Privacy Policy

The CounselEffective date: November 1, 2026Version: 2026-3

The Counsel ("The Counsel", "we", "us") is operated by The Counsel Social LLC. This policy explains the personal information we collect, how we use and disclose it, how long we keep it, and the choices and rights available to you. It covers The Counsel app and website. It forms part of our Terms of Service.

Contact: thecounseldating@gmail.com | 502 W 7th St, Ste 100, Erie, PA 16502-1333

1. Information you give us

Account details. We collect information used to create and protect your account, such as email address, phone number, legal first and last name where needed for checks or support, date of birth, and authentication information. Passwords are handled by our authentication provider in encrypted or hashed form and are not available to our staff in readable form. Your legal name, date of birth, email, and phone number are not displayed to ordinary members.

Sign-in with Google, Apple, or Facebook. If you choose to sign in with one of these accounts, that company gives us an identifier for your account with it, the email address on that account, and the name on that account. Google and Facebook may also provide a link to your profile picture, which our authentication provider stores with your sign-in record. We use the name and email only to sign you in and to fill in your sign-up form, where you can change them. We do not use a sign-in provider's profile picture on your profile. We do not receive your contacts, friends list, or posts, and we never post on your behalf. Apple lets you share a private relay email address instead of your real one.

Email and phone verification. New accounts confirm their email address with a link we send by email and their phone number with a 6-digit code we send by text message through our authentication provider. Existing accounts may be asked to do the same. Your verified phone number is linked to your account as a sign-in method, so one phone number can belong to only one account. We use verification to keep out fake, duplicate, and banned accounts. Text verification is currently available for U.S. phone numbers only, and your carrier's message and data rates may apply.

Dating profile. Depending on the features you use, you may provide photos, display name, bio, prompts, voice prompts or intro, height, weight, job, education, hometown, gender, who you are interested in, sexual orientation, relationship goals and style, whether you have or want children, drinking, smoking, drug use, exercise habits, pets, interests, personality answers, and dealbreakers.

Redacted profile. Redacted uses a separate set of answers and introductory content for anonymous matching.

Atlas travel profile. Atlas may include travel photos, bio and prompts, marital status, gender, orientation, fitness/activity level, job, education, drinking, smoking, drug use, travel preferences and availability, and a Travel Record of places you choose to list.

Emergency contacts. If you use trip-safety tools, you may provide a contact's name, relationship, and phone number. Add a person only if they have agreed to be listed.

Content and activity you submit. This includes messages, photos, videos, voice notes, polls, reactions, Sidebar answers, Open Invites and responses, Atlas trips and applications, questions, likes, skips, and reactions to other members' content.

Reviews, reports, and appeals. We collect reviews and ratings you write, reports about safety or rule violations, appeals, support and problem reports, and evidence you submit such as screenshots or device details.

Checks. For Selfie Checked, you take a camera selfie and choose a profile photo; the app checks on-device whether a face is present in each image. The images are not uploaded for this check. For ID Details Matched, you upload a government-ID image; we use text extraction to compare name and date of birth and then delete the image as described in Section 11. For Booking Checked, you may upload a booking or itinerary; we read text needed to compare it with the trip information and then delete the document as described in Section 11.

Settings and consent choices. We collect notification settings, quiet hours, filters, read-receipt and activity settings, contact-discovery choices, language and unit preferences, ad choices, AI-processing choices, and records showing when you gave or withdrew a legally required consent.

Purchases. Apple or Google provides us with purchase and subscription status needed to unlock plan features. We generally do not receive your full payment-card number.

2. Information collected automatically

Location. With permission, the app reads device location and rounds it on-device to approximately 1 kilometer before storage. We use the rounded location to calculate nearby results and approximate distance. The rounded coordinates used for matching and distance stay on our systems and are not delivered to another member's device; the other member receives only the display result, such as an approximate distance. Places you intentionally select for an Open Invite or Atlas trip may be stored and displayed as part of that content. If you don't pick an area for one, it uses a city-level point (about 10 kilometers) rather than your location.

We also keep the country or other coarse jurisdiction signal needed to determine which legal notices and feature rules apply.

Activity. We collect time zone, recent activity, session information, features used, likes, skips, profile views, and ad views. If you hide activity status, we limit what is displayed to other members as described in Section 8.

Device and app information. We collect device model, operating system, app version, notification token, app/install identifier, and a one-way device code used for fraud, duplicate-account, and ban-evasion detection.

Diagnostics. Crash reports and error logs may be linked to an account or device so we can troubleshoot and protect the Service.

Analytics. Google Analytics for Firebase may receive an app-instance identifier, device/app information, and limited events about screens and features used. We do not send free-form messages, profile answers, review text, trip details, sexual orientation, health answers, trust scores, match results, or other sensitive user content as analytics event values or parameters.

App integrity. Apple App Attest, Google Play Integrity, or similar systems may provide signals that requests come from a legitimate installation of our app.

3. Information from other people

Contact discovery. If you choose contact sync, phone numbers from your address book are transformed into one-way or otherwise protected matching codes before upload. Because a code may still correspond to a phone number, we treat it as personal information. You can turn contact discovery off and withdraw device permission.

Other members. We receive reviews, ratings, reports, likes, reactions, Sidebar answers, emergency-contact shares, and conversations involving you.

App stores. Apple or Google may provide subscription status and, where law or platform features provide it, age-related signals.

Sign-in providers. If you sign in with Google, Apple, or Facebook, that company provides the account details described in Section 1.

Public sources. We do not run comprehensive criminal background screenings of every member. When investigating a report or credible safety concern, we may check public sources such as sex-offender registries.

Law enforcement and others. We may receive legal requests, safety reports, rights complaints, or other information about an account from authorized third parties.

4. Sensitive information

Some optional profile fields can be sensitive under privacy law, including sexual orientation, gender identity, relationship style, drug/alcohol/tobacco use, height, weight, exercise or fitness information, and related inferences. We treat sensitive fields conservatively even when a particular law does not classify every field the same way.

Separate consent. Where consent is required, we ask before saving a sensitive answer. General acceptance of the Terms or this Privacy Policy does not count as consent. The consent request explains the categories involved, purposes, and relevant disclosures. Where applicable consumer-health law requires separate consent to share an answer with other members, the app uses a separate affirmative “show/share” choice rather than bundling collection and sharing into one acceptance.

Use. We use sensitive structured answers only for the purposes disclosed in the consent flow, such as matching, Docket ordering, filters or dealbreakers, and profile display when you separately choose to display them. We do not use sensitive structured answers for advertising and do not send them to generative AI features.

Withdrawal. You can change or remove an answer or withdraw consent in Settings > Sensitive information. Withdrawal stops future use covered by that consent and removes the relevant structured answer from profile and matching systems, subject to lawful retention of consent records or safety/legal records. If a feature cannot operate without a field you withdraw, that feature may be limited until you provide a permitted replacement; we will not silently preserve a sensitive identity label under a generic category.

Other sensitive content. Private messages, ID-derived details, and health or other sensitive information you voluntarily write in free-form content may also be sensitive. They are handled according to the feature, consent, safety, and retention rules described in this policy and the Consumer Health Data Privacy Policy.

Face presence checks. The selfie check detects only whether a face is present. It does not compare faces, identify a person, create an identification template, or perform facial recognition. The selfie-check images remain on the device for this check. We do not intentionally collect biometric identifiers or biometric information through this feature.

5. How we use information

Ratings and trust outputs

A Counsel Rating appears after at least three qualifying reviews. Reviews from newer or lower-trust accounts may receive less weight. A review may be materially down-weighted when our systems detect blocking-related retaliation, extreme-rating patterns, or a score that was lowered after the reviewer saw the other person's review. These systems are designed to reduce manipulation, not to determine objective character or safety. Trust and Travel Trust Scores do not predict whether a member is safe.

What the badges mean

Selfie Checked confirms only that the app detected a face in a camera selfie and in a selected profile photo. It does not compare the faces, test liveness, or establish identity.

ID Details Matched confirms only that the name and date of birth read from an uploaded document matched the account information. The check does not authenticate the document or compare its photo with the member.

Booking Checked confirms only that text read from a booking or itinerary was consistent with the Atlas trip information. It does not confirm that the trip will occur or that the host is safe.

6. Artificial intelligence

Some features use Google Gemini models through Google Cloud. We separate always-on safety processing from optional generative-AI features.

Safety processing

UseInformation sent
Moderation casesReported content and relevant evidence or context needed to help our team review the case. We minimize identifiers where practical.
Scam-pattern checksDerived counts, risk signals, and scores from automated checks. Message text is not sent for this purpose unless it forms part of a report or investigation that requires it.

Safety, fraud, security, and abuse processing may occur without optional-AI consent where allowed by law because it is necessary to protect the Service, respond to a report, or satisfy a legal obligation. People make final permanent-ban and appeal decisions.

Optional AI features

FeatureWhen it runsInformation sent
Counsel InsightOnly in a chat where both participants enabled AI chat processing; either may then request an insight.Up to the 500 most recent text messages in that chat and Sidebar answers, subject to the consent controls.
Message helpWhen you request help. If it would use the other participant's private message text, both participants must have AI chat processing enabled.Your draft and, where permitted, recent conversation context. The other participant's private message text is not sent without the required mutual setting.
Server-side translationOnly when on-device translation is unavailable and both chat participants have AI chat processing on.The specific message text needed for translation.
Conversation Compass / first-message ideasWhen a member asks.Structured, non-sensitive profile fields (interests, relationship goals, children and pets). Another member's bio, prompt answers or job title are sent only if that member has turned on "AI may read my profile text." Their name is not sent.
Open Invite / Atlas writing helpWhen you ask.Your own invite or trip draft and the trip information you are editing.
Review summaries on profilesWhen a profile with several reviews is viewed and our built-in summary isn't enough.That profile's aggregated review scores and counts. No review text, reviewer details or sensitive answers.
Profile, review, and relationship insightsWhen you ask for analysis of your own account or content.Summaries or content from your own profile, review statistics, or other data described in the feature.

Structured sensitive answers from Section 4 are not sent to optional generative-AI features. Free-form content can contain sensitive information, so we apply the consent rules above before optional AI processing of another person's content. You control both permissions in Settings > AI features; both are off until you turn them on.

Google's role. Google processes AI data for us under our Google Cloud agreements and the configuration we select. We do not authorize Google to use The Counsel customer data to train or fine-tune generalized models for Google's own purposes. Google may process limited data for service operation, security, abuse prevention, or transient caching as permitted by our contract and configuration. Because vendor terms can change, the current Google Cloud terms and privacy materials linked in Section 9 control the provider-specific details.

AI outputs can be wrong. Do not rely on them for safety, legal, medical, or other high-stakes decisions. We also use Google Cloud Vision or similar provider functionality for document text extraction and violence screening as disclosed elsewhere in this policy.

7. Automated decisions and safety

Some safety and product decisions are made or assisted automatically. Temporary restrictions may limit messaging or media for up to seven days when multiple reports support an issue or an account has a confirmed prior violation. Permanent bans are decided by an authorized person.

Accounts flagged as likely scams or serious abuse may receive reduced visibility, link restrictions, or media limits. Shadow bans are reserved for ban evasion, fraud, spam, or serious manipulation. Accounts with a date of birth under 18 are automatically suspended. Reviews or posts that appear to contain private information or prohibited language may be held for human review.

You can view disclosed restrictions in Settings > Account status and appeal. Appeals are reviewed by a person. Where applicable law gives you a right to human review of an automated decision, you may request it through the privacy-request channels in Section 12.

8. What other members can see

Shown to other members

Depending on the feature and your settings, members may see your profile photos, display or first name, age, approximate distance, answers you choose to display, badges, Counsel Rating, Atlas profile, Redacted content, Open Invites, trip content, reviews about you without the reviewer's name, activity labels, and read receipts.

In the Redacted deck, in Redacted likes and in a Redacted chat until you both agree to reveal, other members' devices receive only the anonymous card and an anonymous Redacted ID: no name, photos, account ID or location. Messages, voice notes, reactions, Sidebars and reviews in that chat carry only Redacted IDs. Photo and video sharing, Counsel Insight and message help start after the reveal. When you both reveal, the conversation moves to an ordinary chat connected to both accounts, and reviews you left before the reveal are filed then. If the chat ends before a reveal, it is closed and reviews held for it are discarded. Moderators can see who is behind a Redacted card, as described above.

Trip-plan links. Anyone with a valid link may see the trip details displayed on it, such as first name, trip title, destination and dates, expected return time, and check-ins. Treat the link as private and share it only with people you trust.

Calculated on our systems, not sent as hidden raw inputs

Compatibility, distance, activity and dealbreaker results are calculated on our controlled systems. Other members' devices receive the display result needed for the feature, not your personality answers, rounded coordinates, private dealbreakers, answers you keep off your profile, or activity times you don't display. Filters run on the member's own device using only what profiles show, so an answer you hide never matches anyone's filter.

Only you, The Counsel, or authorized processors

Your email, phone number, legal name, full date of birth, private dealbreakers, time zone, jurisdiction signal, ad choice, consent records, and internal safety or anti-fraud signals are not shown to ordinary members. Authorized moderators may access reported content, relevant conversation context, profile information, account history, and private account data when needed for safety, support, legal compliance, or enforcement. Access is limited to people we authorize, and privileged moderator actions (such as restrictions, bans and case decisions) are logged.

Staff may also use the Service as genuine members. Staff accounts may be placed higher in discovery, Likes and Messages, and staff accounts with moderation access can see who is behind a Redacted card (see "Staff accounts" in the Terms). Staff may not handle a moderation case involving their own interactions.

9. How we disclose information

We do not sell personal information for money. We do not give third parties personal information for their own direct marketing. Some state laws treat disclosures for cross-context behavioral or targeted advertising as a “sale,” “sharing,” or targeted-advertising disclosure even when no money is paid. Section 10 explains your choices.

Other members

We disclose profile information, messages, content, trip details, emergency-contact information, and other information to members only as the relevant feature and your choices provide. Sensitive structured profile answers are displayed only when you have separately chosen to display them where law requires that separate choice.

Service providers and processors

Service providers process information for us under contracts or platform terms and are authorized to use it only for the relevant services, subject to applicable law. Consumer health data is subject to the additional processor restrictions in the Consumer Health Data Privacy Policy.

Advertising partner

Google AdMob provides advertising. When personalized ads are enabled, AdMob may receive advertising or app identifiers, IP address, device/app information, and ad-interaction information for ad selection, frequency control, measurement, fraud prevention, and cross-context advertising. For that advertising function, AdMob may be treated as an advertising third party rather than a service provider under some state privacy laws. We do not intentionally send AdMob your name, contact information, profile answers, messages, review text, scores, matches, precise trip details, sexual orientation, relationship style, or health information.

Sign-in providers

If you choose to sign in with Google, Apple, or Facebook (Meta), that company knows you used its sign-in for The Counsel and handles that information under its own privacy policy. We exchange with it only what is needed to sign you in or to confirm it's you, for example when you delete your account. In our app, we turn off the Facebook software's automatic app-event logging, advertising-ID collection, and automatic start-up, so it is not used to send Meta information about your activity in The Counsel.

Safety and legal disclosures

We may disclose information to comply with valid legal process, report apparent child sexual abuse material, respond to an emergency involving danger, investigate fraud, protect the Service, enforce our Terms, or protect rights and safety. We may issue fraud-ban notices required by New York, Vermont, or other applicable law as described in the Terms and Online Dating Safety Policy.

Business transfer

If The Counsel is involved in a merger, acquisition, bankruptcy, financing, reorganization, or sale of assets, information may transfer as part of the transaction subject to applicable law and this policy. Consumer health data receives the additional protections described in the Consumer Health Data Privacy Policy.

Google's terms and policies

Google processes data for us as our service provider under its contracts with us. These are Google's current documents for the services we use; Google may update them, and they don't change this policy:

10. Advertising

The free plan may show AdMob ads, including optional rewarded ads. If personalized ads are enabled, AdMob may use advertising identifiers, IP address, device/app information, and ad interactions to personalize and measure ads across contexts as permitted by your settings and law. We do not use sensitive structured profile information, message content, review text, trust scores, match results, or trip details for ad targeting.

You can opt out of sale/sharing or targeted advertising where applicable through Settings > Do not sell or share my personal information, the Your Privacy Choices page on our website, or by emailing thecounseldating@gmail.com with “Do not sell or share” in the subject line. When the opt-out is active, we configure ad requests as non-personalized or otherwise restricted as required by the applicable platform and law. Reward eligibility does not depend on allowing personalized ads.

Global Privacy Control. If our website receives a recognized Global Privacy Control signal in a context where it can be associated with your account or browser and applicable law requires us to honor it, we treat it as an opt-out request. The app itself may not receive browser GPC signals, so the in-app privacy control remains available.

Our website does not use advertising or analytics cookies. If that changes, we will update this policy and the consent and opt-out controls first.

11. How long we keep information

We keep personal information only as long as reasonably necessary for the purposes described here, subject to legal, safety, fraud-prevention, tax, accounting, dispute, or preservation obligations. The following are our ordinary target periods.

InformationTypical retention
Account and ordinary profile/contentUntil account deletion or an applicable feature-specific deletion event. Inactive accounts may be deleted after two years with at least 30 days notice.
Messages and mediaRemoved from ordinary member-facing conversations when the sending account is deleted. Copies may remain where tied to reports, safety records, disputes, law-enforcement preservation, or backups.
Reviews you wroteDeleted with your account unless you affirmatively choose an available option to keep them, subject to legal/safety retention.
Likes, skips, blocks and settingsUntil they expire, you change them, or the account is deleted, subject to safety/anti-abuse exceptions.
Sensitive-profile consent recordsWhile needed to demonstrate consent and withdrawal, normally for the life of the account and any additional period required by law.
Safety and ban-evasion recordUp to 7 years after account deletion where reasonably necessary to prevent repeat abuse, subject to periodic necessity review and shorter legal limits.
Shadow-ban recordUp to 7 years where necessary for ban-evasion and abuse prevention.
Proof of deletionA minimal record that deletion was completed, without ordinary profile content, for compliance and dispute purposes.
IntroductionsExpired Introduction chat/media deleted when the feature expires; a minimal “previously introduced” record may be retained for up to 1 year.
Selfie-check imagesNot uploaded or stored by us for the face-presence check.
ID and Booking document imagesDeleted from active systems promptly after the check, subject to transient provider processing needed to perform the check and any legally required security logs.
Trip-plan linksDisabled when cancelled and no later than 30 days after the expected return unless a shorter period is chosen.
Report evidenceOrdinarily 180 days after a case closes for copied media, with the written case/safety record retained longer as described above.
Fraud/safety notificationsOrdinarily 90 days for fraud-ban safety notices and 30 days for other in-app notifications.
NCMEC-related materialAs required by federal law or a valid law-enforcement preservation request.
Analytics, sessions and ad-view recordsTarget 90 days unless a shorter or longer period is technically necessary and legally permitted; aggregated/deidentified statistics may be kept longer.
Saved translationsTarget 90 days if a translation is saved; ephemeral processing is not intentionally retained beyond the feature need.
Problem/support reportsTarget 1 year after closure unless tied to a longer safety or legal record.
Download-my-data filesTarget 7 days after creation.
Purchase/tax recordsUp to 7 years or the period required for accounting, tax, fraud, and dispute purposes.
Server/security logsApproximately 30 days unless a security incident, investigation, or legal hold requires longer.
BackupsDeleted or overwritten on our backup rotation. Consumer-health-data deletion from archived or backup systems follows the Consumer Health Data Privacy Policy and applicable law; Washington law can allow delayed backup deletion for up to six months after authentication of the request.

12. Your choices and rights

Requests by email. You may contact thecounseldating@gmail.com from the email associated with the account. We may request additional information reasonably necessary to authenticate the request and use that information only for verification and compliance.

Authorized agents. Where law allows an authorized agent, we may require proof of authority and may still ask you to verify your identity or confirm the request directly.

Timing. We respond within the time required by applicable law, generally within 45 days for U.S. state privacy requests, with any extension allowed by law. California request-confirmation timing and other state-specific deadlines will be followed where applicable.

Appeals. If applicable law provides an appeal right, email thecounseldating@gmail.com with “Privacy appeal” in the subject line or use the appeal method shown with the decision. We will respond within the applicable legal deadline and provide information about further regulatory recourse where required.

We do not unlawfully discriminate against you for exercising a privacy right.

13. State and regional rights

Depending on where you live and whether a state privacy law applies to The Counsel at the relevant time, you may have rights to access, know, correct, delete, or port personal information; opt out of sale, sharing, targeted advertising, or certain profiling; limit or consent to sensitive-data processing; and appeal a denied request. We honor applicable rights through the methods in Section 12.

California

If the California Consumer Privacy Act applies, the table below summarizes the categories we may process. “Sale” and “sharing” are legal terms. We do not sell personal information for money. Personalized AdMob disclosures involving identifiers, IP address, app/device information, and ad interactions may constitute “sharing” for cross-context behavioral advertising unless you opt out.

CategoryExamplesDisclosed toSold/shared?
IdentifiersName, email, phone, account ID, sign-in provider account ID, app/device identifiers, advertising ID, IP addressService providers/processors; the sign-in provider you choose, to complete sign-in; display name to members; AdMob receives limited ad identifiers/IP/device data where personalized ads are enabledLimited AdMob disclosures may be “sharing”; otherwise no sale for money
Personal recordsName, phone number, details read from an IDService providers/processorsNo
Protected classificationsAge, gender, sexual orientation, marital status or other profile answers you chooseService providers/processors; members only as you chooseNo
Commercial informationSubscription and purchase statusService providers/processors; app storesNo
Internet/network activityApp usage, screens/features, likes/skips, ad interactionsService providers/processors; AdMob receives ad-related eventsAd-related disclosures may be “sharing”
GeolocationRounded location held on our systems, country/jurisdiction signal, places selected for trips/eventsService providers/processors; members see only approximate distance or places you intentionally postNo raw location sale/sharing
Audio/visual/electronicPhotos, videos, voice notes, private messages, temporary ID/booking imagesService providers/processors; intended members for content you send/shareNo
Professional/educationJob and education information you listService providers/processors; members as you chooseNo
InferencesCompatibility, ratings, trust and Travel Trust Scores, badgesService providers/processors; members see disclosed output such as ratings/badgesNo
Sensitive personal informationAccount credentials, sexual orientation, ID details, private messages, health-related answersService providers/processors; members only when you intentionally share applicable profile/content dataNo; not used for targeted advertising

We do not intentionally collect biometric information through the Selfie Checked feature. We do not disclose personal information to third parties for their own direct marketing under California's Shine the Light law.

Nevada

We do not sell covered information for monetary consideration as Nevada's general online privacy law defines sale. Consumer health data is governed by the separate Consumer Health Data Privacy Policy.

Consumer health data - Washington, Nevada, and Connecticut

Some profile answers, inferences, or free-form content may qualify as consumer health data under Washington, Nevada, or Connecticut law. We maintain a separate Consumer Health Data Privacy Policy that describes the categories, sources, purposes, recipients, consent structure, rights, deletion process, and security measures. A separate and distinct link to that policy appears on our homepage and in the app under Settings.

EEA, Switzerland, and United Kingdom

Registration and ordinary availability are currently limited to the United States. We do not actively offer the Service to residents of the EEA, Switzerland, or United Kingdom. Existing members may be able to access parts of the Service while traveling. Before actively offering the Service in those regions, we will update this policy and implement the required controller disclosures, legal bases, international-transfer safeguards, representatives, and Digital Services Act or UK-specific processes. This paragraph is not intended to claim that a law cannot apply based on the facts of a particular user or processing activity.

14. Security

We use administrative, technical, and organizational safeguards designed for the nature of the information we hold, including access controls, encryption in transit and at rest where supported, app-integrity checks, protected contact-matching codes, coarse location, logging of privileged moderator actions, and screenshot blocking on selected screens. No system is perfectly secure. Use a strong unique password and contact us promptly if you suspect unauthorized access.

15. Age requirement

The Counsel is for adults 18 and older. We do not knowingly permit children under 18 to maintain dating accounts. Accounts entered with a date of birth under 18 are suspended. If we learn that a person under 18 provided personal information, we delete or restrict it as appropriate, except for limited information we reasonably need for safety, abuse prevention, legal reporting, or compliance.

16. International processing

Our primary data systems are in the United States. Some service-provider processing, including cloud AI or security processing, may occur through global infrastructure. Where applicable law requires transfer safeguards, we use contractual or other lawful mechanisms appropriate to the service and jurisdiction.

17. Changes and contact

If we make a material change to this policy, we will provide notice in the app or by another appropriate method before the change takes effect when law requires. If a new use of previously collected information requires fresh consent, we will ask before using the information in that materially different way. We will maintain earlier published versions on our website.

Questions and privacy requests: thecounseldating@gmail.com | The Counsel Social LLC, 502 W 7th St, Ste 100, Erie, PA 16502-1333