Privacy Policy

In short

• Kiss or Slap is only for people who are 18 or older.
• We store an approximate location. Other people see only a distance bucket, never your exact location, and never your birth date.
• Slaps are private. Ratings are anonymous and shown only in aggregate.
• We do not sell your data and we do not show ads. We use no analytics or advertising trackers.
• Sensitive details, such as ethnicity, are optional and need your separate, explicit consent.
• You can download your data, withdraw consents or delete your account in Settings at any time.

Who is responsible for your data

The data controller is [Operator name, registration no., address] (“we”, “us”).

For any question, privacy request or appeal, write to support@kissorslap.it-ist.ro.

Kiss or Slap is a dating service, so some of the data we handle is personal and some is sensitive. We try to collect as little as we need and to keep it for as short a time as we can.

What data we collect

Data you give us:

• Account: your email address (we send you a one-time code to sign in; there is no password).
• Profile: display name, date of birth (used to check that you are 18 or older and to show your age), photos, bio, gender and who you are interested in.
• Optional profile details: interests, what you are looking for, prompts and answers, height, job, company, school, the city you live in, languages, pronouns, diet, lifestyle details, and, only with your separate consent, ethnicity.
• Approximate location, rounded to a grid of about 1 km, which you share with your consent.
• Your activity: Kisses, Slaps and French Kisses you send, notes attached to a Kiss, Undos, blocks and reports you file.
• Conversations: messages, reactions, gifts, game results, and your read-receipt setting.
• Ratings you give to people you matched with.
• Games: your “this or that” picks, guesses, daily question votes and answers in games with matches.
• Kisses: your balance, a history of what you earned and spent, perks, and daily check-ins.
• Invitations: your invite code, the code you entered if someone invited you, and a coded form of your email address (see Retention).
• Settings and choices: language, distance unit, notifications, sounds, and the consents you gave or withdrew, with dates and the version of the text.
• Messages you send to our support email.

Data created while you use the app: when you were last active, how complete your profile is, your Daily picks, your push notification subscription (a technical address given by your browser), sign-in sessions, short-lived anti-abuse counters, and technical server logs such as IP address and time of requests.

Data about you from other people: ratings given to you, reports about you, and Kisses, notes or game guesses involving you.

What we do not collect: your exact GPS position for display, your contact list, your device advertising ID. Our own database does not store your IP address or browser details; our sign-in service and servers may handle them, as explained below.

Sensitive data

Some of the data you may give us can reveal sensitive things about you. Your gender and who you are interested in can indirectly reveal your sexual orientation. Pronouns can reveal your gender identity. Diet can reveal religion or health. Ethnicity reveals racial or ethnic origin. Your photos, bio, prompts and messages can reveal anything you choose to write. We ask you not to share health or religion details in free-text fields.

We process gender, who you are interested in, diet and pronouns only with your explicit consent, given separately at sign-up (the “sensitive data” consent). We process ethnicity, and the ethnicity filter in Discovery, only with a further separate, optional explicit consent that names this category. Ethnicity is hidden by default: other people see it only if you switch on “Show on profile”, and values you hide are never shown or used for filtering.

You can withdraw these consents at any time in Settings. If you withdraw the “sensitive data” consent, the data covered by it is cleared and your profile is hidden until you restore it. If you withdraw the ethnicity consent, your ethnicity and your ethnicity filter are cleared. Your account is not deleted.

We do not show a sexual orientation field on profiles. Moderators never see sensitive fields such as ethnicity in report evidence.

Why we use your data and our legal bases

We use your data only for the purposes below. Where the GDPR or UK GDPR applies, this is the legal basis for each:

• Running your account, signing you in and keeping sessions secure: performance of the contract with you (Art. 6(1)(b)).
• Showing your profile, discovery, matching, chat, Circles, Daily picks, games, Kisses and perks: performance of the contract (Art. 6(1)(b)).
• Checking and enforcing the 18+ rule: our legal duties and legitimate interest in protecting minors (Art. 6(1)(c) and (f)).
• Using your approximate location to show distance: your consent (Art. 6(1)(a)), which you can withdraw.
• Gender, who you are interested in, diet, pronouns, ethnicity and the ethnicity filter: your explicit consent (Art. 9(2)(a)).
• Sending push notifications: your consent, given through your browser’s permission prompt (Art. 6(1)(a)).
• Ratings between people who have matched, and showing aggregates: our legitimate interest in trust and safety between people on the service (Art. 6(1)(f)). You can object to this.
• Safety and moderation: handling reports and blocks, preventing spam, abuse and fraud, rate limits, preventing banned people from returning, preventing repeat referral rewards, and keeping the service secure: our legitimate interest (Art. 6(1)(f)), and our legal obligations where they apply, such as telling you the reasons for a decision (Art. 6(1)(c)).
• Invitations and referral rewards: performance of the contract and our legitimate interest in preventing fraud.
• Keeping proof of the consents you gave, and defending legal claims: our legitimate interest and legal obligations (Art. 6(1)(c) and (f)).
• Sending the emails the service needs, such as the sign-in code and decision notices: performance of the contract and legal obligations.
• Answering authorities and courts when the law requires it: legal obligation (Art. 6(1)(c)).

Where we rely on legitimate interests, we weigh them against your rights and interests, and you can object (see “Your rights”). We do not use your data for advertising, we do not sell it, and we do not build advertising profiles.

Who can see what

Other people on Kiss or Slap see only what is needed:

• People who see you in their feed see your photos, name, age, a distance bucket (2, 5, 10, 25, 50 or 100 km, or more than 100 km), and the details you chose to add, such as what you are looking for, interests, job, school and height. They may also see a “recently active” badge (active in the last 24 hours), a “Plans today” badge, a “Test profile” or boost label where it applies. Your matches can open more of your profile.
• Nobody sees your exact location, your birth date, your email address, or the exact time you were last active.
• Slaps are private. The other person is not told. A Kiss is not shown to the person unless you match, with two exceptions: someone who uses the “see who Kissed you” perk can see people who Kissed them and who would also appear in their feed, and a French Kiss shows a badge on your card to the person who receives it.
• A note attached to a Kiss becomes a chat message only when you match. Unmatched notes are cleared after 30 days.
• Your matches see your conversation with them. Read receipts and the typing indicator are on by default; if you turn your read receipts off, you will not see others’ either.
• Ratings: only you and the people you are currently matched with can see your rating summary. It is published in weekly batches, only once enough different people have rated you, with a rounded average and a coarse count (for example “3+”). Nobody ever sees who rated whom, or any single rating.
• Games: your “this or that” picks can be revealed one at a time to people who guess them, namely your matches and people who currently have you in their feed (at most 3 guesses per person who is not a match). Daily question results are shown only as percentages, after enough people have voted.
• Invitations: the person who invited you sees only a count of rewarded invitations, never who joined.
• If someone reports you, you are not told who. Our moderators see people through pseudonymous identifiers, and never see location, birth date or sensitive fields.
• Some profiles are test or demo profiles created by us. They are always labelled “Test profile”.

Photos are kept in private storage and are shown only through short-lived links.

Who we share data with

Kiss or Slap runs on our own server in Romania (EU), operated by us. We use no analytics services and no advertising networks. We share data only with the following:

• Brevo, an email delivery provider in the EU: receives your email address and the content of the emails we send, such as the sign-in code and decision notices.
• Cloudflare (Turnstile), a bot-protection service used at sign-in: runs in your browser and processes technical signals such as your IP address and browser details to tell people from bots. Cloudflare is a US company.
• Your browser’s push service (for example Google, Apple, Mozilla or Microsoft), only if you turn on notifications: it receives the technical address of your subscription, your IP address, and a generic text such as “New match” or “New message”. We never put names or message text in a notification.
• Other people on the service, as described in “Who can see what”.
• Authorities, courts and other third parties, when the law requires it or when it is necessary to protect people or to defend legal claims.
• Professional advisers who are bound by confidentiality, and a buyer or successor if the service is ever transferred, in which case you will be told.

We do not sell your personal data and we do not share it for cross-context behavioural advertising.

International transfers

Your profile, photos, messages and other data are stored and processed on our server in Romania, in the European Union. We do not transfer them outside the European Economic Area ourselves.

Some of the services in the previous section may process limited technical data outside the EEA or the UK: Cloudflare (Turnstile) and the push services run by browser providers. Where that happens, we rely on the safeguards the law allows, such as an adequacy decision or standard contractual clauses (and their UK equivalents). Push notifications happen only if you turn them on.

You can ask us for more information about these safeguards at support@kissorslap.it-ist.ro.

How long we keep data

We keep your data while your account exists, unless this section says otherwise. You can delete your account at any time. If you do not open the app for 30 days, your profile is hidden from other people’s feeds, but your account stays until you delete it.

• Account, profile, photos, matches, messages, ratings, game data, Kisses history: until you delete your account. A conversation is deleted for both people when either of you unmatches.
• After you delete your account: your data is removed from our live systems and your photo files are deleted. Copies may stay in our backups for up to 14 days before they are overwritten.
• Sign-in: sessions end after 14 days without use, and after 30 days at most. Old session records are removed after 30 days, and the sign-in audit log after 90 days.
• Proof of consent: after you delete your account, we keep a coded (pseudonymised) record of the consents you gave for 3 years.
• Reports: the conversation copy and profile snapshot kept as evidence are deleted after 90 days. The report record itself is kept for 2 years and is not linked to your account after deletion. The moderation log is kept for 2 years, and decision notices for 1 year after you acknowledge them. Ban emails are removed from our mail queue 30 days after they are sent.
• Banned people: a coded form of the email address is kept while the ban lasts, and for at most 2 years.
• Referral rewards: a coded form of the invited person’s email address is kept for 12 months after the reward, even if the account is deleted, to stop repeat rewards. It is not linked to any account.
• Notes on Kisses that did not lead to a match: 30 days.
• Daily picks: 2 days. Daily question votes: 30 days. Answers to expired match games: 7 days after the game expires. Expired perks: 7 days after they expire. Push notification queue: 7 days.
• Anti-abuse counters (for example for Undos, reactions, Plans today switches, ratings, games and invitation code attempts): from 1 hour to 2 days. They contain no message content.
• Ratings: until the account of the person who gave or received them is deleted, or until a moderator voids them.
• Technical server logs: only as long as needed for security and troubleshooting.

We may keep data for longer where the law requires it, or where it is needed to establish, exercise or defend a legal claim.

Your rights and how to use them

Under the GDPR and UK GDPR you have the rights below. Most of them you can use yourself in the app, in Settings:

• Access and portability: “Download my data” gives you a file with your data and photos in a common, machine-readable format.
• Rectification: edit your profile at any time. Your date of birth is locked, so ask us to correct it.
• Erasure: “Delete my account” removes your account and data, as described under “How long we keep data”. For safety, you must have signed in recently with a fresh email code.
• Restriction: you can hide your profile at any time, and your matches and chats keep working. You can also ask us to restrict processing.
• Withdrawing consent: in “Consents and legal documents” you can withdraw consent to location, sensitive data and ethnicity. Withdrawing location or sensitive data hides your profile and clears the data until you consent again. You cannot withdraw your confirmation that you are 18 or older, but you can delete your account instead.
• Objection: you can object to processing that is based on our legitimate interest, for example ratings.
• No decisions based only on automated processing that have a legal or similarly significant effect.
• Complaint: see the next section.

You can also write to support@kissorslap.it-ist.ro. We reply within one month, which the law lets us extend by up to two months for complex requests. We may need to check who you are, and signing in is usually enough. We normally do not charge for requests.

We may not be able to give you everything you ask for, for example where it would reveal another person’s data. We do not reveal who rated or reported you, and your access file shows rating summaries, not individual ratings.

Complaints to a supervisory authority

You have the right to complain to a data protection authority. In Romania, where we are based, this is ANSPDCP (dataprotection.ro). If you live elsewhere in the EU or EEA, you can complain to your local authority (list of authorities). In the UK, it is the Information Commissioner’s Office. In other countries, contact your local authority.

We would be glad to hear from you first at support@kissorslap.it-ist.ro, so we can try to put things right.

Children

Kiss or Slap is only for people aged 18 or older. We do not knowingly collect data from anyone under 18. We check your date of birth at sign-up, and our database refuses accounts for people under 18.

If you think someone under 18 is using the service, please report the profile or write to support@kissorslap.it-ist.ro. We treat these reports as top priority and delete the data of accounts that belong to minors.

How we protect your data

We use technical and organisational measures that fit the risk. In general terms:

• Connections to the app are encrypted (HTTPS).
• Photos are in private storage and shown through short-lived links. Hidden data is removed from photos on your device before upload.
• Database access rules make sure that each person can reach only the data they are allowed to see.
• You sign in with a one-time email code. Sessions expire, and there are rate limits and bot protection on sign-in.
• Access for our team is limited to the roles we grant. Moderators see pseudonymised information, and moderation tools require two-step verification in production.
• We keep as little as we can and delete short-lived data automatically.

No system is perfectly secure. If a data breach affects you, we will inform you and the authorities as the law requires.

Automated processing and profiling

We use automated rules to decide who appears in your feed and in which order. We apply your filters (age, distance, who you are interested in, and the optional “looking for” and ethnicity filters), blocks and pauses. We then order profiles by distance bucket, recent activity and verified status, and give a profile a temporary boost where a person has used that perk.

“Circles” and “Daily picks” group or score profiles using shared interests, the same “looking for”, recent activity and profile completeness. We never use ethnicity or your ratings to score or rank profiles. Ethnicity is only a filter that you choose to set yourself, and only visible values are used.

This is a recommendation of who you might like to see. It has no legal effect on you and does not significantly affect you in a similar way. Decisions to warn, suspend or ban an account are made by people, not only by automated means. Automatic safety limits and the refusal of sign-up with an email address that was banned before do exist, and you can ask for a person to review them at support@kissorslap.it-ist.ro.

Cookies and similar storage

We use only what is needed to run the app and remember your choices. We use no advertising or analytics cookies or trackers.

• Sign-in cookies, which keep you signed in.
• A language cookie, which remembers your language.
• An invitation cookie, set for up to 30 days only when you open an invite link, which holds the invite code.
• Storage on your device for your preferences and small interface flags: for example the sounds and vibration setting, which “What’s new” notice you have seen, and tips you have dismissed.
• The app’s service worker, which keeps the app shell and logos to load faster and show an offline page. It does not store your personal data.

The Cloudflare Turnstile widget at sign-in may use its own technical storage to tell people from bots. You can clear cookies and storage in your browser settings, but sign-in will not work if you block the necessary ones.

California residents (CCPA/CPRA)

To the extent the California Consumer Privacy Act, as amended (CCPA/CPRA), applies to us, this section gives California residents the required information. We do not sell personal information, and we do not share it for cross-context behavioural advertising. We have not done so in the past 12 months. We do not knowingly sell or share the data of anyone under 16, because the service is for people 18 and older.

In the past 12 months we collected these categories of personal information, as described in “What data we collect”:

• Identifiers, such as your email address and display name.
• Personal characteristics, such as date of birth or age, gender and, if you add it, ethnicity.
• Photos and other visual information.
• Approximate location (a grid of about 1 km).
• Activity in the app, such as Kisses, Slaps, matches, games and ratings.
• The content of your messages and profile text.
• Sensitive personal information: ethnicity (optional), the content of private messages, and information that can reveal sex life or sexual orientation (gender and who you are interested in).

We collect this from you and from your device, and from other people (for example ratings). We use it for the purposes described in “Why we use your data”. We disclose it only to the service providers in “Who we share data with”, for business purposes. We use sensitive personal information only to provide the features you chose, for security and for legal compliance.

California residents can ask to know and access their data, delete it, correct it, and not be discriminated against for using these rights. Because we do not sell or share personal information, there is no opt-out to apply. Use Settings (“Download my data”, “Delete my account”) or write to support@kissorslap.it-ist.ro. We verify requests through your signed-in account or your email address. An authorised agent can write to us with proof of authority. We respond within 45 days, which can be extended by another 45 days.

Changes to this policy

We may update this policy, for example when we add features or when the law changes. The “last updated” date is at the top of this page. If a change is important, we will tell you in the app before it applies and, where the law requires, ask for your consent again.

Contact

Questions, privacy requests and appeals: support@kissorslap.it-ist.ro. Controller: [Operator name, registration no., address].