ConnePal Privacy Policy

Effective date: 1 October 2026

This Privacy Policy explains how DIRWAAS INTELLIGENT SOLUTIONS LLC ("DIRWAAS", "we", "us" or "our") collects, uses, shares and protects personal data when you use ConnePal, including the website at connepal.com and the ConnePal apps for iOS and Android (the "Service").

We have written this policy with the Jordanian Personal Data Protection Law No. 24 of 2023 and the principles of the EU General Data Protection Regulation (GDPR) in mind. Depending on where you live, some or all of the rights described below may apply to you.

1. Who is responsible for your data

DIRWAAS INTELLIGENT SOLUTIONS LLC, Amman, Jordan, is the controller of the personal data processed through the Service.

• Email: contact@dirwaas.com
• Website: connepal.com

2. Our privacy commitments in short

• ConnePal is for adults aged 18 and over only.
• Other users see your masked profile, not your name, email or exact location.
• Visitors who are not signed in see a decorative globe, not real members: your dot is shown only to signed-in users.
• Signed-in users see dots fade in a few coarse steps when someone has not opened the app for more than a week. We never show the date or time you were last active.
• Your city is shown to others at city level only. The app does not access your device's GPS or precise location. If you tap "Use my location", we suggest the nearest city from the approximate location of your internet connection; that approximate location is used only to make the suggestion and is not saved to your account; only the city you choose is saved.
• Your reveal card (first name, age, your chosen stamp or, if you choose, your photo, and any contact details you add) is shown to a pen pal only if you both accept a reveal (shown in the app as becoming friends).
• We do not show ads, we do not sell your data, and we do not use third-party advertising trackers.
• Letters are encrypted in transit and at rest by our infrastructure provider. The Service does not use end-to-end encryption. Our staff may review reported content and, when investigating a safety concern, the conversation it belongs to; every such access is logged.

3. The data we collect

Data you give us

• Account data: your email address, used for sign-in and for service messages. If you choose to set a password, we store only a salted one-way hash of it, never the password itself, and we cannot read it.
• Date of birth: used to verify that you are 18 or older.
• Profile data: your chosen city, country, languages, interests, answers to the short character quiz, and your short intro line. We also generate a codename for you, and you choose a stamp illustration that stands in for a photo.
• Letters: the content of the letters you send and receive, and related information such as sender, recipient, send and delivery times, the city the letter was posted from (shown on its postmark), the envelope design chosen, and the delivery date of any letter sent to the future.
• Reveal data: if you set up a reveal card: your first name, the background you choose, whether to show your stamp or your optional photo, and any optional contact details you add (such as a phone number, email address or social media usernames). Your age is shown with it.
• Safety records: blocks you make, reports you make or that are made about you, and the outcome of our review, including any suspension or ban.
• Communications with us: anything you send us, for example by email.

Data collected automatically

• Security logs: your IP address and information about your device and app (for example device type, operating system, and app version), recorded for security, abuse prevention and troubleshooting.
• Rate-limit counters: counts of certain actions (for example sign-in attempts or letters sent) used to prevent abuse and spam.
• Essential storage: on the web, we use only the browser storage that is strictly necessary to keep you signed in and to secure the Service, and in the app and browser we keep on your device which letters you have opened (this is never sent to anyone). We do not use advertising or cross-site tracking cookies.
• Weather: to show a pen pal's local weather, our server asks MET Norway (the Norwegian Meteorological Institute) for the forecast at the centre of their city. No personal data is sent. Weather data is licensed under CC BY 4.0 from MET Norway.

Data you may choose to share in letters

Letters are free text. Please do not include sensitive information, such as information about your health, religion, political opinions or sex life, or any information about other people. If you choose to include it, it will be processed only as part of delivering and moderating your letters.

We do not access your device's GPS, contacts, camera roll (other than a photo you select for a reveal), or microphone.

4. How we use your data and our legal bases

We use your personal data only for the purposes below. Where the GDPR or a similar law applies, we rely on the legal bases shown.

• To create and run your account, sign you in, build your masked profile, deliver your letters with the distance-based delay, and run the reveal feature. Legal basis: performance of our contract with you (the Terms of Service).
• To verify that you are 18 or older. Legal basis: performance of our contract, our legitimate interest in keeping minors off the Service, and our legal obligations.
• To compute a compatibility score from quiz answers (see Section 5). Legal basis: performance of our contract.
• To automatically block contact details during the masked period, apply rate limits, detect and prevent spam, fraud, abuse and security incidents, and keep security logs. Legal basis: our legitimate interests in keeping users and the Service safe, and performance of our contract.
• To handle blocks and reports, review reported content, and suspend or ban accounts. Legal basis: our legitimate interests in user safety and enforcing our Terms, and, where applicable, our legal obligations.
• To report child sexual abuse and exploitation and respond to lawful requests from authorities. Legal basis: legal obligation, and our legitimate interest in protecting children and other people, and the vital interests of any person at risk.
• To send you service messages, such as sign-in codes, security alerts, and notices about changes to our terms or this policy. Legal basis: performance of our contract, and our legal obligations.
• To maintain, troubleshoot and improve the Service. Legal basis: our legitimate interests in operating and improving a reliable service.
• To establish, exercise or defend legal claims. Legal basis: our legitimate interests, and legal obligation where applicable.
• To show your reveal card (first name, age, chosen picture and any contact details you added) to a pen pal. Legal basis: your consent, which you give by filling in the card and accepting a reveal. Once a reveal is complete, the pen pal has already seen that information.

Where we rely on legitimate interests, we have weighed them against your rights and interests. You may object, as explained in Section 11.

We do not use your data for advertising, and we do not sell or rent it.

5. Automated processing and the compatibility score

The Service uses a few automated processes:

• Compatibility score: we compute a score from your and other users' quiz answers to indicate how compatible you may be as pen pals. It is a suggestion to help you choose whom to write to. It does not produce legal effects concerning you and does not similarly significantly affect you, and you remain free to write to anyone available on the Service.
• Contact detail filter: during the masked period, letters that contain email addresses, phone numbers, links or social media handles are blocked automatically, so that users stay masked until a mutual reveal.
• Age check: if the date of birth you enter shows that you are under 18, you cannot create an account.
• Rate limits: actions above certain limits may be automatically slowed or blocked to prevent abuse.
• Letter moderation: before a letter is sent, automated models run by our infrastructure provider (Cloudflare Workers AI) check it for hate, threats, sexual exploitation, insults and similar harm. Clearly hateful, threatening or exploitative letters are not sent. Other harmful letters are held back once with a warning, and you may change the letter or send it anyway. A refused letter, or a letter sent anyway after a warning, counts as a strike, and three strikes pause the account: you can still read your letters but not write until our staff review it. We keep a short excerpt of flagged letters for that review. A letter that only suggests its writer may be at risk of self-harm is sent, noted for our staff, and never counts against the writer.
• Translation: each letter from your pen pal is checked by a model run by our infrastructure provider (Cloudflare Workers AI) and, if it is not in the language of your app, translated automatically. A translation is shown only if it passes the same checks as letters (contact details before a reveal, moderation), is clearly labelled as a translation, with the original always one tap away. The translation is kept with the letter and deleted with it.
• Notifications: if you allow notifications on your phone, we keep a token for that device and use it to tell you when a letter arrives or a pen pal asks to become friends. A notice never contains a name, a place or any words of a letter. Notices are delivered by Google Firebase Cloud Messaging (Android) or the Apple Push Notification service (iPhone). Notices to a device stop as soon as you sign out there or that session ends, and the token is deleted within minutes after that. It is also deleted when the device stops accepting our notices or when your account is deleted. You can turn notifications off at any time in your phone's settings.
• Photo checks: photos you upload for your reveal card may be checked automatically by Google Cloud Vision (SafeSearch) for explicit or violent content. A clearly explicit photo is refused; a doubtful one stays hidden from your pen pals until our staff review it.

Decisions to ban an account are made by our staff, and a paused account is reviewed by our staff. Every time a member of staff opens someone's letters, photo or account details, or acts on an account, it is recorded in an access log. If you believe an automated process has affected you unfairly, contact us at contact@dirwaas.com and a person will review it.

6. How we share your data

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

• With other users, as the Service is designed: your masked profile (codename, stamp, city, country, languages, interests, intro line and compatibility score) is visible to other signed-in users, and your letters are delivered to their recipients. Your reveal card is shown only to a pen pal with whom you have completed a mutual reveal.
• With service providers who process data on our behalf: our infrastructure provider, Cloudflare, hosts the Service and stores and processes data using Cloudflare Workers, the D1 database and R2 storage, runs the letter moderation models (Workers AI), and delivers our emails. Google processes reveal card photos you upload, only to check them (Google Cloud Vision); the photo is not stored by Google for any other purpose. Google (Firebase Cloud Messaging) and Apple (Apple Push Notification service) deliver notifications to your device if you allow them. Service providers may use your data only to provide services to us.
• For legal reasons: we may disclose data to law enforcement, courts, regulators or other authorities where we believe in good faith that it is required by law or legal process, or necessary to protect the rights, property or safety of DIRWAAS, our users or others, including reports of child sexual abuse and exploitation to the relevant authorities and to the National Center for Missing and Exploited Children (NCMEC) where applicable.
• Business transfers: if DIRWAAS is involved in a merger, acquisition, reorganisation, financing, or sale of all or part of its business or assets, your data may be transferred as part of that transaction, subject to this Privacy Policy or a policy that is at least as protective.
• With your consent or at your direction.

When you download the app, Apple or Google process data under their own privacy policies, which we do not control.

7. International transfers

We are based in Jordan, and our infrastructure provider operates a global network. Your personal data may therefore be stored and processed outside Jordan and outside the country where you live, including in countries that may not offer the same level of data protection. Where the law requires it, we rely on appropriate safeguards for these transfers, such as the contractual data protection commitments offered by our infrastructure provider, or on other grounds permitted by applicable law, including where the transfer is necessary to provide the Service you have asked for.

8. How long we keep your data

We keep personal data only for as long as necessary for the purposes described in this policy.

• Account data, date of birth and profile data: for as long as your account is active. If you delete your account, it is deactivated and hidden immediately, and permanently erased after a 30-day grace period.
• Letters: for as long as your account is active. When you delete your account, your letters, including the copies in your pen pals' inboxes, are permanently erased after the 30-day grace period, and those letters then show "this pen pal has left".
• Reveal card and photo: for as long as your account is active. They are permanently erased after the 30-day grace period following account deletion.
• Security logs (IP address and device and app information): only for as long as needed for security, abuse prevention and troubleshooting, after which they are deleted.
• Rate-limit counters: only for the short period needed to apply the relevant limit.
• Letter translations: for as long as the letter they translate.
• Moderation records (flags and short excerpts of flagged letters): up to 12 months.
• Staff access log: up to 24 months, so that any access to your data can be accounted for.
• A copy of a reported photo: kept with the report, for as long as the report is kept.
• Block, report and ban records: for as long as the accounts involved are active. After account deletion, minimal records of safety reports and bans may be retained for up to 12 months for abuse prevention and legal compliance. To keep a ban in force, a one-way hash of the email address of a banned account, or of an account found to belong to someone under 18, is kept for as long as the ban applies; it cannot be turned back into the address.
• Communications with us: for as long as needed to handle your request and any follow-up.

We may keep data for longer where we are required to by law, or where it is needed to establish, exercise or defend legal claims, or to comply with a lawful request from an authority.

9. Deleting your account

You can delete your account in Settings. We ask you to confirm twice. You can also request deletion by emailing contact@dirwaas.com or by visiting connepal.com/delete-account.

• Your account is deactivated and hidden from other users immediately.
• During a 30-day grace period, signing in again restores your account.
• After 30 days, your profile, letters (including copies in your pen pals' inboxes, which will then show "this pen pal has left") and photos are permanently erased.
• Minimal records of safety reports and bans may be retained for up to 12 months for abuse prevention and legal compliance. To keep a ban in force, a one-way hash of the email address of a banned account, or of an account found to belong to someone under 18, is kept for as long as the ban applies; it cannot be turned back into the address.

10. Security

Letters and other data are encrypted in transit and at rest by our infrastructure provider. We also use automated filters, rate limits and security logging to protect the Service and its users. The Service does not use end-to-end encryption, which means that data can be accessed on our systems where necessary to operate the Service, and our staff may review reported content and, when investigating a safety concern, the conversation it belongs to. Every such access is logged.

No method of transmission or storage is completely secure, and we cannot guarantee absolute security. Please keep your email account secure, because it is used to sign in to ConnePal and to reset your password, and do not reuse your ConnePal password on other services. If we become aware of a personal data breach that affects you, we will notify you and the relevant authorities where the law requires it.

11. Your rights

Subject to the conditions and exceptions in applicable law, including the Jordanian Personal Data Protection Law No. 24 of 2023 and, where it applies, the GDPR, you may have the right to:

• be informed about how we process your personal data;
• access your personal data and obtain a copy of it;
• correct inaccurate or incomplete data;
• delete your data;
• restrict our processing of your data in certain circumstances;
• object to processing based on our legitimate interests;
• receive your data in a structured, commonly used and machine-readable format, and have it transmitted to another controller (data portability);
• withdraw your consent at any time, where we rely on consent, without affecting processing that took place before you withdrew it; and
• lodge a complaint with a data protection authority, including the competent authority in Jordan or the authority in the country where you live or work.

How to exercise your rights: you can delete your account directly in the Service. For any other request, email contact@dirwaas.com from the email address linked to your account. We may need to verify your identity before acting on your request. We will respond within the time required by applicable law, and in any case within one month where the GDPR applies, extended where the law allows. We will not charge you unless a request is manifestly unfounded or excessive.

Some rights are limited. For example, we cannot delete a letter you sent from another user's inbox unless you delete your account, and we may keep minimal safety records as described in Section 8.

12. Children

ConnePal is only for adults aged 18 and over. We do not knowingly collect personal data from anyone under 18. If we learn that a user is under 18, we will close the account and delete their personal data, except for any minimal records we must keep for child protection, abuse prevention or legal compliance. If you believe a person under 18 is using the Service, please report it in the app or email contact@dirwaas.com.

13. Changes to this policy

We may update this Privacy Policy from time to time. If we make material changes, we will notify you before they take effect, for example by email or by a notice in the Service, and we will update the effective date above. Where the law requires your consent to a change, we will ask for it.

14. Language

This Privacy Policy is available in English and in Arabic. If there is any conflict or inconsistency between the versions, the English version prevails.

15. Contact us

If you have questions about this policy or your personal data, contact us:

• Company: DIRWAAS INTELLIGENT SOLUTIONS LLC, Amman, Jordan
• Email: contact@dirwaas.com
• Website: connepal.com