1. INTRODUCTION
Red Feather Industries, a trade name of Fleet Lifestyle LLC ("we," "us," "our"), operates the Evara dating app ("App"). This Privacy Policy explains how we collect, use, share, and protect your personal information. By using Evara, you consent to the practices described in this policy.
2. INFORMATION WE COLLECT
a. Information You Provide
- Phone number, used to verify your account via SMS one-time passcode
- Name, date of birth, gender, and other profile details
- User-inputted traits and preferences used for matching
- Photos and media you upload
- Messages and communications with other users, and with Ocean, our AI assistant
- Your name and email address, if you choose to register or sign in using Sign in with Apple or Google Sign-In
- Device contacts, if you choose to use the My Circle feature and grant Evara permission to access your contacts (see Section 6)
b. Information We Collect Automatically
- Device identifiers (e.g., device ID, advertising ID)
- Precise location data (GPS), if you grant permission — used to verify you're in an active launch market and to power location-based features like nearby events
- Log data (IP address, app activity, crash reports)
- Usage data (features accessed, time spent, interactions)
- An account identifier (user ID) that we use to associate the above with your account
- Purchase history for in-app purchases and subscriptions, as reported to us by Apple (we never receive your payment card details)
c. Information from Third Parties
- Your name and email address from Apple or Google if you use social sign-in (subject to those platforms' privacy policies)
- Analytics data from Firebase (Google) to help us understand app performance and user behavior
d. Sensitive Personal Information
Because Evara is a dating app, some of what you provide is treated as sensitive personal information under Apple's App Store privacy disclosures and under several state privacy laws. We collect the following, and we collect it because the App cannot perform its core function without it:
- Information that can indicate sexual orientation. Your gender, and the gender or genders you tell us you are interested in, can together indicate your sexual orientation. We use this to show you people you may actually want to meet, and to operate the App. It is not used for any other purpose.
- Race or ethnicity. During onboarding you select an ethnicity for your own profile, and you may set your own preferences about the people Evara shows you. Whether your ethnicity appears on your profile is a setting you control, and you can change or clear your selection at any time by editing your profile. Evara never infers, estimates, or scores your race or ethnicity from your photos, your messages, or anything else — the only value we hold is the one you chose yourself. It is never used to explain why someone was matched with you, and Ocean is never given it.
- Precise location. See Section 5.
- Your device contacts. See Section 6 — only one-way hashes leave your device.
We do not use sensitive personal information for advertising, we do not sell or share it, and we do not use it to infer characteristics about you beyond operating the App's matching and safety features. You can request deletion of any of it as described in Sections 8 and 11.
3. HOW WE USE YOUR INFORMATION
We use your information to:
- Create and maintain your account, including verifying your phone number
- Generate match suggestions based on your profile and traits
- Power the My Circle feature (matching your contacts against other Evara users, and showing vouches from people you know)
- Enable communication between matched users, and power Ocean, our AI assistant (see Section 7)
- Automatically screen photos and messages, and manually review reported content, for material that violates our Terms of Service
- Process in-app purchases and subscriptions through Apple
- Improve the App using analytics (Firebase)
- Send service-related notifications and updates
- Detect and prevent fraud, abuse, and violations of our Terms
- Comply with legal obligations
4. SHARING YOUR INFORMATION
We do not sell your personal information. We may share your data with:
- Other Users: Your profile information (as you configure it) is visible to other Evara users for matching purposes. If you use My Circle, users you've matched with via your contacts may see limited information about that connection (such as that you're mutually connected) — we do not show your full contact list to other users or to Evara staff beyond what's needed to operate the matching feature.
- Service Providers: Third-party vendors who assist us in operating the App, bound by confidentiality obligations. This includes Firebase/Google Analytics; Google's Gemini API, which processes messages and related context to power Ocean and to help screen content; and Apple, for payments.
- Law Enforcement: If required by law, court order, or to protect safety.
- Business Transfers: In connection with a merger, acquisition, or sale of assets, your data may be transferred to the successor entity.
5. LOCATION DATA
We collect your precise location only with your explicit permission. We use it to confirm you're located in one of Evara's active launch markets and to support features like nearby events and local match discovery. You can disable location access at any time through your iPhone settings (Settings > Privacy & Security > Location Services > Evara). Disabling location may affect your ability to use the App in a geo-gated launch market, and may affect other features such as proximity-based matching.
6. CONTACTS AND MY CIRCLE
If you choose to use My Circle, Evara will ask for permission to access your device's contacts. With your permission, we convert your contacts' phone numbers into a one-way hash (a scrambled, non-reversible value) before sending them to our servers to check which of your contacts are also Evara users. We do not store or display your full contact list, and unmatched contacts are not retained beyond what's needed to perform the match. If you choose to reveal a match, limited identifying information (such as name and verification status) is shared between you and that specific contact, and only for matches you initiated. My Circle is entirely optional; declining contacts access does not affect your ability to use Evara's core features. You can revoke contacts access at any time through Settings > Privacy & Security > Contacts > Evara, and you can request deletion of My Circle data as described in Section 8.
7. OCEAN AND AI PROCESSING
Ocean, Evara's in-app AI assistant, uses Google's Gemini API to generate its responses. When you talk to Ocean directly, your messages to it — along with limited context about your account and activity in the App (such as your match count, subscription tier, or recent activity) — are sent to Gemini to generate a reply. Ocean does not read the content of your conversations with other users as part of that general context. The one exception: if you explicitly ask Ocean to draft a reply within a specific chat and confirm that request in the App, that conversation's content is sent to Gemini to generate the draft — we keep no record of that message content afterward, only a record that consent was given for that thread and how many messages were involved. We also use an AI-based classifier to help automatically screen chat content for safety issues. Ocean may retain "memory" of things you've told it directly across sessions to make future conversations more useful; you can view, delete individual memories, or fully reset Ocean's memory of you at any time in Settings. Content processed by Ocean is subject to Google's data handling as our service provider, in addition to this Policy.
8. DATA RETENTION
We retain your personal information for as long as your account is active or as needed to provide the App's services. You may request deletion of your account and associated data at any time through the App's settings or by contacting us at privacy@evaradating.com. Some data may be retained for a limited period as required by law or for legitimate business purposes (e.g., fraud prevention records).
9. SECURITY
We implement reasonable technical and organizational safeguards to protect your data, including encryption in transit (TLS) and at rest. However, no method of transmission over the internet is 100% secure. We encourage you to use a strong, unique password and to protect your device.
10. CHILDREN'S PRIVACY
Evara is intended for users 18 years of age and older. We do not knowingly collect personal information from anyone under 18. If we become aware that a user is under 18, we will promptly terminate their account and delete their data. If you believe a minor is using our App, please contact us at support@evaradating.com.
11. YOUR RIGHTS AND CHOICES
Depending on your state of residence, you may have some or all of the following rights:
- Access: Request a copy of the personal data we hold about you.
- Correction: Request that we correct inaccurate data.
- Deletion: Request deletion of your personal data.
- Opt-Out: Opt out of certain data collection (e.g., location, contacts, analytics) via device settings, or opt out of certain uses of your data where applicable state law provides that right.
- Data Portability: Request a copy of your data in a portable format.
- Limit Use of Sensitive Personal Information: Where applicable state law provides this right, ask us to limit our use of your sensitive personal information (Section 2d) to what is necessary to provide the App.
California Residents (CCPA/CPRA): You have the right to know, delete, and opt out of the sale of personal information (we do not sell personal information). You also have the right not to be discriminated against for exercising your privacy rights.
Residents of other states with comprehensive privacy laws (for example, where Evara currently operates) may have similar rights under applicable state law. To submit any request under this section, contact privacy@evaradating.com.
12. APPLE-SPECIFIC DISCLOSURES
In compliance with Apple App Store requirements:
- We comply with Apple's App Store Review Guidelines regarding privacy.
- Our App's data collection practices are disclosed in our App Store Privacy Nutrition Label.
- We use Apple's Sign In with Apple in compliance with Apple's guidelines.
- In-app purchases are processed entirely by Apple; we do not store payment card information.
13. DO NOT TRACK
Our App does not currently respond to "Do Not Track" signals from browsers, as no uniform standard exists. We will revisit this as standards develop.
14. CHANGES TO THIS POLICY
We may update this Privacy Policy periodically. We will notify you of material changes through the App or via email. The updated policy will be effective upon posting, and continued use of the App constitutes your acceptance.
15. CONTACT US
For general questions: support@evaradating.com For privacy-related requests (access, correction, deletion, or other rights described in Section 11): privacy@evaradating.com
Red Feather Industries, a trade name of Fleet Lifestyle LLC