Privacy Policy

1. Introduction

Lovendo is committed to protecting your privacy. This Privacy Policy explains how we collect, use, and safeguard your personal information. We comply with the General Data Protection Regulation (GDPR) for EU users and the KVKK (Law No. 6698 on Protection of Personal Data) for Turkish users.

2. Data We Collect

• Account Information: Username, email, phone number, date of birth
• Profile Data: Photos, bio, location preferences, social media links
• Content: Moments, messages, gifts, and media you create or share
• Transaction Data: Payment history, withdrawal records, escrow status
• Usage Data: App interactions, search history, preferences
• Device Information: OS, device type, unique identifiers, IP address

3. Legal Basis for Processing

• Contract: Processing necessary to provide our services to you
• Legitimate Interest: Fraud prevention, security, and service improvement
• Consent: Marketing communications and optional data processing
• Legal Obligation: Compliance with laws and regulatory requirements

4. How We Use Your Data

• Provide and improve our dating and social connection services
• Process payments and manage escrow transactions
• Match you with relevant connections based on preferences
• Send notifications about messages, gifts, and updates
• Ensure platform safety and prevent fraud
• Comply with legal obligations (KYC, AML requirements)
• Analytics to improve user experience

5. Data Sharing

We do not sell your personal data. We share data only in these circumstances:

• Service Providers: Payment processors (PayTR), cloud hosting (Supabase), analytics (PostHog)
• Legal Requirements: When required by law, court order, or regulatory authority
• User Profile: Other users see limited profile information you choose to share
• Business Transfers: In case of merger, acquisition, or sale of assets

6. Data Retention

7. Your Rights

Under GDPR Article 15-22 and KVKK Article 11, you have the following rights:

• Right to Access: Request a copy of your personal data
• Right to Rectification: Correct inaccurate or incomplete data
• Right to Erasure: Request deletion of your personal data ("right to be forgotten")
• Right to Data Portability: Receive your data in a machine-readable format
• Right to Object: Object to processing for marketing or legitimate interests
• Right to Restrict: Limit how we process your data
• Withdraw Consent: Withdraw consent at any time

Exercise Your Rights: Use the in-app "Export Data" or "Delete Account" features, or email us at privacy@lovendo.xyz

8. Data Protection Measures

• Encryption of data in transit (TLS 1.3) and at rest (AES-256)
• Row-Level Security (RLS) on all database tables
• Regular security audits and penetration testing
• Automated anomaly detection for suspicious activity
• GDPR-compliant error sanitization (production only shows generic messages)

9. International Data Transfers

Your data may be transferred to and processed in countries outside the EU/EEA or Turkey. We ensure adequate protection through Standard Contractual Clauses approved by the European Commission or by relying on adequacy decisions where applicable.

10. Children's Privacy

Lovendo is not intended for users under 18 years of age. We do not knowingly collect personal data from minors. If you believe we have collected data from a minor, please contact us immediately.

11. Changes to This Policy

We may update this Privacy Policy periodically. We will notify users of material changes via the app or email. Continued use after changes constitutes acceptance of the updated policy.

12. Contact Us

For privacy-related questions, data requests, or complaints:
Email: privacy@lovendo.xyz
Data Protection Officer: dpo@lovendo.xyz
Address: Lovendo Inc., Istanbul, Turkey

You have the right to lodge a complaint with your local data protection authority (e.g., KVKK Board in Turkey or ICO in the UK).