v1.0 — Reviewed by Adv. Tazmeen (Pakistan), June 2026. This is the most sensitive document (CNIC, live location, chat data). Effective date to be set at launch; keep a written confirmation of the review on file.

Rubaru — Privacy Policy

Data Controller: Fumie (SMC-Private) Limited ("Rubaru", "we", "us") Registered office: Office 24, Pakland City Center, I-8 Markaz, Islamabad Privacy contact / Grievance Officer: info@fumie.org Effective date: [to be set at launch] Version: 1.0

This policy explains what personal data Rubaru collects, how we use it, who we share it with, and how long we keep it. It applies to all users of the Rubaru platform.

1. Summary (Plain Language)

• We verify your CNIC once, then delete it. We do not store your CNIC image or number.
• Your exact location is never shown to other users. Only an approximate area is shown, and location data is purged 24 hours after your last active session.
• Your chat messages are scanned by an automated safety system for harassment and abuse, and may be reviewed by staff in connection with reports or legal cases.
• We do not sell your personal data. Aggregated, anonymised venue statistics may be shared with partner venues.

2. Data We Collect

2.1 Account & identity

• Phone number (for OTP login)
• Name, date of birth, gender (verified against CNIC)
• CNIC — collected temporarily for verification only (see section 3)

2.2 Profile

• Bio, hobbies, interests, likes/dislikes, food preferences, cities, favourite spots
• Profile and gallery photos
• Privacy settings (e.g. image visibility: Anyone / Friends only)

2.3 Location

• Device GPS location, stored as a geographic point, used for radius-based discovery and Live sessions

2.4 Activity & content

• Live sessions you host or join
• Friend connections
• Chat messages and shared images
• Ratings you give and receive, Trust Score, badges, achievements

2.5 Technical

• Device identifiers, app version, IP address, log data, push-notification tokens

3. CNIC — Special Handling ("Verify and Discard")

3.1 Your CNIC is submitted only to verify that you are a real, adult Pakistani resident and that your declared gender matches your identity.

3.2 During review, your CNIC is held in a restricted, access-logged review queue. Access is limited to authorised verification staff.

3.3 Upon a decision (approval or rejection), your CNIC image and number are permanently and irreversibly deleted. We retain only:

• a verification flag (verified: yes/no),
• your verified gender,
• the verification date, and
• a one-way hash derived from the CNIC, used solely to prevent the same CNIC creating multiple accounts.

3.4 We cannot recover your CNIC after deletion, and we do not use it for any purpose other than verification and duplicate-prevention.

4. Location Data — Privacy-Preserving by Design

4.1 Your exact GPS coordinates are never disclosed to other users.

4.2 In Browse mode, only an approximate area (neighbourhood level, e.g. "F-7", "I-8") is shown.

4.3 In Live mode, your pin shows a general location, not a street address, until you and another user are matched in an active session.

4.4 Location is updated when you open the app and periodically while you are active.

4.5 Location data is purged 24 hours after your last active session. We do not maintain a long-term history of your movements.

5. Chat and Safety Monitoring

5.1 Chat messages and shared images are processed by an automated AI safety system that scans for harassment, threats, sexually explicit content, and abusive behaviour.

5.2 Where the system flags content, or where a report or dispute is raised, authorised staff may review the relevant messages and metadata.

5.3 Where conduct appears unlawful, related data may be retained and included in a case file for cooperation with authorities (see section 8).

6. How We Use Your Data

We use your data to:

• create and verify your account;
• show you nearby users consistent with your Discovery Preference, and show you to them;
• operate Live sessions, friend connections, and chat;
• calculate Trust Scores, ratings, badges, and enforcement actions;
• keep the platform safe (safety monitoring, fraud and fake-account detection);
• send notifications;
• provide AI features (matchmaking suggestions, icebreakers, activity suggestions);
• comply with Pakistani law and respond to lawful requests.

7. Third Parties That Process Data for Us

We use trusted service providers ("processors") to run the platform. These may include:

• Supabase — database, authentication, storage, realtime (hosted in Singapore, ap-southeast-1)
• Vercel — application hosting
• Twilio — SMS OTP verification
• Firebase Cloud Messaging — push notifications
• Google Maps / Mapbox — maps and location features
• OpenWeatherMap — weather-based suggestions
• Anthropic (Claude API) — AI safety monitoring, matchmaking, icebreakers
• Google Vision API — fake-photo detection
• JazzCash / EasyPaisa / Stripe — payments

These providers process data on our instructions. Some may process or store data outside Pakistan (see section 10).

8. When We Share or Disclose Data

8.1 With other users: only what your settings allow — profile information, approximate location, Trust Score/badges (per the rules in the product), and images per your image-privacy setting.

8.2 With partner venues: only aggregated, anonymised statistics (e.g. number of check-ins). We do not share your identity with venues without your action (such as checking in).

8.3 With authorities: we may disclose data where lawfully required, including to the PTA and the FIA Cybercrime wing, in compliance with PECA 2016 and the 2021 Content Rules, and to protect the safety of users.

8.4 We do not sell your personal data.

9. Data Retention and Deletion

• CNIC: deleted on verification decision (section 3).
• Location: purged 24 hours after last active session (section 4).
• Account data: retained while your account is active.
• On account deletion: we delete or anonymise your personal data within 30 days, except data we must retain for legal, safety, or dispute purposes (e.g. open legal case files, records required under law).
• Safety/legal case files: retained as long as necessary for the matter and as required by law.

You can request deletion of your account at any time via the in-app Settings → Delete account, or by emailing info@fumie.org.

10. International Data Transfers

Some processors (section 7) may store or process data outside Pakistan. Our primary database (Supabase) is hosted in Singapore (ap-southeast-1); other processors may operate in other regions. Where this occurs, we take reasonable steps to ensure your data is handled in line with this policy.

11. Your Rights

Subject to applicable Pakistani law, you may:

• access the personal data we hold about you;
• correct inaccurate data;
• request deletion of your account and data;
• adjust your privacy and visibility settings;
• withdraw consent to optional processing.

To exercise these rights, contact our Privacy/Grievance Officer (above).

12. Security

We use technical and organisational measures to protect your data, including access controls, audit logging on sensitive data (such as the CNIC review queue), and encryption in transit. No system is perfectly secure; we will respond to any breach in line with our legal obligations.

13. Children

Rubaru is strictly for adults (18+). We do not knowingly collect data from anyone under 18. Accounts found to belong to minors are removed.

14. Changes to This Policy

We may update this policy and will notify users of material changes in-app. The "Version" and "Effective date" above indicate the current version.

15. Contact

Privacy questions, requests, and complaints: info@fumie.org (Grievance Officer, Pakistan).

Prepared for Fumie (SMC-Private) Limited. Reviewed by Adv. Tazmeen (Pakistan), June 2026.