settings, or by contacting us at the details in Section 17.

11. South African users POPIA

If you are located in South Africa, POPIA gives you the rights described in Section 10, plus the right to object to processing for direct marketing purposes at any time, free of charge.

Information Officer: Siviwe Tengani, reachable at info@verly.co.za.

You may lodge a complaint with the South African Information Regulator: website inforegulator.org.za.

12. EU/UK users GDPR

If you are located in the European Economic Area or United Kingdom, you have the rights listed in Section 10 under the GDPR/UK GDPR, and may lodge a complaint with your local data protection supervisory authority. We have not appointed a separate EU Article 27 representative at this time. Privacy requests can be sent to info@verly.co.za.

13. California users CCPA / CPRA

If you are a California resident, you have the right to know what personal information we collect, request deletion, correct inaccurate information, opt out of the “sale” or “sharing” of personal information (Verly does not sell personal information), limit use of sensitive personal information, and not be discriminated against for exercising these rights. To submit a request, contact us using the details in Section 17 or use the in-app privacy controls.

14. Cookies and tracking

This website uses only cookies and similar technologies that are required to serve static pages and measure basic availability. We do not currently run advertising cookies or a marketing pixel on verly.co.za. You can block cookies through your browser settings.

15. Children’s privacy

Verly is intended for users aged 18 and older. We do not knowingly collect personal information from anyone under 18. If we become aware that we have collected information from a person under 18, we will delete it and terminate the associated account. If you believe a user is underage, please report them via the in-app reporting tool or contact info@verly.co.za.

16. Changes to this policy

We may update this Privacy Policy from time to time. If we make material changes, we will notify you via the app or by email before the changes take effect. Continued use of the Service after changes take effect constitutes acceptance of the updated Policy where permitted by law.

17. Contact us