Document 1

SureKeep Privacy Policy

Last updated: June 2026 · Effective date: June 2026

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1. About this Policy

This Privacy Policy explains how SureKeep Inc ("SureKeep," "we," "us," or "our"), the operator of the SureKeep mobile application (the "App"), collects, uses, shares, and protects information about you when you use the App.

SureKeep is a privacy-first, location-aware messaging app designed to let you discover and chat with people near you without creating a traditional account. Our guiding principle is to collect as little personal information as possible to make the App work.

By using SureKeep, you agree to the practices described in this Policy. If you do not agree, please do not use the App.

2. Who We Are

• Operator / Personal Information Controller: SureKeep Inc
• Registered address: Cebu City
• Email for privacy concerns: privacy@surekeep.xyz
• Data Protection Officer (DPO): SureKeep Officer, legal@surekeep.xyz

If you live in the Philippines, you may also contact the National Privacy Commission (NPC) at https://privacy.gov.ph if you believe we have not adequately addressed your concerns.

3. Information We Collect

We collect only what we need to operate SureKeep.

3.1 Information you provide directly

• Anonymous user identifier (UUID). When you first launch the App, your device generates a random unique identifier. This UUID is the only mandatory identifier — you do not provide a name, email, or phone number to use SureKeep.
• Optional profile information. You may add a nickname, age, sex, and a short status. All fields are optional and you may leave them blank or change them anytime.
• Messages you send. When you message another user, the content passes through our servers to be delivered.
• Photos and videos you send. If you attach a photo or video to a message, or set a profile picture, that media is uploaded to our cloud storage so it can be delivered or displayed. We only access your camera and photo library when you actively choose to attach or capture media; we do not access them in the background.
• Reports. If you report another user, we collect the reason you provide (if any) and the identifier of the reported user.
• Optional account linking. If you link a Google or Facebook account to preserve your identity across reinstalls, we receive a verified user ID from that provider and store it associated with your UUID. We do not receive your password.

3.2 Information collected automatically

• Approximate location (GPS). While you are using the App and have granted location permission, we collect your device's coordinates so we can show you on the map and find nearby users. Location is only used while the App is active; we do not track location in the background.
• Presence data. We track whether your device is currently connected to our service so we know when to deliver messages versus queue them.
• Device and technical data. Basic technical information such as IP address, device type, OS version, and App version.
• Diagnostics and crash logs. Anonymized crash data may be sent to help us fix bugs. This does not include the content of your messages.

3.3 Information we do not collect

• We do not require your real name, email address, or phone number.
• We do not read or permanently store the content of your messages on our servers (see Section 5).
• We do not access your contacts.
• We do not access your camera, photo library, or microphone unless you choose to attach or capture media to send (see Section 3.1).
• We do not track your behavior across other apps or websites.
• We do not use third-party advertising trackers or sell your data to advertisers.

4. Why We Collect This Information (Lawful Basis)

Under the Philippine Data Privacy Act, we process your information based on:

• Performance of a service you've requested — your UUID, location, and presence data are needed for the App's core function.
• Your consent — for optional information (nickname, age, sex, status, linked OAuth accounts), which you may give or withdraw anytime.
• Legitimate interests — for security, fraud prevention, abuse detection, and improvement of the App, balanced against your right to privacy.
• Legal obligation — when we are required by Philippine law to retain or disclose information.

5. How We Handle Messages

Messages are designed to be ephemeral on our infrastructure:

• Messages are not permanently stored on our servers. When you send a message, we route it to the recipient and do not keep a long-term server-side copy.
• Offline queue. If the recipient is not currently online, we hold your message in a temporary server-side queue for up to seven (7) days so it can be delivered when they reconnect. After delivery, or after seven days (whichever comes first), the queued message is deleted.
• Local storage on your device. Sent and received messages are stored on your own device in a local database. This local history is not synced to our servers or to any cloud. If you uninstall the App or clear its data, your local history is permanently lost.

6. How We Use Your Information

We use the information we collect to:

• Operate the core functions of the App (showing nearby users, delivering messages, displaying profiles).
• Maintain the security and integrity of the App and detect and prevent abuse, spam, harassment, and other Terms violations.
• Investigate user reports and enforce our Terms.
• Respond to your inquiries and provide support.
• Comply with applicable law and lawful requests.
• Improve the App's reliability, performance, and user experience.

We do not use your information for behavioral advertising or sell it to third parties for marketing.

7. Who We Share Your Information With

We share information only in these limited cases:

• Other SureKeep users. When you appear on the map, other nearby users see whatever profile information you have chosen to make visible (nickname, age, sex, status), along with your approximate location and online status. If you turn off map visibility in Settings, you will not appear on others' maps.
• Service providers. We use trusted infrastructure providers — including Amazon Web Services (cloud hosting in Singapore) and Mapbox (map tiles) — who process information on our behalf under contractual confidentiality and security obligations.
• OAuth providers. If you link Google or Facebook, we exchange limited information with that provider as needed to verify your identity. Their handling of that information is governed by their own privacy policies.
• Law enforcement and legal compliance. We may disclose information if required by a valid Philippine court order, subpoena, or other legal process, or where we believe disclosure is necessary to protect rights, safety, or property.
• Business transfers. If SureKeep is acquired, merged, or transferred, your information may be transferred as part of that transaction. You will be notified of any change in ownership materially affecting how your data is handled.

We do not sell your personal information.

8. International Data Transfers

Our servers are hosted in Singapore (AWS ap-southeast-1). If you use SureKeep from the Philippines, your information will be transferred to and processed in Singapore. We rely on standard contractual safeguards to protect data during transfer.

9. How Long We Keep Your Information

10. Your Rights

Under the Data Privacy Act of 2012, you have the following rights:

• Right to be informed about how we process your information (this Policy).
• Right to access the personal information we hold about you.
• Right to correct inaccurate or outdated information.
• Right to erasure or blocking — you may ask us to delete your account and associated data.
• Right to object to certain processing activities.
• Right to data portability — you may request a copy of the data you have provided.
• Right to file a complaint with the National Privacy Commission.
• Right to damages for any harm caused by unlawful processing.

To exercise any of these rights, email privacy@surekeep.xyz. We will respond within a reasonable time, generally no later than fifteen (15) business days. We may need to verify your identity (for example, by asking you to confirm your UUID from within the App) before acting on a request.

11. How to Delete Your Data

• Uninstall the App. This removes your local message history immediately.
• Request deletion. Email privacy@surekeep.xyz from a means we can verify, and we will delete your server-side records (UUID, profile, linked accounts, blocks, reports).
• After deletion, your UUID and profile cannot be recovered. Linked Google or Facebook identifiers will also be removed.

12. Security

We use industry-standard security measures, including:

• Encrypted connections (TLS 1.2+) between the App and our servers.
• Restricted server access controlled by SSH keys and firewalls.
• Strong, randomly generated credentials for our infrastructure.
• Routine security updates of operating system and software dependencies.

No system is perfectly secure. If we experience a data breach affecting your information, we will notify you and the National Privacy Commission as required by Philippine law.

13. Children and Minors

SureKeep is intended for users thirteen (13) years of age or older. By using the App, you represent that you meet this age requirement.

If you are between 13 and the age of legal majority in your jurisdiction, you should review this Policy and our Terms with a parent or guardian, and use the App only with their permission.

We do not knowingly collect information from children under 13. If we learn that we have inadvertently collected information from a child under 13, we will delete it. If you believe a child under 13 has provided us information, please contact privacy@surekeep.xyz immediately.

14. Permissions Used by the App

You may revoke any permission at any time in your device settings. Revoking required permissions will limit or disable parts of the App.

15. Third-Party Services

SureKeep relies on third-party services. Each has its own privacy policy:

• Amazon Web Services (AWS) — https://aws.amazon.com/privacy/
• Mapbox — https://www.mapbox.com/legal/privacy
• Google Sign-In (optional) — https://policies.google.com/privacy
• Facebook Login (optional) — https://www.facebook.com/privacy/policy/
• Apple App Store / Google Play Store — each has its own privacy policy.

We are not responsible for the practices of these third parties; we encourage you to review their policies.

16. Cookies and Similar Technologies

SureKeep is a mobile app and does not use browser cookies. It stores small pieces of data on your device using standard mobile storage mechanisms (secure storage for your UUID and access token, and a local database for message history). These are necessary for the App to work.

17. Changes to this Policy

We may update this Policy from time to time. When we make material changes, we will notify you within the App and update the "Last updated" date at the top. Continued use of the App after a change means you accept the updated Policy.

18. Contact

• Email: privacy@surekeep.xyz
• Postal mail: Cebu City
• Data Protection Officer: SureKeep Officer, legal@surekeep.xyz

You may also file a complaint with:

— End of Privacy Policy —