Privacy Policy — Toumpa Pty Ltd

Effective Date: 12 January 2026

Toumpa Pty Ltd (“Toumpa”, “we”, “our”, “us”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, store, and protect your personal information when you use our mobile application (the “App”).

By creating an account or using Toumpa, you agree to the practices described in this Privacy Policy.

This Privacy Policy governs and prevails over any summaries, explanations, or highlights provided within the App or elsewhere.


1. Information We Collect

We may collect the following categories of information when you use Toumpa:


1.1 Account Information

  • Full name, email address, date of birth, and gender

  • Login credentials

  • Approximate location based on device settings or IP address (we do not collect precise real-time GPS location unless you explicitly enable it).

  • Profile preferences and personal details you choose to include


1.2 User Content

Information you upload or share within the App, including:

  • Photos, profile details, and written content

  • Questionnaire answers and match data

  • Messages, comments, and interactions with other members

You control what User Content you upload.


1.3 Usage Data

  • Features you use and how you interact with the App

  • Matches, likes, messages, and activity history

  • Access times, screens viewed, and click interactions


1.4 Device & Technical Information

  • Device model, operating system, unique identifiers

  • IP address and approximate location

  • App version, crash logs, diagnostics, performance data


1.5 Payment Information

  • Subscription type, purchase amount, and transaction confirmations

  • We do not store credit card or banking details
    Payments are handled securely through the Apple App Store or Google Play.


2. How We Use Your Information

We process personal information based on one or more of the following legal grounds: your consent, performance of a contract, compliance with legal obligations, and our legitimate interests in operating and improving the Service.


2.1 Provide and Operate the Service

  • Create and manage your account

  • Display profiles and User Content to other members

  • Deliver matching, messaging, and interaction features


2.2 Personalise and Improve the App

  • Provide personalised matches and recommendations

  • Analyse usage to develop and test new features

  • Improve App stability and performance


2.3 Communicate With You

  • Account confirmations and verifications

  • Safety notices and essential updates

  • Optional marketing communications (opt-out available)


2.4 Ensure Safety & Security

  • Detect and prevent fraud, abuse, or violations

  • Enforce our Terms & Conditions and Community Standards

  • Monitor suspicious activity and block harmful accounts


2.5 Legal Compliance

  • Comply with laws, regulations, and court orders

  • Protect Toumpa’s legal rights and user safety


3. Automated Decision-Making & Profiling

Toumpa uses automated processing and algorithms to:

  • Analyse your questionnaire answers

  • Compare compatibility scores with other members

  • Suggest matches based on shared traits

These systems help personalise your experience.
You may contact us for more information about how our matching algorithms work.


4. Sharing Your Information

We do not sell or rent your personal data.

We may share your information only as described below:


4.1 With Other Members

  • Your profile details and User Content are visible to other users

  • Messages, comments, and shared content may be copied or redistributed by others outside of our control, including screenshots.


4.2 With Service Providers

Trusted providers that help us operate Toumpa, including:

  • Hosting & cloud storage

  • Analytics (e.g., Firebase Analytics)

  • Crash reporting (e.g., Firebase Crashlytics)

  • Payment processors

They may only use your data as necessary to support the App.


4.3 For Legal or Safety Reasons

We may share information when necessary to:

  • Comply with laws, legal processes, or lawful requests

  • Protect rights, safety, and prevent harm

  • Investigate fraud, misuse, or security issues


4.4 Business Transfers

If Toumpa is sold, merged, or reorganised, personal data may be transferred to the new owner under strict confidentiality.


4.5 With Your Consent

For example, when connecting third-party accounts or integrations.


5. Data Storage & Security

5.1 Storage

Data is stored in Australia or overseas using secure, reputable providers.

5.2 Security Measures

We use:

  • Encryption (in transit and at rest, where applicable)

  • Access controls

  • Firewalls and security monitoring

5.3 No System Is Perfect

No online service is entirely secure.
We cannot guarantee absolute protection against unauthorised access.

5.4 Your Responsibilities

  • Keep your login details secure

  • Please notify us immediately of unauthorised access


6. International Access & Data Transfers

6.1 Users Outside Australia

You must comply with local laws when using Toumpa.

6.2 Overseas Transfers

Your data may be stored or processed outside Australia.

6.3 Safeguards

We work with providers that use:

  • Standard contractual clauses

  • Technical and organisational security measures

6.4 Consent

By using Toumpa, you consent to international data transfers where necessary.


7. Your Rights

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

7.1 Access & Correction

Please request a copy of your data or ask us to correct inaccuracies.

7.2 Deletion / Account Closure

Request the deletion of your personal data.
We may retain specific data where required by law.

7.3 Withdraw Consent

Opt out of marketing or specific data uses at any time.

7.4 Data Portability

Request a portable copy of your data (where applicable).

7.5 Complaints

  • Email: info@toumpa.com

  • If unresolved, contact the OAIC: www.oaic.gov.au


8. Data Retention

We retain personal data:

  • Following account deletion, personal data is deleted or anonymised within a reasonable period, unless retention is required by law.

  • As required for legal obligations or dispute resolution

Backups may retain historical copies for a brief period before deletion.
Aggregated or anonymised data may be kept for research or improvement.


9. Cookies & Tracking Technologies

Toumpa may use:

  • Mobile identifiers

  • Analytics tools

  • Tracking technologies to understand usage and improve features

These do not collect additional personal information beyond what is described in this Policy.


10. No Sale of Personal Data

Toumpa does not sell, trade, or rent personal information to third parties, including for targeted advertising or marketing purposes.


11. Data Breach Notification

If a data breach occurs that is likely to result in serious harm, we will promptly:

  • Notify affected users, and

  • Notify regulatory authorities as required by law


12. Children’s Privacy

Toumpa is for 18+ adults only.
We do not knowingly collect information from minors.
If a minor is identified, the account will be deleted immediately.


13. Your Choices

You can control specific privacy-related settings, including:

  • Push notifications

  • Location permissions

  • Photo uploads and profile visibility

  • Marketing email preferences

Disabling specific permissions may affect App functionality.


14. Changes to This Policy

We may update this Policy periodically.

  • Minor changes take effect when posted.

  • Material changes may be communicated via email, in-app alerts, or notifications.

Your continued use of Toumpa after updates constitutes acceptance.


15. Contact Us

For privacy enquiries:
📧 info@toumpa.com

For general enquiries:
📧 info@toumpa.com

Postal Address:
📍

If unresolved, you may contact the Office of the Australian Information Commissioner (OAIC):
🌐 https://www.oaic.gov.au