Privacy Policy

Updated on 10/26/2022

1. Definitions

Application: The HOOKD application is available on the Apple App Store and the Google Play Store.

Account: The Member’s dedicated personal area within the Application, which he or she accesses when he or she registers and connects to the Application. It enables the Member to access the Services. A Member may only have one Account.

Grid: List of Nears in HOOKD app.

Nears: Profiles of other people on your grid, recorded when you hooked another member if the geolocation is enabled.

New match: An event that is created between two profiles, triggered by a Like on both profiles. It represents mutual interest and sends out a “You hookd” notification, allowing Members to start a conversation.

Facebook Connect: A feature enabling Members to use their Facebook account to log in to the Application, in order to simplify the registration process.

Google Connect: A feature enabling Members to use their Google account to log in to the Application, in order to simplify the registration process.

Quick: a function that allows you to send a short message to a member before matching.

Geographical position: your location, recorded by HOOKD and updated regularly when this option is enabled.

Like: An action represented by a checkmark.

Member: A person registered with the Application.

About me: Information provided by the Member describing his or her lifestyle and personal characteristics on the profile. The Member can choose the information he or she wishes to appear on the profile.

Messages and/or voice messages: Only Members who have a “Like” can use the Application’s “Chat” function to send each other Messages. Messages are stored in the inbox, which is accessible via the icon on the bottom right of the application.

Profile Photos: photos on your profile enabling the easy identification of the Member. The Member accepts to, at the very least, provide 2 photos of his or her face in which he or she is clearly recognizable, and place it in first position. These two criteria combined are an essential condition for using the Services.

If the photo of the Member’s face is not placed in first position, it will be automatically placed in first position by default. If the Member has several photos of his or her face, he or she will be able to choose their order of appearance.

Services: All services, whether charged or free-of-charge, offered by HOOKD to encourage virtual or real-life meet-ups between Members who have crossed paths and who have a mutual interest in one another, according to the selected search criteria.
Favorites: A feature enabling Members to access a selection favorite profiles which they selected as favorites.

2. Data controller

The data collected is processed by Redcapy Inc. The company’s headquarters are located at 8 Green Ste R, Dover 19901, Delaware.

HOOKD is extremely concerned about the protection of your personal data and respect for your privacy. The purpose of this privacy policy (along with our document on the use of cookies and our terms of service and any other document it refers to) is to inform you on the way we process the personal data you share with us and that we collect when you use the Application and Services. Please read this document carefully to better understand how we process your personal data, and to know your rights.

This Privacy Policy applies to all Services published by HOOKD that you use (with the exception of services supplied and operated by third parties, in which case, their privacy policy will apply).

3. Information we collect

HOOKD collects and processes personal data on you when you use the HOOKD application or when you communicate with HOOKD. It may be information you share with us directly, or data we collect automatically.

To make sure our privacy policy is clear, we are providing below an overview of the personal data HOOKD collects and processes. Information is given below for each type of data collected.

  • Mandatory data
    • Identification data
    • Depending on how you signed up, email address and/or telephone number
    • Data relating to your activity on the application
    • Technical data of the cell phone or device
    • Your city (if you refuse the geolocation feature)
  • Data required for certain purposes
    • Data relating to taking part in games and competitions, to your experience and your satisfaction
    • Geographical position or at least your city
    • Nears with other Members
    • Search preferences – people whom you would like to Near with (age and gender)
    • In-app messages and in-app voice messages sent and received
    • Data relating to reports made and requests sent to the HOOKD customer service
  • Optional data
    • Professional career and education
    • Interests, lifestyle, Member Characteristics
    • Depending on how you signed up, email address and/or telephone number
    • Description

3.1 Data you share directly

When you use our Services, you share information with us, some of which may be used to identify you. When you communicate this information, you accept that some of the data will be visible to the other Members of the Application, and therefore made public on the Application. In an effort to help you identify this information easily, it is signaled as ‘public’ below. HOOKD cannot be held liable for data published on its platform and disclosed by a Member. However, information not marked as Public will not be visible or accessible by other Members; such information is signaled as ‘private’ below.

HOOKD collects and processes data relating to your registration and data relating to your interactions with HOOKD.

3.1.1. Registration data

Information required for registering

This is the basic data required for you to register and access our Services.

This data is collected by HOOKD using different methods depending on the type of registration you choose.

If you choose to register using your Facebook, Apple or Google account, your data will be collected from the relevant platform in an effort to reduce formalism. By selecting “Log in with Facebook/Apple/Google,” you agree to having these platforms provide us with such data.

In addition, you can register using a cell phone number and, if this is the case, your data will be sent to HOOKD directly by you.

This data relates to your identity.

Depending on how you registered, some data must be collected in order to provide our Services. If such data is not obtained, HOOKD will not be able to provide you with its Services via the Application, and you will not be able to create an Account. In all cases, your first name (public), age (public), birthdate (private), gender, and at least one Profile Photo (public) are required to register with the Application. Subsequently, you may add or remove Profile Photos at any time, providing you have added at least one Profile Photo containing a person’s face and one which doesn’t have to contain face. As stated in paragraph 1, “Definitions,” the first Profile Photo should be a photo of a person’s face, otherwise one of your photos of your face will automatically be put in first position.

If you register using your phone number, you must provide said phone number in order to register.

When you register via Facebook, we must collect your first name and your age. You may also allow Facebook to provide HOOKD with your last name, birthdate, gender and email address.

When you register via Apple or Google, we must collect your first name and email address. Said platforms may also provide HOOKD with your last name.

Optional information to complete your profile

You may add additional information to improve your profile. This information is optional, shared at your own discretion, and is your sole responsibility. You can add this information directly to your profile on the Application and/or via Facebook Connect by syncing your Account with Facebook. This data is as follows:

  • sexual orientation (public)
  • interests and habits (public): personal preferences, leisure activities, musical preferences, lifestyle, Member Characteristics;
  • profile description (public): if you would like to, you can share additional information about you in the space provided for this purpose. This information will be visible to HOOKD Members. Moreover, if you so wish, you can also answer the questions on your lifestyle (personality traits, sports, travel, type of meeting expected, etc.).

Your description is a free text area, HOOKD does not encourage Members to share data that can be perceived as sensitive with other Members, or with HOOKD through the Application. Sensitive data refers to data that is legally qualified as “sensitive” by the General Data Protection Regulation (“GDPR”). More specifically, it includes information on race or ethnicity, political opinions, religious or philosophical beliefs or affiliation with a union, along with information on health, sexual life or sexual preferences (“Sensitive Data”). If a Member decides to share such information on his/her profile regardless, it is deemed to have been “clearly made public” by the Member who shared it, according to the GDPR.

3.1.2. Data relating to interactions with HOOKD:

When you contact our customer or support services, report an issue with our services, ask for help, exercise your personal data rights, or participate in promotional activities, games, competitions or surveys, when you share your experience of our services, give testimonies, or answer one of our questionnaires, HOOKD will collect, depending on the case, the following personal data:

  • Data relating to reports and requests sent to the HOOKD customer service (private): Date and time of the report, nature and reason for the report, data relating to the reported user. Furthermore, proof of identity may be requested as part of the exercise of your rights over your personal data, and for safety/confidentiality reasons.

This data will be collected by HOOKD when you ask for help from our customer service, exercise your rights over your personal data, report a problem or another user. Such information is required to handle reports or answer your requests. This information will also be handled if a report is made about you. In fact, HOOKD has a legal obligation to collect reports from its Members brought to its knowledge regarding contents or behavior likely to infringe our Terms of Service.

  • Data relating to taking part in games and competitions, to your experience and satisfaction (private): participation, responses, satisfaction level, suggestions, experience.

Such data is collected by HOOKD when you take part in our games and competitions, answer our surveys and satisfaction questionnaires, share your experiences. This data is mandatory if you wish to take part in the games and competitions organized by HOOKD. Without this data, HOOKD may not register you for games or competitions. However, data on your experiences and satisfaction is optional.

3.2 Data we collect automatically

When you use our services and features, we collect information on your activities on the Application:

  • Activity data (private) (registration date, login dates, on or offline status, interactions with Members and third-party accounts, number of transactions, notifications received, notification preferences, etc.)

When you access our Services and use the Application and its features, information on the way you use them is collected and processed. Most of the information collected by HOOKD is necessary to the provision of its Services. Without this data HOOKD cannot supply the Services linked to the HOOKD application.

More specifically, this includes your registration date, login dates, on or offline status, the type and number of interactions with other Members (such as Quicks, Likes, Nears) , notifications received and notification preferences.

  • Geographical positions and Nears with other Members (public)

The Application’s main value and purpose is to allow Members to find other Members they have or may have been nearby. Your Geographical position is collected with your express consent only. In fact, you will be asked to authorize the collection and processing of your location data to allow HOOKD to identify your nears with other Members who have agreed to be geolocated.

Unless you have chosen stricter settings on your device, HOOKD will collect your Geographical position regularly also in the background (while not actively using the application). Background location access is necessary for the seamless use of the application. Without the background location tracking enabled, HOOKD won’t be able to always notify you about nearby members.

When the Geographical positions of two Members are within a certain radius, HOOKD adds Members to the Grid.

Your Nears will be displayed on your Grid, but Members with can never see your exact location.

You may, at any time, withdraw your consent by disabling geolocation on your smartphone. If you choose to do so, your Grid will no longer be updated, and you will not be able to see who you have Hookd with after disabling the geolocation option.

  • Text messages and voice messages sent and received (private)

Messages are sent and stored on HOOKD’s servers, to provide the Service to allow Members with a Like to have a conversation. Messages and voice messages are strictly private and only implicate the Members involved. HOOKD’s authorized managers do not exercise any rights to view these conversations. These Messages are not transmitted or communicated to third parties except in cases of judicial requests, and/or in compliance with the applicable legislative or regulatory provisions. Moreover, Messages are strictly private and are not accessible to other Members who are not involved in the conversation, nor to any third party.

  • Search preferences – people whom you would like to cross paths with (age and gender) (private)

The Application lets you set preferences by age, gender, and the Member Characteristics they have provided. You can change these settings in the Application and specify the age range and Member Characteristics, and, after agreeing to HOOKD collecting and processing your data, the gender of people you are looking for, so you can be matched exclusively with profiles you crossed paths with and who meet your search criteria. You will then only see the Members you have on Grid with and who share your search preferences on your news feed.

  • Technical data of the cell phone or device (IP, mobile ID, application version, telephone version and model advertisement ID, etc.) (private)

We collect information from the devices and equipment you use to access our Services, including server logs, which may contain information such as IP addresses, version of the application, device version and model, language used, operating system, application crashes, and advertisement ID. Data may be collected with cookies or other tracking tools: to learn more about this, please refer to our document on the Use of Cookies.

4. How do we use your data?

4.1. Supply of services and features according to our terms of service

  • Creation and management of your Account as a Member:
    • Creation of your profile.
    • Registration, deregistration, deactivation of your Member profile.
    • Management of parameters and preferences.
    • Management of subscriptions.
    • Management of access to the Services proposed by HOOKD.
  • Managing and storing messages exchanged between Members (Messages, Quicks, Likes).
  • Sending information messages relating to the Services or your interactions with other Members (notifications).

Legal basis: Execution of the contract

The data collected by HOOKD is required to make sure the Application is running smoothly and to supply the Services, which it is contractually obliged to provide to Members under the service contract biding the two parties (Terms of Service).

4.2. Suggesting profiles you have Hookd

  • Geolocation to suggest profiles of Members you have crossed paths or may cross paths with.

Legal basis: Consent

When you have given your consent, you are free to withdraw it any time by disabling the geolocation option on your smartphone. Withdrawal of consent does not affect any processing carried out before the withdrawal.

Additional information

The aim of the Application is to help you find other Members whose paths you have crossed or may cross. In fact, it allows you to identify your Hooks with other Members who have agreed to be geolocated. These crossing points allow HOOKD to show you profiles of Members you have crossed paths or may cross paths with and who meet your search criteria.

Legal basis: Execution of the contract

Processing this data enables us to provide our Services, and thus, to increase your likelihood of meeting Members with whom you are a good match.

  • Recommend your Profile via email to other Members with whom you have crossed paths or with whom you could cross paths.

Legal basis: Legitimate interest

This processing is based on the legitimate interest of HOOKD to offer Members relevant Profiles as part of its Services. You can contest this data use at any time by contacting us (see section 11. Contact).

4.3. Suggesting relevant offers and contents (marketing and advertisements)

  • Sending marketing or advertisement messages or contents:
    • Send the HOOKD editorial newsletter by email. We will stop sending the newsletter to Members who have not opened it in over a year.
    • Send a newsletter suggesting Profile recommendation that can be viewed on the Application (your Favorites).
    • Distribute marketing contents and advertisements related to HOOKD offers and services on the application and by emails.
    • Provide Members with offers and/or promotions on HOOKD’s services.

Legal basis: Legitimate interest

This processing is based on the legitimate interest of HOOKD to share its offers. As relates to the newsletter, you can object to receiving emails from HOOKS at any time by clicking on the “Click here to unsubscribe” link provided for this purpose in the emails you receive.

  • Conducting marketing operations and advertising outside of the application: we conduct marketing operations and advertising outside of the HOOKD application outside of third-party sites, social networks and third-party applications. If you are already a Member of the Application, we may share you email address and telephone number with such entities to exclude you from our Marketing campaigns. This information is provided for “hashing” purposes. This can also help HOOKD disseminate its campaigns to profiles similar to yours, who may be interested in our Services. The existence of your profile will never be disclosed to these similar profiles. The social networks which may receive your data for this purpose appear in the list of our service providers, available here.

Legal basis: Legitimate interest

This processing activity is based on HOOKD’s legitimate interest in excluding you from its promotional content on social media and advertising its services to non-Members on third-party websites.

  • Display personalized advertisements on the HOOKD Application with regard to third-party products and services to ensure they are relevant to the Member. These advertisements are personalized based only on your age group, gender and the country and/or city where you live. Your personal preferences will not be analyzed in disseminating such advertising. Personalized advertising also includes the restricting of identical advertisements. As a result, when a Member consents to it, repeated or irrelevant advertisements are limited and the Member will see more diverse content.

Legal basis: Consent

4.4. Improving and optimizing our services and our knowledge of how you use them

  • Improvement and optimization of the services of HOOKD, of the knowledge of its Members and the manner of using the Services:
    • Statistical studies.
    • Satisfaction survey.
    • Analyses of the use of the Application and Services by Members.
    • Understanding how our Application and its features are used
    • Improving our Application, offers and features
    • Understanding your needs

Legal basis: legitimate interest

This processing activity is based on HOOKD’s legitimate interest in improving and optimizing its services, knowing its users and how its services are used.

  • Provide Members with advice on which Profile Photos to publish by analyzing all Members’ profiles, so Members can, if they wish to do so, optimize the way their profile is presented.

Legal basis: legitimate interest

This processing activity is based on HOOKD’s legitimate interest in improving the way profiles are presented in the Application. You may oppose this use at any time by contacting us (see Section 11, Contact).

4.5. Guaranteeing the security of your personal data

  • Detecting or preventing breaches of the security of the Services by identifying and analyzing fraudulent behavior.

Legal basis: Legitimate interest

This processing is based on HOOKD’s legitimate interest in guaranteeing the security of its application and the data it processes. You can object to this use at any time by contacting us (see section 11. Contact). However, HOOKD may continue to implement the processing if it justifies legitimate and compelling reasons.

4.6. Preventing and combating illegal or unauthorized activities (breaches of the terms of service), ensuring the trust of Members and complying with legal requirements

  • Analysing and processing reports of fraudulent/undesirable behavior.
  • Managing undesirable behavior and warning, suspending, blocking or deleting the Member’s Account.
  • Managing requests to exercise Members’ rights over their data.

Legal basis: Legal obligation

These processes are based on HOOKD’s legal obligation, as a data host, to remove illegal content as soon as it becomes aware of it and on its obligation to respond to requests to exercise Members’ rights over their personal data (Articles 12 to 22 of GDPR).

  • Detecting or preventing fraudulent activities or activities which breach our Terms of Service:
    • Automated analysis of profile data, application activity to detect fake profiles, fraudulent behavior or behavior that breaches the Terms of Service.
  • Guarantee the quality of profiles:
    • Automated analysis of Members’ Profile Photos in order to detect faces, and, as much as possible, exclude fake profiles from the Application, combat fraudulent behavior and guarantee Member identification. You will not be able to create an account if your face cannot be detected in one of your Profile Photos upon registering. If you are prevented from registering even though your Profile Photo does show your face, you may contact us at any time.

Legal basis: Legitimate interest

This processing is based on HOOKD’s legitimate interest in preventing and stopping fraudulent activities that may be carried out on its Services or breach its Terms of Service, and in protecting users’ safety though profile identification. You can object to this use at any time by contacting us (see section 11. Contact). However, HOOKD may continue to implement the processing if it justifies legitimate and compelling reasons.

4.7. Providing Members with help and technical support

  • Responding to the requests for support submitting by Members using the Application

5. Cookies and tracking tools

Cookies may be used on our showcase website for technical, advertising reasons or for measuring audiences. In the Application, cookies and tracking tools may be used for technical reasons and for measuring audiences.

To learn more, read our document on the Use of Cookies on our website.

6. How data is shared

Only certain HOOKD employees from customer services and authorized managers process Members’ personal data for the purposes described above. These employees and authorized managers only have access to the data necessary to perform their duties.

Authenticated and reliable service providers and partners, who may access and/or process Members’ personal data, in compliance with the Privacy Policy, and ensuring the security and privacy of the Members’ personal data. These service providers help us operate and improve our Services, including

  • our sub-contractors in charge of data infrastructure and hosting
  • suppliers of the analysis software we use
  • technical sub-contractors for using the Application and/or ensuring that the Application functions properly
  • our customer service to provide Members with the support they need and manage reports;
  • our Marketing partners to provide HOOKD Members and non-Members with relevant messages, offers and content.

As part of marketing and advertising operations outside the Application intended for non-Members, your data may be provided to partner social networks in order to exclude you from our campaigns, unless you oppose that.

For more detail, please refer to the list of our sub-contractors and partners.

In addition, at the request of state bodies, in particular the judicial authorities, and in order to comply with any judicial or legal request, HOOKD may transmit the personal data of its Members.

Lastly, we may be required to share your data for the purposes of corporate operations, which include, but are not limited to, a restructuring, a change in control of the company, a merger, an acquisition, a transfer, or a termination of the company.

7. Transfer of Personal Data outside the EU

The personal data of Members processed as part of their use of the Application is hosted in the European Union.

However, the personal data of Members are transferred to HOOKD subcontractors located outside the European Union, for Member support, report management, advertising and marketing.

Transfers of data outside the European Union may be made to countries in relation to which no adequacy decision has been taken by the European Commission on the protection of personal data. HOOKD guarantees that transfers are made under conditions ensuring the confidentiality and security of the data and providing an adequate level of protection compliant with regulations. These transfers are governed by standard contractual clauses of the European Commission.

For the exact location of our recipients, please refer to the list of our sub-contractors and partners.

8. Exercising your rights over your Data

Your rights

In compliance with the GDPR, every Member has a right to access, rectify, and a right to data portability and removal of his/her personal data, along with a right to object to or limit processing of his/her personal data, and the right to decide on the way to handle the personal data after his/her death. In an effort to address its Members’ concerns, HOOKD commits to respecting the protection of personal data and to process requests as soon as possible.

Exercising your rights

Members may exercise their rights, subject to proving their identity, by sending an email to, by exercising their rights directly via the Application. For confidentiality reasons, if there is a doubt on the requesting party’s identity, proof of identity may be requested.

For any other claim, the Member may lodge a request with the national authority responsible for data protection.

Description of rights

  • The right to access allows a Member to ask HOOKD for data pertaining to him/her in an accessible format, based on the terms and conditions of Article 15 of the GDPR. Your right of access must not infringe on the privacy of third parties, which is why you will only have access to your personal data and not that of third parties (for example, only messages that you have sent will be communicated to you and not those that you have received).
  • The right to correct grants a Member the right to demand HOOKD corrects, adds to, updates or removes any personal data on him/her that is inaccurate, incomplete, ambiguous, out-of-date, or whose use, communication or storage is prohibited based on the terms and conditions of Article 16 of the GDPR. You can modify or rectify some data directly on the Application. You just need to go on your profile and make changes directly in the sections “My photos”, “Work and Education (Job, Employer, School)”, and “About me”. When you have registered via Facebook Connect, to change your first name, age, or gender, go to your Facebook page and update the “About me – contact and basic info” section of your profile. When you have registered via a cell phone number, you must send a letter or contact customer support at the addresses listed above, to change your first name, age or gender. In case of error, your age can be rectified once, directly on the Application.
  • The right to data portability grants a Member the right to receive the personal data he/she gave to HOOKD, in a structured, commonly used format, legible on a machine, and to forward them to another processing entity, in compliance with Article 20 of the GDPR.
  • The right to contest grants a Member the right to object, free of charge and at his/her own discretion, to the use of his/her data by HOOKD for canvassing, especially commercial canvassing, and to the processing based on HOOKD’s legitimate interest, in compliance with Article 38 of the French Data Protection Act and Article 21 of the GDPR. For processing based on legitimate interest, HOOKD retains the option to justify legitimate and compelling reasons to continue processing.
  • The right to delete grants a Member the right to demand the removal, free of charge and at his/her own discretion, of data transmitted to HOOKD, within the limits of the rights based on Article 17 of the GDPR. Also, you can delete your Account using the corresponding feature on the Application. We inform you that all your data will be deleted from the HOOKD application. However, HOOKD, as the host, has a legal obligation to retain your personal data for one year under Article 6-II) of the French Trust in the Digital Economy Act no. 2004-575 of 21 June 2004. Your data will be kept in an archive database kept separate from our production databases and only for the purpose of responding to a court order. Data will be permanently deleted after one year.
  • The right to limitation grants Members the right to request the temporary suspension of the processing of their data by HOOKD under the conditions set out in Article 18 of GDPR.

These rights may only be exercised within the limits of HOOKD’s resources as it relates to its use of Facebook, Google and Apple to log into the Application. Some data sent to HOOKD by Facebook, Google or Apple cannot be corrected without Facebook, Google or Apple’s cooperation.

9. How long will we keep your data?

HOOKD has introduced a process for automatically deleting your account and your personal data with regard to the storage time limits defined below. When certain data must be stored for statistical uses beyond these storage time limits, this data is anonymized irreversibly to ensure you can no longer be identified.

HOOKD will store the Member’s data for as long as required in order for the Member to use his/her Account, namely:

  • For the length of the Member’s registration, plus one year. After one year of inactivity on an Account, the Account will be deleted and the Member’s data will be retained for another year, before being permanently destroyed or irreversibly anonymized. An account is considered inactive when the Application of the Member has not established contact with HOOKD’s servers (including due to deactivation of the geolocation process); and the Member has not used the Application.
  • When a Member is banned, his/her Account becomes inactive. Information from this Account is retained in an active database for one year, in order cross check it with information provided with new registrations to the Application, in order to prevent, to the extent possible, banned users from registering again. Subsequently, the personal data is archived for one more year, after which it is deleted permanently or irreversibly anonymized.
  • When the Member deletes his/her Account or requests its deletion from Customer Service, it will be deleted from the Application. However, the Member’s data will be kept in a separate archive for one year before being permanently destroyed or irreversibly anonymized, in order to enable HOOKDto comply with its obligation to keep it as host.
  • Some of the Member’s data, such as email address and telephone number, will be retained for prospecting or Marketing purposes (see Article 4.3) or to be analyzed in order to improve and optimize our service (see Article 4.4) for one year after an Account has been inactive for one year. If a Member deletes his/her Account, this data will not be used for prospecting or marketing purposes.

With regard to your Geographical Positions and Crossing Points, shorter storage times apply:

– Your Geographical Positions are stored for one month from their collection in order to determine your Nears with other Members;

– Your Hooks are stored for six months from their collection in order to display the Profiles of Members you have crossed on the Application.

HOOKD undertakes to make every effort and to invest all means at its disposal to guarantee that the stored data is kept as secure as possible. However, it is the Member’s responsibility to take appropriate measures to protect his/her data.

10. Personal data of minors

HOOKD shall not collect data from minors. Should a Member lie about his/her date of birth, and particularly if he/she fraudulently claims to be an adult, the parents of the minor in question should inform HOOKD of this fact by sending an e-mail to one of the contacts mentioned in Article 11 “Contact”, requesting the data to be deleted. HOOKD commits to deleting all data on the minor in question as soon as possible.

11. Contact

If you have any questions regarding this privacy policy, or any other request concerning your personal data, you can contact us: