Privacy Policy | Gatherly

1. Data Controller and Contact

Entity: Gatherly Ltd
Address: 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom
Email: [email protected]

2. Categories of Data We Collect

We process the following data to provide our matching and dinner group services:

Identity & Profile Data: Name, gender, date of birth (to verify you are 18+), biography, occupation, nationality, and profile photo.
Contact Data: Phone number (verified via SMS) and optional email address. If you sign in with Apple and choose "Hide My Email", the address we hold is Apple's relay address rather than your own.
Location Data: Precise GPS coordinates and your chosen "Max Distance" radius.
Preference & Interest Data: Dietary restrictions; cuisine, alcohol, and smoking preferences; dinner length; available dates; and questionnaire responses.
Technical Data: IP address, device type, app version, time zone, and system logs.
Match & Event Data: Match history, dinner dates, restaurant details, and cancellation status.
Post-Dinner Feedback: After a dinner, whether you attended, a 1–5 rating you give each of the other people at your table, and whether you report that someone did not show up. This includes feedback other members give about you.
Purchase Data: What you bought, when, and from which store. We never receive your card or bank details.
Push Notification Tokens: An identifier for your device, so we can send you notifications. There are four kinds, and they are not treated the same:
- Your own dinner (matched, restaurant booked, dinner cancelled) is part of the service and cannot be switched off in the app — missing it means not knowing where to turn up.
- The feedback reminder after a dinner, which you can switch off.
- Announcements about the running of the service, such as a change to these terms or a new city. These are on unless you switch them off.
- Offers and discounts. These are marketing. They are on when you join, and you can switch them off at any time, in the app or by writing to us. We stop as soon as you do.
All four are in Settings → Notification Preferences, and your phone's own settings can silence everything.
Diagnostic Data: Crash reports from the mobile app, containing the state of the app when it stopped working.

3. Legal Bases for Processing

Where applicable (e.g., EEA/UK), we rely on the following legal bases:

Contractual Necessity (Art. 6(1)(b)): To create your account and arrange your dinners.
Consent (Art. 6(1)(a)): For device permissions such as location and camera.
Legitimate Interest (Art. 6(1)(f)): For the security of the service, the prevention of fraud and abuse, the post-dinner feedback that lets us act on members who do not turn up or behave badly at a dinner, announcements about the running of the service itself, and telling you about our own offers. You can object to the last of these at any time, and switching offers off in the app does exactly that.
Legal Obligation (Art. 6(1)(c)): To comply with tax, safety, or law enforcement requirements.

4. How Your Dinner Group Is Chosen

Your dinner group is put together automatically, without a person deciding. The data used to do it is the data you gave us for that purpose:

the city you signed up in, and how far you are willing to travel;
the languages you speak;
your dietary needs and your cuisine, alcohol, smoking and dinner length preferences;
your questionnaire answers and your interests;
the dates you said you were free.

Nothing else about you is used, and the outcome is only which dinner you are placed in. If you want a person to look at your matching status, email [email protected].

4a. Ratings and No-Show Reports

After a dinner is over, everyone who was at the table is asked whether they went, to rate the others from 1 to 5, and to say if somebody did not show up. This is how we know whether the dinners we arrange actually happen, and it is the only signal we have about a member who repeatedly leaves four people waiting.

Nothing is shown to you in the app but your own average, and only once at least three people have rated you. Nobody is ever told, in the app, who rated them or what any one person said.
If you ask us, that is different. You can write to us and we will tell you what was said about you: the scores from a dinner and whether anyone reported you as a no-show, without saying which person gave which. We withhold that last part because it is also personal data about them. Where so few people rated a dinner that an unnamed score would still point at one person, we give you the total rather than the detail, and say so.
Nothing here happens automatically. A no-show report does not suspend or ban anyone by itself — our staff read the reports and decide.
You can contest what was said. A report is one member's account of an evening, not a finding by us, and we cannot know who was right. Write to us and we keep a record of what you tell us, take it into account alongside the report, and do not act on a disputed report while we are looking into it.
We delete it after twelve months, ratings and no-show reports together, whether or not you are still a member. Your average is worked out from what is left, so it reflects the last year rather than everything that ever happened.
Deleting your account removes both the feedback you gave and the feedback others gave about you, straight away.

5. Data Sharing & Recipients

We do not sell your personal data. We share it only with:

The other people at your dinner: your first name only, and only once the dinner has been confirmed with a restaurant. We do not give them your last name, photo, phone number, email address, or anything else from your profile. If you cancel, your name stops being shown to them.
Our service providers: the companies listed below, each processing only what their part of the service needs.
Professional Advisers: Insurers, auditors, or legal counsel where necessary.
Law Enforcement: Only if required by a binding legal order.

The categories of provider we use, and what each category receives:

Hosting and database providers — everything listed in section 2.
File storage providers — your profile photo.
SMS providers — your phone number, to send your verification code.
Geolocation and mapping providers — your location, to identify your country and city and to find restaurants near your group.
Sign-in providers — if you sign in with Google or Apple, the account details that provider gives us. Apple tells us an identifier for you and, only if you agree to share it, an email address; choosing "Hide My Email" means we only ever hold Apple's relay address, not your real one.
Push notification and crash reporting providers — your device's push token and crash reports.
Purchase validation providers — your purchases, to confirm what you bought.
Bot protection providers — technical data at login, to check you are not a script.
Logging providers — our logs, which can contain your IP address.
Email providers — your email address, to deliver emails we send you.

If you want to know which company sits behind any of these categories, ask us at [email protected] and we will tell you.

6. International Transfers

Your data is stored in the United States, and several of the providers in section 5 are based there. If you are in the EEA or the UK, your data is therefore transferred outside it. We rely on:

Adequacy Decisions by the European Commission.
Standard Contractual Clauses (SCCs) and relevant supplemental measures.

7. Your Rights

Depending on your location, you may have the following rights:

Access & Portability: Request a copy of your data in a machine-readable format.
Rectification & Erasure: Correct inaccurate data or request the "Right to be Forgotten."
Object to Automated Processing: Request a human review of your matching status.
Withdraw Consent: At any time for optional data or device permissions.
Lodge a Complaint: With your local Data Protection Authority (DPA).

You can delete your account yourself, at any time, from the settings screen in the app; section 8 sets out exactly what that removes. For anything else, email [email protected] and we will handle it by hand.

8. Data Retention

We keep your data until you delete your account, with one exception: ratings and no-show reports are deleted after twelve months, as described in section 4a. We do not currently delete or anonymise accounts automatically after a period of inactivity.

Deleting your account from the app erases your profile, your photo, your preferences and questionnaire answers, your notifications and everything else listed in section 2. Two things survive it, and we want to be direct about that:

Purchase records are kept, because we are required to keep records of sales. The link to you is severed, so what remains is a transaction with no account attached to it.
A dinner you were part of continues to exist for the other people at it, with you removed from it. If that leaves too few people for the dinner to go ahead, it is cancelled and the others get their dinner credit back. The ratings you gave, and the ratings and no-show reports others gave about you, are deleted.

Server logs are kept for our logging provider's standard period.

9. Security Measures

We take appropriate technical and organisational measures to protect your personal data against loss, misuse and unauthorised access. Traffic between the app and our servers is encrypted, passwords are never stored in a readable form, staff access is restricted to those who need it, and we keep backups. No service can promise perfect security, and we do not.

10. Children's Privacy

Gatherly is strictly for individuals aged 18 and older. If we discover we have collected data from a minor, we will delete it immediately and terminate the account.

11. Changes to this Policy

Material changes will be notified via in-app alerts. Your continued use of the app after the effective date constitutes acknowledgment of the updated policy.