Privacy Policy

AURELIUS HQS LTD – PRIVACY POLICY
Company Registration Number 17315549
ICO Registration Number
Unit 14, 167, Princeton Mews London Road, Kingston Upon Thames, United Kingdom, KT2 6PT

Updated and Effective 6 October 2026

Introduction

Aurelius HQS Ltd (“Aurelius,” the “Company,” “we,” “us”) is committed to maintaining a safe and trustworthy private community. We understand that privacy and confidentiality are of the utmost importance to our members, applicants and other users (“you”). Your privacy is a priority in everything we do and every feature we develop. This policy (the “Privacy Policy”) describes the information we collect, how it may be used, and with whom it may be shared. We have tried to describe it in plain language, limiting legal and technical jargon where possible.

By using our application (the “App”) and related services (collectively, the “Service”), you agree to be bound by the terms described here. This Privacy Policy applies to all use by you of the Service. We encourage you to read it alongside our Terms of Use and to contact us at info @ weaurelius. com with any questions.

We are the data controller responsible for your personal data. Aurelius HQS Ltd is a company registered in England and Wales. You can contact us at any time at info @ weaurelius. com

We will occasionally update this Privacy Policy to reflect changes in the law, our practices, the features of our Service, or advances in technology. When we make changes, we will revise the “Updated” date above and post the revised policy at https://weaurelius.com/privacy. Your continued use of the Service following changes means you accept the revised policy. If you do not agree to a change, you can close your account at any time as described in our Terms of Use.

Information We Collect

Information you provide when applying for membership. Aurelius is an invitation-only, application-based private network. When you apply, we collect the information you submit as part of your application, which may include your name, email address, telephone number, date of birth, gender, city of residence, photographs, biographical information, occupation and professional details, interests, and your preferences for connections and recommendations. Membership to the App is subject to review and acceptance.

Identity verification. To protect the integrity and safety of the community, we require applicants to verify their identity using government-issued identification (such as a passport). This verification is carried out by a trusted third-party identity-verification provider on our behalf. That provider processes your identity document to confirm it is genuine and that it matches you. We receive the outcome of that verification and limited associated data (such as confirmation of your name, date of birth and verification status). The third-party provider processes your data in accordance with its own privacy policy and applicable data protection law. We retain verification status and related application data as described in the “Retaining Your Information” section below.

Membership assessment. As part of the application process, you may be asked to complete a psychological and behavioural assessment designed to help us evaluate suitability for the community. The responses and results of this assessment are stored together with your application data and are used solely to evaluate and manage your membership, and to support the safety and quality of the community. This assessment and its results may constitute special category data (see “Sensitive / Special Category Data” below), and we process it only with your explicit consent, which you provide when you choose to complete the assessment as part of your application.

Profile information. If your application is accepted, information you provide builds your member profile, which may include your first name, age, city, photographs, occupation, interests, biographical description and other details you choose to share. Some of this information will be viewable by other members of the Service, as described below.

Sensitive / special category data. Some information you provide may be considered “special category” or “sensitive” data under applicable data protection law — including information relating to your racial or ethnic origin and the results of the membership assessment described above. We collect and process such data only where you have given your explicit consent, and you may withdraw that consent at any time by contacting us at contact@weaurelius.com (noting that withdrawing certain consents may mean we can no longer provide the Service to you). You are not required to provide optional sensitive information in order to apply.

Location information. You may be asked to allow us to collect your location. You can choose to allow this always, only while using the App, or not at all, and you can change this at any time through your device settings. Whether you display your location to other members is optional and controlled by you in the App settings. Even where you do not grant location permissions, we may infer your general location (such as city) from your IP address.

Communications with other members. If you communicate with other members through the Service, the content of those communications is transmitted through the App. Member-to-member chat is end-to-end encrypted, which means the content of your messages is encrypted on your device and can only be read by you and the recipient. We cannot read the content of your encrypted messages. We may process limited metadata (such as the fact that a message was sent) to operate the Service.

Information collected automatically. As you use the Service, we automatically collect certain technical information, including your device type and identifier, operating system, IP address, access times, and information about how you interact with the Service and other members.

Information other members provide. Other members may provide information relevant to you — for example, if they report a concern about you, or submit a private post-date review (see below).

Post-date reviews and behavioural information. A core feature of Aurelius is maintaining a safe, accountable community. Members may be invited to provide private feedback and reviews following interactions or dates arranged through the Service. We use this information, together with other behavioural signals (such as patterns of conduct on the platform), to assess members’ conduct, uphold community standards, and make decisions about continued membership. This means we build a picture of how members conduct themselves, and persistent or serious breaches of our standards may result in removal from the Service. We process this information on the basis of our legitimate interests in maintaining the safety, trust and quality of the community (see “Legal Bases” below).

Financial information. We accept payment exclusively through third-party providers such as Apple and Stripe. We never ask for or store your full card details; your financial information is handled by, and subject to the security and privacy policies of, those providers.

Cookies and similar technologies. We and our website may use cookies and similar technologies to recognise you and your device, authenticate you, remember your preferences, and analyse usage. You can manage non-essential cookies through our website’s cookie controls where available and through your browser settings.

How We Share and Use Information

We use the personal information you provide only in connection with operating and improving the Service. We will never sell your personal information, and we do not disclose it to third parties for their own purposes without your permission, except as described below.

Information shared with other members. If you become a member, your profile will be viewable by other accepted members. They will be able to see the information you have chosen to make visible on your profile. A mutual expression of interest (“match”) enables you and another member to communicate through the Service. Applicants who have not been accepted cannot see member profiles.

How we use your information. We use information we collect to: (i) create, verify and manage your account and application; (ii) operate, maintain and improve the Service and develop new features; (iii) facilitate and monitor connections and interactions between members; (iv) assess suitability for and continued eligibility for membership, including through identity verification, the membership assessment, and behavioural information; (v) maintain the safety, security and integrity of the community, including fraud prevention and moderation; (vi) perform research and analytics (internally or using service providers); (vii) communicate with you; and (viii) comply with legal obligations and enforce our Terms of Use.

Service providers. We share personal data with third parties who perform services on our behalf — such as identity verification, cloud hosting, payment processing, and analytics — only to the extent needed to perform those services, and under contracts requiring them to protect your data and use it only for those purposes.

Analytics. We may use third-party analytics services to understand how the Service is used. Information shared with such providers is subject to their own privacy terms.

Legal and corporate situations. We may disclose your information (i) to comply with legal obligations, a court order, or a lawful request from a law enforcement or government authority; (ii) in connection with a significant corporate transaction, such as a sale of our business or assets; or (iii) with your consent or at your request.

Aggregated and non-identifiable information. We may use and share aggregated or non-identifiable information (which does not identify you) with third parties, including advisors, investors and professional service providers, for business purposes.

Legal Bases for Processing

We rely on the following legal bases under UK GDPR to process your information:

  • Performance of a contract — to maintain your account and profile, make it viewable to other members, facilitate connections, and provide the Service you have signed up for.
  • Legitimate interests — to improve and secure the Service, prevent fraud, moderate conduct, operate our post-date review and behavioural-standards processes, and manage our business, provided these interests are not overridden by your rights.
  • Consent — for processing that requires it, including special category data (such as ethnicity information and the membership assessment results) and certain optional features. You may withdraw consent at any time by contacting contact@weaurelius.com.
  • Legal obligation — where we are required to process your information to comply with applicable law.

Keeping Your Information Secure

Security measures. We take the security of your information seriously and have implemented technical and organisational measures to safeguard it, including encryption of member-to-member chat. However, no system is guaranteed to be completely secure, and we cannot promise that your information will always remain secure. If you believe your account or information is no longer secure, please contact us immediately at contact@weaurelius.com.

International data transfers. We are based in the United Kingdom. Where we transfer personal data outside the UK or European Economic Area (for example, to service providers in other countries), we take steps to ensure your data remains protected, including using appropriate safeguards such as UK International Data Transfer Agreements or Standard Contractual Clauses approved for such transfers. You can contact us for more information about these safeguards.

Retaining your information. We keep your personal information only as long as necessary for the purposes described in this policy and as permitted by law. Following account deletion, we apply a safety retention window of three months, during which account information is retained but the account is no longer visible on the App. After this window, we delete or anonymise your information, except where we must retain it to (i) comply with applicable law; (ii) resolve an outstanding issue, claim or dispute; or (iii) pursue legitimate business interests such as fraud prevention and community safety. We may also delete or anonymise information after a prolonged period of account inactivity. Technical constraints mean we cannot guarantee deletion within a specific timeframe.

Your Rights

Under UK data protection law, you have the following rights in respect of your personal information:

  • Access — you can request a copy of the personal information we hold about you.
  • Rectification — you can ask us to correct inaccurate or incomplete information.
  • Erasure — you can ask us to delete your information in certain circumstances.
  • Restriction — you can ask us to restrict processing in certain circumstances, such as where you contest the accuracy of the data.
  • Objection — you can object to processing based on our legitimate interests.
  • Portability — you can ask to receive certain information you provided to us in a portable format.
  • Withdraw consent — where we rely on consent, you can withdraw it at any time.

To exercise any of these rights, contact us at contact@weaurelius.com. For your protection and that of our members, we may ask you to verify your identity before responding. We may decline requests in limited circumstances, including where a request is unlawful, would infringe the rights, privacy, trade secrets or intellectual property of others, or would prevent us from providing the Service (for example, we cannot provide the Service without your date of birth).

Tools to control your information. You can access, update or delete much of your information directly in the App settings, manage device permissions (such as location and notifications) through your device, and delete your account at any time using the in-App function.

Complaints. If you have concerns about how we handle your personal data, you have the right to lodge a complaint with the UK Information Commissioner’s Office (ICO) at ico.org.uk, or with your local supervisory authority if you are in the EEA.

Communications

By using the Service, you agree to receive communications from us relating to your account and the operation of the Service. We may also send you updates about features and promotional matters; you can opt out of non-essential marketing communications at any time.

Age Policy

The Service is restricted to individuals aged 18 and over. Only applicants aged 18 or over will be considered for membership. If we become aware of a user under the age of 18, we will remove them from the Service. We do not knowingly collect or use information from anyone under 18.

Governing Law

This Privacy Policy and your use of the Service are governed by the laws of England and Wales, and are subject to the exclusive jurisdiction of the courts of England and Wales.

How to Contact Us

If you have any questions about this Privacy Policy, please contact us at info @ weaurelius. com

Aurelius HQS Ltd. Registered in England and Wales.