Privacy Policy

Last updated: 30 September 2026

1. Who We Are

Cpycat Ltd ("Cpycat", "we", "us") is an AI-powered dating and compatibility platform. We are a company registered in England and Wales, company number 17123542, with our registered office at 71-75 Shelton Street, Covent Garden, London WC2H 9JQ. We are the data controller for the personal data processed through cpycat.com.

Contact: cpycatcc@gmail.com

2. What Data We Collect

2.1 Account Data

Email address, display name and username — provided at sign-up and clone creation. Date of birth — provided at the age-confirmation step immediately after sign-up (Cpycat is for adults only) and again when you create your clone; we use it to confirm you are 18 or over and for the optional zodiac features. We also record which version of the Terms you accepted and when.

2.2 Biometric Data (Special Category — Article 9 UK GDPR)

We collect the following biometric data with your explicit consent:

• Face photographs — captured via face scan or uploaded manually. Used to create your visual clone identity.
• Voice recordings — a 30-second voice sample recorded through your browser. Used to create a voice clone via Fish Speech AI.

This data is classified as biometric data under UK GDPR Article 9. We process it solely on the basis of your explicit consent, obtained before any capture begins.

2.3 Personality Data

Writing samples, AI conversation transcripts, personality questionnaire answers — used to train your clone's personality model via the Anthropic Claude API.

2.4 Optional Data

Place of birth, height, weight, zodiac information — provided optionally to enrich your clone's personality.

2.5 Technical Data

IP address, browser type, device information, essential cookies — collected automatically to operate and secure the service.

2.6 Dating Data

When you enable dating, your clone takes part in simulated dates with other members' clones. Each simulated date produces a Date Record and a Compatibility Report, generated from your data. These are shown to the other member in each simulated date. Your contact handle is shared only after mutual approval. Other members never see your account email address or your payment details — only the contact detail you choose to share, which may itself be an email address. They never receive your raw voice recordings or writing samples — only your clone's generated speech and messages. Photographs are shown to a match only from the gallery you have approved, and only once the match reaches the reveal stage.

How we handle biometric data

Face images. To create your clone's appearance we collect the photographs you upload or take with the face scan, and a verification selfie. From them we generate enhanced portraits and a short animated portrait. Face images are biometric data, which is special category data under Article 9 of the UK GDPR. We process them on the basis of your explicit consent under Article 9(2)(a). We ask for that consent before capture begins and record it on your account with the time you gave it; we do not accept face images from an account that has not given it. We keep face images in private storage in Switzerland (AWS Zurich). We share them with fal.ai and D-ID to generate your images and video. We also share them with Anthropic, directly or through Vercel's AI Gateway, to check that a generated portrait still looks like you. fal.ai and D-ID keep copies of the images and videos they make for us, including portraits we reject. When you delete your clone or your account we ask D-ID to delete the videos we have a record of; it may keep other copies under its own terms. We keep a record of the portraits and animated portraits that fal.ai makes for your clone in the background, for the Dating Service or when you ask for a new portrait. For each one we copy into our storage on or after 27 September 2026, we ask fal.ai to delete its copy a day or two after the copy. When you delete your clone or your account, we ask fal.ai to delete every one of them we have a record of, including portraits we rejected and those made before that date. We ask fal.ai to delete a copy by the request number of the run that made it. We do not hold that number for the images fal.ai makes while you wait, when you build your clone or use the Photo Enhancement Studio, so we cannot ask fal.ai to delete them. For the enhanced portraits among them, we keep a link to the copy at fal.ai together with the result of our likeness check, until you delete your clone or your account. fal.ai keeps or deletes those copies under its own terms. In the Dating Service, a member paired with you is shown your clone's generated portrait and the gallery photographs you have approved only after you have both agreed to reveal your faces. If you make your clone public, its public profile and our public Explore page show only AI-generated portraits, to anyone, including people who are not signed in. These are your clone's generated main portrait and, on the profile, any other generated portrait you mark as public. They are made from your photographs, so they show your likeness. The photographs you uploaded or took are never shown on your public profile or on Explore. Only you can make a talking video of your clone. A member paired with you in the Dating Service is told your clone's display name. While any match of yours has not reached the reveal, your clone is not listed on Explore and its public profile shows no portrait, photograph or voice to anyone, so a member paired with you cannot find your face there before the reveal. This applies to every match, including one that has ended. A link to a public portrait that was issued before a match was made stops working within one hour.

Voice recordings. To create your clone's voice we collect the voice sample you record in your browser and the spoken answers you give in the Clarity journey. Voice recordings are biometric data, which is special category data under Article 9 of the UK GDPR. We process them on the basis of your explicit consent under Article 9(2)(a). We ask for that consent before recording begins and record it on your account with the time you gave it; we do not accept recordings from an account that has not given it. We keep your recordings in private storage in Switzerland (AWS Zurich). We send them to Fish Audio, which builds your voice model, holds it for us and generates your clone's speech. When you delete your clone or your account we ask Fish Audio to delete your current voice model and any earlier voice model we have a record of. When your voice is retrained, we ask Fish Audio to delete the model it replaces. A voice model replaced before 27 September 2026 that we kept no record of may remain at Fish Audio. While you speak, the live transcript is made by your browser's own speech recognition. Depending on your browser, that may send your audio to the browser maker. In the Dating Service, a member paired with you hears your clone's generated voice intro, not your recordings. If you make your clone public and confirm the publish notice, its public profile can play a short AI-generated voice preview, but only if your clone has never been in the Dating Service. Your own recordings are never played to anyone else, and other speech generated in your clone's voice is given only to you.

Withdrawing your consent. You withdraw your consent to our processing your face and voice by deleting your clone or your account. If you build a clone again, we ask for your consent again.

Dating preferences. Your dating preferences, including the gender or genders you are interested in, can reveal your sexual orientation, which is special category data under Article 9 of the UK GDPR. We process them only with your explicit consent under Article 9(2)(a), which we ask for when you set your preferences and record on your account with the time you gave it. Until you have given it, your clone is not matched. You can withdraw it at any time by turning dating off in Settings. When you withdraw this consent or turn dating off, we delete your dating preferences, unless we are required to preserve them. You enter them again if you consent again.

Personality data. To create your clone's personality we collect your writing samples, your questionnaire and Clarity answers, and, if you choose to give them, your birth time, place and zodiac details. We process this data because it is necessary to perform our contract with you, under Article 6(1)(b) of the UK GDPR. When you confirm your age and accept our Terms, we record which version of the Terms you accepted and when. We keep this data in our database in Switzerland (AWS Zurich) and send it to Anthropic, which generates your clone's personality and replies. Your date of birth is also held by Clerk, our sign-in provider. Your clone's replies are generated from this data, so they can reflect it. That applies to what your clone says to you and to what it says in your simulated dates. Nobody else can chat with your clone: not a member paired with you, and not a visitor, even if your clone is public. A member paired with you in the Dating Service is told your clone's display name. They also see what your clone says in your simulated dates and the Compatibility Report. The report's scores come partly from both members' profile and personality data (goals and values, personality, lifestyle, demographics, education and career, interests, and reciprocity) and partly from the simulated date itself. If you make your clone public, its bio and a zodiac sign worked out from your date of birth are shown on our public Explore page.

Usage records. Each time our service asks one of our AI or media providers to produce something (a text, a check, a voice, an image or a video), we record the feature, the provider and the model, how much was used (for example the number of word pieces, characters or seconds) and, where we have one, our estimate of what it cost. When the call is made for one member, we also record which account and clone it was for. We use these records to keep the cost of the service under control. They hold nothing that you or your clone wrote or said. We keep them for 13 months. When you delete your clone or your account, the records stay, without your account and clone identifiers.

Clone output. What your clone says and makes — its replies, its generated speech and video, and its part in simulated dates — is generated to deliver the service to you. We process it because it is necessary to perform our contract with you, under Article 6(1)(b) of the UK GDPR. It is labelled as AI-generated. Our providers generate it: Anthropic its words, Fish Audio its speech, D-ID its talking video, and fal.ai its images and animated portrait. What your clone says in a simulated date is shown to the other member in that simulated date and to no other member. Cpycat administrators can view the transcripts of simulated dates through our admin tools.

Date Records. Each simulated date produces a Date Record: the transcript of the date and the account of it written for each of you. We generate it to deliver the service, and we process it because it is necessary to perform our contract with you, under Article 6(1)(b) of the UK GDPR. A Date Record is shown to the other member in that simulated date and to no other member. Anthropic generates the dialogue for us, and Cpycat administrators can view the transcripts of simulated dates through our admin tools. Until it was switched off, a member in a mutual match could put up to ten questions to the other member's clone. The questions and the clone's replies that were stored before then are kept with that match, and only the member who asked them can read them. If you delete your account, the messages you wrote in the Dating Service and any contact details you shared are removed; the Date Record otherwise stays available to the other member.

Compatibility Reports. Each simulated date also produces a Compatibility Report: the scores for how well the two of you matched. We generate it to deliver the service, and we process it because it is necessary to perform our contract with you, under Article 6(1)(b) of the UK GDPR. A Compatibility Report is shown to the other member in that simulated date and to no other member. Cpycat administrators can view compatibility scores and match outcomes through our admin tools. If you delete your account, the Compatibility Report stays available to the other member.

Cpycat Ltd is the controller of this data and is registered with the Information Commissioner's Office, registration number ZC237472.

3. How We Use Your Data

4. Third-Party Data Processors

We share your data with the following processors, all under appropriate data processing agreements:

Where data is transferred outside the UK/EEA, we rely on Standard Contractual Clauses (SCCs) or adequacy decisions.

Requests from law enforcement are handled under our Law Enforcement Policy at cpycat.com/law-enforcement.

5. Data Retention

• Clone data (photos, voice recordings, personality): retained while your account is active. When you delete your clone or your account, we delete it from our database and file storage straight away. We also ask Fish Audio to delete your current voice model and any earlier voice model we have a record of, and D-ID to delete the talking videos made for your clone. We ask fal.ai to delete the portraits and animated portraits it made for your clone in the background that we have a record of. We cannot ask fal.ai to delete the images it made while you waited, when you built your clone or used the Photo Enhancement Studio, because we do not hold the request number fal.ai needs to delete them. Copies our other processors (Section 4) made while providing the service are kept or deleted under their own terms.
• Backups: records deleted from our database stay in our database provider's daily backups until those backups expire, 7 days later. Photos and voice recordings are not included in those backups.
• Date Records and Compatibility Reports: each simulated date produces a single record shared by both members, so it is retained while either account remains active — including after the other member has deleted their account. Any contact detail you chose to share at an introduction likewise stays with the member you shared it with. You can ask us to erase a specific record at any time by emailing cpycatcc@gmail.com.
• Account data: retained while your account is active. When you delete your account, we delete it from our database and file storage, together with your sign-in account at Clerk, our sign-in provider.
• Payment records: We keep a minimal record of each payment (the account ID, the plan, the status and the dates) for 6 years from the date of the deletion, and never less than 7 years after the payment itself, because UK tax rules require it; then we delete it. Stripe keeps its own record of the payment under its own retention rules.
• Usage records: 13 months. After you delete your clone or your account they stay without your account and clone identifiers.
• Records we keep after deletion: an audit record, with your account ID, that a reveal or meeting step took place in the Dating Service, which the service cannot edit or delete; reports made by you or about you, with the copy of the reported content saved with them (Terms Section 7.11); and anything we are required to preserve, for example for a legal claim or a law-enforcement request, until that requirement ends.
• What deletion cannot reach: emails we have already sent, such as a billing notice or a contact detail you shared at an introduction, stay in the recipients' mailboxes, including our own, and in the records of Resend, our email provider. Our hosting provider's function logs, which can include your account ID, are kept for up to 30 days. Rate-limit counters keyed by your account ID or IP address expire on their own within about 60 days.
• Waitlist data: retained until launch, then migrated to account data or deleted.

6. Your Rights (UK GDPR)

You have the right to:

• Access your personal data (Subject Access Request)
• Rectify inaccurate data
• Erase your data ("right to be forgotten") — including the biometric data we hold; we also ask Fish Audio, D-ID and fal.ai to delete the copies we have a record of, and we cannot ask fal.ai to delete the images it made while you waited, because we do not hold the request number fal.ai needs to delete them (Section 5)
• Restrict processing
• Data portability — receive your data in a machine-readable format
• Object to processing based on legitimate interest
• Withdraw consent at any time (this does not affect the lawfulness of processing before withdrawal)
• Lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk

To exercise any right, email cpycatcc@gmail.com or visit Settings → Account & Privacy. We will respond within 30 days.

Self-service: You can export your account data or delete your account from your Account Settings page. Deletion removes your account data subject to the retention periods in Section 5. Each simulated date is a single record shared by both members and is kept while either account remains active. Deleting your account does not remove the other member's copy of a shared Date Record or contact details you chose to share. Payment records are retained for 6 years from the date of the deletion, and never less than 7 years after the payment itself (Section 5).

7. Biometric Data — Specific Protections

Given the sensitive nature of biometric data:

• We obtain explicit, informed, and freely-given consent before any biometric capture
• You can withdraw consent and request deletion at any time
• Biometric data is encrypted in transit, and encrypted at rest in our database and file storage (Supabase)
• Access to biometric data is restricted to essential processing only
• We conduct Data Protection Impact Assessments (DPIAs) for biometric processing

8. Cookies

We use essential cookies only:

• Session cookies — to maintain your logged-in state

We do not set analytics or advertising cookies.

9. Security

We implement appropriate technical and organisational measures including: encryption in transit (TLS 1.2 or higher), encryption at rest in our database and file storage (Supabase), access controls, audit logging, and regular security reviews.

10. Children

Cpycat is not intended for users under 18. We do not knowingly collect data from minors. If we discover we have collected data from a minor, we will delete it immediately.

11. Changes to This Policy

We will notify you of material changes via email or in-app notification at least 14 days before they take effect. A correction that only makes this policy match what we already do takes effect when we publish it. The date at the top of this page shows when this policy was last changed.

12. Contact

Data Controller: Cpycat Ltd
Registered in England and Wales, company number 17123542
Registered office: 71-75 Shelton Street, Covent Garden, London WC2H 9JQ
Email: cpycatcc@gmail.com
ICO Registration: Cpycat Ltd is registered with the Information Commissioner's Office, registration number ZC237472.