Privacy policy

1. Who is responsible

SOUVENIR LABS LTD ("Souvenir Labs", "we", "us") is the controller of personal data processed through Squabble. We are registered in England and Wales under company number 17370314.

2. Scope and age

This policy applies to the Squabble mobile app, its related services, and support requests. Squabble is for adults aged 18 and over. We collect a date of birth or receive an age-range signal where available to determine eligibility. We do not routinely collect identity documents. See our age-suitability page.

3. Information we collect

We receive information directly from you, from your use of Squabble, from other participants who interact with you, and from service providers or app stores used to operate Squabble.

• Account and profile: date of birth, optional gender, phone number if linked, internal identifiers, display name, handle, avatar, biography, settings, blocked accounts, account status, and records of account recovery, phone changes, resets, or deletion requests.
• Voice and conversation content: voice recordings, transcripts, debate questions, positions, messages, reactions, votes, outcomes, timing, and participant identifiers. We do not use voice recordings to identify you by your voice.
• Contacts and invitations: contact-matching tokens and selected phone numbers when you choose to find or invite contacts, plus connection and invitation records. Address-book entries are processed transiently for matching when you grant permission; raw unselected contacts are not retained by Squabble.
• Safety information: reports, relevant evidence and context, moderation decisions, appeals, and information needed to investigate misuse or protect people.
• Technical and security data: device and app version, operating system, network and IP information, push-notification token, crash reports, diagnostics, activity records, and security logs.
• Optional product analytics: if you choose to share product analytics, we collect limited information about how Squabble is used, such as app opens, screens viewed, and onboarding completion. This includes a random installation identifier and limited app, device, and operating-system information. We do not include account details, phone numbers, contacts, advertising identifiers, recordings, transcripts, debate content, prompts, or other free text.
• Purchases, trials, ads, and choices: introductory-offer eligibility status, subscription entitlements, store transaction identifiers, restore or transfer events, rewarded-ad interactions and verification records, region or age signals supplied by a platform, and records of privacy or consent choices. Apple, Google, RevenueCat, and payment providers process payment and trial eligibility; Squabble does not receive full card details.

4. Accounts, recovery, and starting again

You can use Squabble as a guest or verify a phone number. A guest account should not be treated as recoverable on another device until a phone number is linked. A verified phone number is used to secure and recover the same Squabble account and, if you choose, to find friends. Signing in with the same verified number on another device returns you to that account. If a guest verifies a number that already belongs to an established account, Squabble opens the established account rather than silently combining the two profiles.

Changing the phone number on an account requires verification of both the current and new numbers. The account identifier, activity, and Squabble+ entitlement stay with the account. Apple and Google payment accounts are separate from Squabble sign-in and are not used to find friends.

Start fresh is an account reset, not account deletion. It retains the account identifier, verified phone, Squabble+ entitlement, completed content shared with other participants, safety history, age and required policy-acknowledgement records, and a record that the reset occurred. It clears profile presentation, friend and discovery choices, matching and notification preferences, personalisation, and pending requests. To remove the account and its associated content instead, use account deletion.

5. Why we use information and our legal bases

• To provide the service: create, recover, and secure accounts; match participants; deliver and transcribe contributions; produce requested outcomes; maintain, restore, or transfer subscription access; send essential notifications; provide support; and carry out reset or deletion requests. For UK and EEA users, this is generally necessary to perform our contract with you.
• To keep Squabble safe and reliable: prevent fraud and abuse, investigate reports, enforce our standards, protect users, diagnose failures, and improve service reliability. We rely on our legitimate interests where they are not outweighed by your rights.
• With your consent: use optional contacts, notifications, product analytics, and advertising choices where consent is required. You can withdraw permission in Squabble or your device settings. Withdrawal does not affect processing already carried out lawfully.
• To comply with law and protect life: respond to valid legal requests, keep records we are required to retain, report unlawful material where required, and act where someone's life or safety is at risk.

Some information is necessary to create an account or provide a requested feature. If you do not provide it, that account or feature may not work. Optional information is identified when requested. You may object to processing based on legitimate interests by contacting us, and we will consider your circumstances.

6. Voice recordings and automated processing

Squabble is voice-first. When you record a contribution, audio is uploaded so it can be delivered to the other participant, transcribed, and used to provide conversation features and the requested analysis or outcome. Other participants can hear contributions shared with them. Recording starts only after you press the microphone control, and the app displays an active recording indicator while it is capturing audio. Before you first use the app, onboarding explains that recordings and conversation content are shared with transcription and AI providers for these requested features and asks you to agree to that processing.

Automated systems help transcribe, organise, summarise, evaluate, and prioritise content for safety review. Transcripts, summaries, scores, and outcomes can be incomplete, subjective, or wrong. They are part of the product and entertainment experience and do not determine legal rights or produce similarly significant real-world decisions. Automated signals may prioritise a safety review, but disputed moderation decisions can be appealed for human review.

Conversations can reveal political opinions, beliefs, health information, sexuality, or other sensitive matters. Only share information you are comfortable providing to the other participant and having processed to operate the feature. Do not record another person or upload an outside recording without the permissions required by law.

For UK and EEA users, processing a recording to provide the voice feature you deliberately request is generally necessary to perform our contract with you. We do not use conversation content to infer sensitive characteristics for profiling, advertising, or unrelated purposes. If we introduce processing that requires a separate special-category condition, we will identify an applicable condition and ask for explicit consent where required before that processing begins.

7. How long we keep information

• Raw voice audio: Squabble-managed raw audio is assigned a maximum 90-day retention period. Automated work checks for expired audio, queues deletion from primary storage, and retries failed deletion work. Audio can be deleted sooner when the related content or account is deleted, or retained for a specific legal or safety reason where necessary.
• Provider copies: a transcription or processing provider may temporarily hold a copy under its contract and configured retention controls. Provider retention and deletion settings must be verified against the release inventory before this draft becomes effective.
• Account and profile: while the account is active and then during the deletion process, except for information that must be retained for a limited legal, security, or safety purpose.
• Account reset records: while the reset account remains active, so we can apply the reset reliably and investigate misuse. They are removed with the account, subject to limited legal, security, or safety exceptions.
• Transcripts and conversation content: while needed to provide the conversation history, then deleted or de-identified when the associated account or content is deleted, subject to limited legal and safety exceptions.
• Contacts and invitations: raw address-book entries are used transiently. A token for a selected unmatched contact may be kept for up to 12 months, and an invitation record for up to 90 days.
• Account deletion: access ends when a deletion request is accepted. Data in active systems is normally deleted or de-identified within 30 days. Residual copies in protected backups expire on the backup schedule and are not available for ordinary use. We may retain a limited deletion receipt and a one-way reference to the deleted account for as long as reasonably needed to prove completion, prevent accidental reactivation, secure the service, and resolve disputes. Those records do not retain the phone number or restore deleted content.
• Purchase and entitlement records: Apple, Google, RevenueCat, and Squabble retain limited transaction and entitlement records for the periods needed to verify, restore or transfer a valid subscription, prevent duplicate or fraudulent claims, resolve billing disputes, and meet store, tax, accounting, or other legal obligations. A pseudonymous entitlement receipt may remain after Squabble account deletion for those purposes, but it cannot reopen or recover deleted account content.
• Safety, security, and diagnostic records: only for the period reasonably needed to investigate an incident, prevent repeat abuse, resolve a dispute, secure Squabble, or meet a legal obligation. The period depends on the record and risk.
• Optional product analytics: kept for no more than 12 months. Turning analytics off stops future collection. Information already collected expires on that schedule.

8. Who receives information

Conversation content is shared with its intended participants. We also use providers for cloud hosting and storage, authentication and SMS, transcription, automated processing, notifications, optional product analytics, diagnostics, support, payments and subscriptions, non-personalised advertising, and app distribution. Providers may use personal data only to provide contracted services and must protect it under applicable data-protection requirements. Our service-provider list will identify the verified release inventory.

We may disclose information where reasonably necessary to protect users, investigate wrongdoing, comply with valid legal process, or complete a corporate transaction subject to appropriate safeguards. We do not sell personal data or share it for cross-context behavioural advertising.

9. International transfers

Some providers may process information outside the UK or EEA. Where required, we rely on an adequacy decision, approved contractual clauses, the UK International Data Transfer Addendum or Agreement, or another lawful transfer mechanism, together with supplementary safeguards where appropriate.

10. Security

We use access controls, encryption in transit, restricted service credentials, separated environments, monitoring, and deletion controls appropriate to the information and risk. No internet service is completely secure. Report a suspected vulnerability to [email protected]without accessing, downloading, or retaining another user's data.

11. Your choices and rights

Depending on where you live, you may have rights to access, correct, delete, restrict, or receive a copy of your information, object to certain processing, withdraw consent, and complain to a regulator. You may delete your account in Squabble or use the alternative process on our account-deletion page. To exercise another right, email [email protected]. We may need proportionate information to verify your identity.

Product analytics is off by default. You can turn it on or withdraw your consent at any time under Privacy in Squabble settings. Turning it off does not affect the app's core features.

UK users may complain to the Information Commissioner's Office. EEA users may contact the data-protection authority where they live or work. These rights are subject to lawful exceptions.

12. Changes and contact

We will post changes here and give additional notice in Squabble when a material change requires it. Questions, objections, and privacy requests can be sent to [email protected].