Happens — Version 1.1 · Last updated 21 July 2026
The data controller is We-Dev Ltd, registered in England and Wales, company number 15878974, registered office in St. Albans, United Kingdom.
Contact: info@we-dev.uk · +44 (0)1727 309243
This policy is written under the UK GDPR and the Data Protection Act 2018.
| Data | Why | Lawful basis |
|---|---|---|
| --- | --- | --- |
| Email, password hash | To create and secure your account | Performance of a contract |
| Date of birth | To confirm you are 18+ | Legal obligation; substantial public interest (protection of children) |
| Profile: name, photos, voice intro, interests, answers | To show you to people you match with | Performance of a contract |
| Location, while discovery is on | To reveal people who are physically nearby | Consent — you switch it on and can switch it off |
| Age estimate and verification decision | To keep under-18s off the service | Legal obligation; substantial public interest |
| Challenge selfie | To confirm the photographs are of you | Substantial public interest |
| Identity document, if requested | Where other checks are inconclusive | Substantial public interest |
| Reports about other users | To keep people safe | Legitimate interests — safety of our users |
| IP address at registration, terms version | Evidence if an account is disputed | Legitimate interests — fraud prevention |
| AI processing costs | To operate the service | Legitimate interests |
| Personality scenario answers | To match you on compatibility rather than looks | Performance of a contract |
| Personality trait scores and badges | To show what you are like, and to rank matches | Performance of a contract |
| Voice introduction | To let a match hear you before meeting | Performance of a contract; consent — it is optional |
| Meeting plans: venue, time, messages | To arrange a meet-up with a match | Performance of a contract |
| Whether a meeting happened | To show a "Shows Up" badge earned by corroboration | Legitimate interests — trust between users |
| Declines and un-matches | To stop showing you people you have passed on | Performance of a contract |
| Device push token | To notify you about reveals and plans | Consent — you allow notifications |
| Last seen time | To avoid revealing people who are not around | Performance of a contract |
We do not store face templates, biometric identifiers, or anything that could be used to recognise you in another photograph.
Our automated age estimation analyses an image and returns an age range. It is called in a way that stores nothing on the provider's side, and we never use it to identify anyone — only to estimate an age. We do not create the kind of biometric record that UK GDPR Article 9 governs.
We do not sell your data. We do not use it for advertising.
Proximity reveals. When discovery is on, we compare your position with other opted-in users. If you are mutually compatible and close by, you are revealed to each other. Others are shown an approximate distance only — never your position, never a map of where you are.
Personality answers. Your scenario answers produce trait scores across eight dimensions and, where confident enough, short badges such as "Low-Drama". Other users see the badges. They never see your raw answers or your scores.
Voice introductions. Optional. A match can play it; it is served only to someone you are matched with and never publicly.
Meeting outcomes. After a meet-up we ask both people whether it happened. Your answer is never shown to the other person. A meeting only counts when both of you independently say yes; a single answer counts for nobody. There is no negative score anywhere — no "no-show" count, no reliability percentage, and nothing one person can do alone that harms another's standing.
AI-generated text. We use an AI model to write a short personality summary from your answers. Your answers are sent to that provider for this purpose and are not used to train their models.
Notifications. Reveal notifications are deliberately anonymous — they never carry a name or photo, because you have not chosen to meet that person yet. Notifications about a plan you have already agreed do name the other person.
The app itself does not use cookies. The admin panel, used only by our staff, uses a single session cookie that is strictly necessary to keep them signed in. We use no analytics, advertising or tracking cookies anywhere.
Your data is stored and processed in the UK and the EEA. Where a processor operates outside the UK, transfers rely on UK adequacy regulations or the International Data Transfer Addendum.
| Data | Retention |
|---|---|
| --- | --- |
| Challenge selfie | Deleted 30 days after a decision |
| Identity document | Deleted immediately once a decision is made |
| Age estimate | The range and the decision only, kept with your account |
| Location coordinates | Deleted as soon as you turn off "Discover me nearby" |
| Account and profile | Until you delete your account |
| Records of a rejected under-18 account | Minimum needed to prevent recreation |
| Audit records of decisions we made | 6 years, to answer a later complaint |
| Voice introduction | Until you replace or delete it, or delete your account |
| Meeting plans and outcomes | Until you delete your account |
| Push notification token | Until you sign out or disable notifications |
Deleting your account removes your data. It is not a deactivation flag.
Other users see your first name, photographs, voice introduction, badges and an approximate distance — and only once you have both been revealed to each other. Your exact location is never shown to anyone.
Photographs are served only to you and to people you are matched with. They are not publicly accessible.
Nobody is told what you answered about whether a meeting happened. Your answer is never shown to the other person.
Under UK data protection law you have the right to:
To exercise any of these, write to info@we-dev.uk. We will respond within one month.
Some data we must keep even if you object — for example the minimum record of a rejected under-18 account, which exists to protect children.
Age estimation is automated, but it cannot approve or reject you on its own. It can only send you to a human, and only a person decides. You can ask for a decision to be reviewed by writing to info@we-dev.uk.
Happens is strictly 18+. We do not knowingly collect data from anyone under 18. If we learn that an account belongs to a minor we suspend it and delete the data, keeping only the minimum record needed to stop it being recreated. If you believe a child is using Happens, report the account in the app or write to info@we-dev.uk — a report of a suspected minor takes that account out of contact with others immediately.
Passwords are stored only as hashes we cannot reverse. Photographs are served only to authenticated, matched users. Challenge selfies and identity documents are stored outside the public web directory and are never reachable by URL.
If you are unhappy with how we handle your data, tell us at info@we-dev.uk.
You also have the right to complain to the Information Commissioner's Office (ICO), the UK supervisory authority: ico.org.uk · 0303 123 1113.
We record which version of this policy applied when you accepted it. If we change it materially we will tell you.
*We-Dev Ltd · Company No. 15878974 · Registered in England and Wales · St. Albans, United Kingdom · info@we-dev.uk*