Privacy Policies
65square – Consolidated Privacy Policies
Last updated: September 4, 2025
This document provides a unified, modernized privacy framework for the 65square ecosystem with app-specific annexes. It replaces all previous versions
1) Who we are
Controllers:
15461812 Canada Inc. (“65square”) – primary controller for commercial products (e.g., Dating Square, 65square for Business). Mailing address: 2949 17 Ave SE, Suite 281 Calgary, AB T2A 1B7.
12981114 Canada Foundation (“DEFEND”) – Nonprofit controller for certain research/safety initiatives and non-profit apps (e.g., Train Those Lips) and may act as joint controller for shared services. Mailing address: 9-3041 Dougall Ave. Windsor, ON, Suite 178, N9E 1S3.
Contact: info@helpusdefend.com
Data Protection Contact: info@helpusdefend.com (we will route to our privacy lead/DPO function)
2) Scope
This Policy applies to the following products (collectively, the “Services”):
Dating Square (18+ only)
Train Those Lips (research/training tool)
65sqan – 3D Scanning
65square Age & Gender Guesser (demo)
65square (core social app) – coming soon
65square for Business – coming soon
Each product’s specifics are in the Annexes. If an Annex conflicts with the main Policy, the Annex controls for that product.
3) What we collect
We collect the categories of data below, depending on the product and your choices:
Account & identifiers: username, email, password (hashed/salted)
Identity & age verification (where applicable): legal name, date of birth, passport photo page image, passport number and nationality (stored with strict access controls), verification results. We treat these as sensitive and limit internal access.
Facial analysis data: When you log in, the app will activate your device’s camera and capture up to 6 low resolution (generally under 500 pixels x 500 pixels) screenshots of your face. These are analyzed (on device only) to estimate age and gender only, to confirm eligibility (e.g., that you meet minimum age requirements) and reduce misuse. This process is mandatory for login and cannot be skipped. With your explicit consent, screenshots may also be retained to train and improve our age and gender estimation models. In addition, our team may manually review screenshots at a later point to help confirm that the person logging in matches the verified account holder. We do not use facial recognition (at no time do we attempt to match face data to any other face images). We will NOT attempt to identify your face against any databases.
Profile & content: photos, bio, interests, preferences, audio clips you upload or create in-appUsage & technical data: app interactions, crash logs, diagnostic events; limited IPs for security/abuse prevention (not for ad tracking);
Communications: reports/complaints, support requests, and their metadata.
We do not sell your personal information and we do not use third-party behavioral ad trackers.
4) Legal & purposes
We process data for:
Service delivery & security (contract + legitimate interests): account creation, authentication, fraud/abuse prevention, keeping under-18s off adult services, and user safety.
Identity verification (consent + substantial public interest/safety where permitted by law): preventing impersonation, bots, catfishing; maintaining a safer community.
Facial analysis & AI model development (consent or legitimate interests with opt-out): login screenshots analyzed for age and gender; optional consent for training/improvement of these models. See Annexes for app-specific opt-out/withdrawal process.
Compliance (legal obligation): responding to lawful requests, safety obligations where applicable, recordkeeping.
Business operations (legitimate interests): analytics to improve performance and reliability; non-promotional communications.
Where we rely on consent, you can withdraw it at any time (see Section 10). If we rely on legitimate interests, you may object.
5) Sharing
We share only as needed:
Service Providers/Processors: hosting, in-app communications (e.g., chat), and security providers. We bind them by contract and restrict use to our instructions.
Affiliates: DEFEND (12981114 Canada Foundation) and subsidiaries for internal operations under this Policy.
Business transfers: as part of a merger/acquisition, with continuity safeguards.
Legal: to comply with law, protect safety, investigate abuse, or defend legal claims.
We do not make user content publicly accessible on the open web unless you choose to publish it in a public area in-app.
6) International transfers
We may process/store data in Canada, the U.S., and other countries where our providers operate. We use appropriate transfer mechanisms (e.g., contractual clauses) and apply equivalent protections, including encryption in transit and at rest, access controls, and audit logging.
7) Retention
We keep personal data only as long as necessary for the purposes above and to meet legal requirements, then delete or irreversibly anonymize it. See Annexes for app-specific timelines. For Dating Square or 65square, face data (login screenshots) are retained for up to 12 months for fraud prevention, audits, and possible lawful responses to police or court requests, then deleted or anonymized. If you close your account, we will delete all of your data no later than 6 months after you initiate closing your account if there are no pending valid (court ordered) legal requests from law enforcement. All login face screenshots are stored securely on our private servers in Kansas City, using encrypted MinIO object storage with strict access controls.
8) Security
We employ layered defenses appropriate to sensitivity: TLS, encrypted storage, least-privilege access, short-lived access tokens, rate-limiting, network segmentation, monitoring, and regular reviews. No method is 100% secure, but we work to continually improve our safeguards.
9) Children
Dating Square: strictly 18+; verified. Under-18s are not permitted.
Other apps: See Annexes. If we discover unpermitted collection from a child, we will delete it.
10) Your rights
Depending on your region, you may have rights to: access, correct, delete, port, restrict/oppose processing, and withdraw consent. You also may have rights not to be subject to automated decisions with legal or similarly significant effects. Contact us to exercise rights. We will respond per applicable laws.
11) Do Not Track & ads
We don’t run advertising in our apps and do not track users for advertising. Because we don’t engage in cross-site behavioral ads, browser “Do Not Track” signals don’t meaningfully apply.
12) Changes
We may update this Policy. We’ll post updates here and, when material, we’ll notify you in-app or via email.
ANNEX A – Dating Square (18+)
Controller: 15461812 Canada Inc.
Age restriction: 18+ only (enforced).
Key data elements:
Identity verification (required at sign-up): legal name, date of birth, gender, face photo found within the passport’s NFC chip, passport number & nationality; verification results.
Facial analysis during login: Your camera is automatically activated and up to 6 low resolution (generally under 500 pixels x 500 pixels) screenshots of your face are captured. These are analyzed to estimate your age and gender, confirm eligibility (18+ only), and discourage impersonation. This is a required step and cannot be bypassed. Our specially trained authorized team may occasionally and randomly manually audit these screenshots at a later point to confirm that the login attempt appears consistent with the verified account holder. With your explicit consent, screenshots may also be used to train and improve our AI models for age and gender estimation. We do not use facial recognition or match facial data against any databases.
Profile: username, email, age, gender, sexual orientation (optional), preferences, photos, bio, interests, location settings you choose.
Communications: reports/complaints and support correspondence.
Purposes & legal bases:
Account creation & security: contract + legitimate interests; identity verification uses consent and/or substantial public interest where applicable. Refusal to verify will block access to 18+ features and will have services terminated without refund.
User safety & moderation: legitimate interests; minimal necessary processing.
AI model improvement: legitimate interests with opt-out or consent depending on region. See “AI training choices” below.
AI training choices:
Login screenshots may be used to improve our age and gender models, but only with your consent. You can opt out by emailing info@helpusdefend.com from your account email. Opting out does not affect the real-time analysis required for login.
Sharing with Service Providers:
We use third-party communications and infrastructure services (for chat APIs, storage). We limit data shared to what’s necessary and bind providers to confidentiality and security obligations. If you’d like details for a specific provider (e.g., Agora), contact us and we’ll provide their privacy notice.
Retention:
Account data: retained during your active subscription and deleted within 6 months after inactivity or confirmed deletion request unless law requires longer.
Login screenshots: For Dating Square or 65square, face data (login screenshots) are retained for up to 12 months for fraud prevention, audits, and possible lawful responses to police or court requests, then deleted or anonymized.
Abuse reports and enforcement records: retained as long as necessary to protect users and meet legal obligations.
Region-specific rights: see Addendum at the end of this document.
ANNEX B – Train Those Lips (research/training tool)
Controller: 12981114 Canada Foundation (DEFEND) with 65square as operator.
What we collect: user-created videos, images, sounds, and voices while you use the app; your ratings/feedback on lip-reading accuracy.
Purposes: to deliver the feature and to train and evaluate our lip-reading AI models and related safety tools.
Consent & opt-out: We rely on your explicit consent for training use. You can stop training use at any time by emailing info@helpusdefend.com with a face image plus approximate date/time of sessions to help us locate the data. We will exclude future data on request and delete prior training clips where feasible, subject to safety/testing constraints and legal obligations.
Access: limited to authorized staff (e.g., AI engineers) under NDAs and least-privilege access.
Retention: research clips are retained only as long as needed for model development/validation, then deleted or irreversibly anonymized. If you withdraw consent, we cease using your future clips and remove identifiable clips from active training sets where feasible.
No third-party public access: content is not published or made publicly accessible.
ANNEX C – 65sqan – 3D Scanning
Controller: 15461812 Canada Inc. (or DEFEND for nonprofit releases).
Data collection: No personal data is required. The app can operate offline. If you choose to export/upload scans to your own storage or to 65square services, those exports will follow the storage location’s policies. This Annex covers only the app in standalone/offline use.
ANNEX D – 65square Age & Gender Guesser (demo)
Controller: 15461812 Canada Inc.
Data collection: The demo does not collect personal data and can be used without an internet connection. If you voluntarily export/share output, that is at your discretion.
ANNEX E – 65square (core app) – Coming Soon
We will publish a detailed Annex before launch, including identity verification options, profile choices, messaging, and safety controls.
ANNEX F – 65square for Business – Coming Soon
We will publish a detailed Annex before launch, including business account data, billing, and team communication features.
Regional Addendum (Rights & Disclosures)
Canada (PIPEDA & provincial laws)
We comply with PIPEDA and applicable provincial regimes. You may access/correct your personal information and file complaints with the Office of the Privacy Commissioner of Canada. We avoid collecting more than necessary for stated purposes and apply heightened safeguards to sensitive identifiers (e.g., passport numbers).
European Economic Area & UK (GDPR/UK GDPR)
Controllers: as listed in Section 1.
Legal bases: contract, legitimate interests (safety/security), consent (verification/training where required), legal obligation.
Your rights: access, rectification, erasure, restriction, objection, portability, and withdrawal of consent; right to lodge a complaint with your local DPA/ICO.
Automated decisions: We do not make decisions with legal or similarly significant effects solely by automated means without your ability to obtain human review.
United States (including California – CCPA/CPRA)
We do not “sell” personal information as defined by CPRA, nor “share” for cross-context behavioral advertising. California residents may exercise CPRA rights (access, deletion, correction, limit use of sensitive PI, and opt-out of sharing/sale—though we do not share/sell). We will not discriminate for exercising rights.
Australia (Privacy Act 1988)
We process personal information in line with the APPs. Where age verification laws or online safety codes apply, we implement proportionate verification and parental tools consistent with this Policy.
How to contact us
Email: info@helpusdefend.com
Mail (Canada – commercial): 15461812 Canada Inc., SUITE 281, 2949 17 Ave SE Calgary, AB T2A 1B7
Mail (Canada – nonprofit): 12981114 Canada Foundation, 9-3041 Dougall Ave. Windsor, ON, Suite 178, N9E 1S3
We aim to respond within 30 days or the period required by your local law.