Draft text. Not yet reviewed by a lawyer; bracketed fields are still to be completed.
Privacy Policy
Last updated: [DATE]
1. Data controller
Your personal data is processed by [COMPANY NAME] ([ADDRESS], [EMAIL]) as data controller, under the Turkish Personal Data Protection Law (KVKK) and, where it applies, the EU and UK General Data Protection Regulation (GDPR).
2. What we process
Account: email address, date of birth, sign-in details.
Profile: display name, gender, bio, photos, interests, languages, optional profession, what you are looking for, who you want to see and your age-range preference.
Location: your device location and its accuracy, only while you are "Live" and the app is open. In venue mode, the venue you checked in to.
Activity: likes, matches, messages, Hellos and gifts, game answers, blocks, reports, "we met" confirmations and your private post-meeting answers, venue suggestions, "tonight" plans.
Purchases: subscription status and credit balance. Your card and payment details never reach us; the store handles them.
Technical: push token (if you allow notifications), language, and request counts used to prevent abuse.
3. About location data
Your location is never tracked in the background. It is taken only while you are Live and used to work out who is near you.
Only your latest position is kept on the server; no movement history is recorded. The record is deleted when your session ends or you go invisible.
Other users are never shown your coordinates, a map position or a distance — only "Within 50m", "Within 100m" or "Same venue".
4. Purposes and legal bases
Creating your account, matching you with people nearby and enabling chat: performance of our contract with you.
Processing your location, and preferences that may reveal sexual orientation: your explicit consent. You can withdraw it at any time; location permission can be switched off in your device settings.
Safety, reviewing reports, preventing fake accounts and abuse: our legitimate interests and legal obligations.
Subscription and purchase records: contract and statutory record-keeping.
5. What other users see
People near you who meet the mutual-visibility rules see your display name, age (not your date of birth), photos, bio, interests, what you are looking for, your badges and — if you chose to show them — your profession and the gifts you received.
Your post-meeting answers and your reports are never shown to other users.
If you switch on "Show me to Premium members exploring my venue", Premium members who are not at that venue can also see your profile while you are Live there. This is off by default.
6. Who receives your data
Hosting and database: Supabase (servers in the European Union, Frankfurt).
Venue information: Google Places. To list venues around you, your location is sent to Google without being linked to your identity.
Payments: Apple App Store, Google Play, and RevenueCat for subscription management.
Notifications: Expo and your device's push service (Apple or Google).
Authorities where the law requires it. We do not sell your data for advertising.
Some of these providers are outside your country. International transfers are made under the safeguards required by KVKK Article 9 and the GDPR. [LAWYER: state the transfer mechanism]
7. How long we keep it
Live location record: for the session; deleted when it ends.
Venue check-ins: 24 hours. "Tonight" plans: 18 hours. Request-count records: 2 days.
Profile, matches and messages: while your account exists.
When you delete your account, your profile, photos, matches and messages are deleted. Records we are legally required to keep (for example purchase records) are kept for the required period. [LAWYER: confirm periods]
8. Your rights
Under KVKK Article 11 and the GDPR you can ask whether we process your data, request information, correction or deletion, object to processing, withdraw consent and ask for a copy of your data.
Send requests to [EMAIL]; we reply within 30 days. You can also complain to the Turkish Personal Data Protection Board or the data protection authority where you live.
9. Security
Data travels over encrypted connections. Location data cannot be read through the app directly; only the server-side matching functions use it. Access is permission-based and request limits guard against abuse. No system is perfectly secure; if a breach occurs we will meet our legal notification duties.
10. Children
The App is not for anyone under 18 and we do not knowingly collect their data. If you notice such an account, please report it.
11. Changes
We may update this policy and will tell you in the App about significant changes.