Privacy Policy

1. Introduction

Welcome to **Kisloba** ("we," "us," or "our"). Kisloba is a dating and social networking application operated by **Kisloba S.R.L.**, a company registered in Romania, with its registered office in Bucharest, Romania.

We are committed to protecting your privacy and personal data in accordance with the **General Data Protection Regulation (EU) 2016/679 ("GDPR")**, Romanian Law No. 190/2018 on implementing the GDPR, and other applicable data protection legislation.

This Privacy Policy explains how we collect, use, store, share, and protect your personal data when you use the Kisloba mobile application and related services (collectively, the "Service").

2. Data Controller

The data controller responsible for your personal data is:

3. Data We Collect

We collect the following categories of personal data when you register and use Kisloba:

3.1 Information You Provide

• Account Information: name, email address, phone number, date of birth, gender, and login credentials.
• Profile Information: photos, bio/description, interests, preferences (e.g., age range, distance, gender preferences), occupation, education.
• Verification Data: selfie photos or videos used for identity verification.
• Communications: messages you send and receive through the app, reports, and feedback you submit.
• Payment Information: transaction details for premium subscriptions or in-app purchases (payment processing is handled by third-party providers; we do not store full credit card numbers).

3.2 Information Collected Automatically

• Device Information: device type, operating system, unique device identifiers, IP address, browser type.
• Location Data: approximate or precise geolocation (with your consent) to show nearby users and enable distance-based matching.
• Usage Data: how you interact with the app (e.g., swipes, matches, time spent, features used).
• Cookies & Tracking Technologies: we use cookies, pixel tags, and similar technologies on our website and app.

3.3 Information from Third Parties

• Social media platforms (e.g., if you sign up using Google or Apple).
• Analytics and advertising partners.

4. Legal Basis for Processing

Under the GDPR, we process your personal data based on the following legal grounds:

• Contractual Necessity (Art. 6(1)(b) GDPR): to provide and maintain the Service, including matching, messaging, and account management.
• Consent (Art. 6(1)(a) GDPR): for optional features such as precise geolocation, photo verification, and marketing communications. You may withdraw consent at any time.
• Legitimate Interest (Art. 6(1)(f) GDPR): for fraud prevention, security enforcement, analytics, and improving the Service.
• Legal Obligation (Art. 6(1)(c) GDPR): where required by law, such as responding to lawful requests from authorities.

5. How We Use Your Data

• Create and manage your account.
• Provide matchmaking and discovery features.
• Enable messaging and social interactions.
• Process payments and manage subscriptions.
• Verify your identity and prevent fraud.
• Send you service-related notifications and, with your consent, promotional communications.
• Analyze usage to improve the app experience.
• Ensure safety by detecting and preventing abusive or harmful behavior.
• Comply with legal obligations.

6. Data Sharing & Disclosure

We may share your personal data with:

• Other Users: your profile information (name, photos, bio, age) is visible to other users as part of the core dating functionality.
• Service Providers: cloud hosting, payment processors, analytics, customer support, and moderation tools.
• Legal Authorities: when required by law, court order, or to protect the safety of our users.
• Business Transfers: in connection with a merger, acquisition, or sale of assets.

We do not sell your personal data to third parties.

7. International Data Transfers

Your data may be transferred to and processed in countries outside the European Economic Area (EEA). In such cases, we ensure adequate safeguards are in place, including:

• EU Standard Contractual Clauses (SCCs) approved by the European Commission.
• Adequacy decisions by the European Commission for certain countries.
• Other legally recognized transfer mechanisms.

8. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes described in this policy:

• Active Account: data is retained while your account is active.
• Account Deletion: upon account deletion, your data is removed within 90 days, except where we are required by law to retain it (e.g., for tax or fraud prevention purposes).
• Messages: messages are retained for up to 1 year after account inactivity, then permanently deleted.
• Inactive Accounts: accounts inactive for more than 24 months may be automatically deleted after prior notification.

9. Your Rights Under GDPR

As a data subject, you have the following rights:

• Right of Access (Art. 15): obtain a copy of your personal data.
• Right to Rectification (Art. 16): correct inaccurate or incomplete data.
• Right to Erasure (Art. 17): request deletion of your personal data ("right to be forgotten").
• Right to Restriction (Art. 18): restrict processing under certain circumstances.
• Right to Data Portability (Art. 20): receive your data in a structured, machine-readable format.
• Right to Object (Art. 21): object to processing based on legitimate interest or direct marketing.
• Right to Withdraw Consent: withdraw consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, contact us at privacy@kisloba.com. We will respond within 30 days.

You also have the right to lodge a complaint with the Romanian National Supervisory Authority for Personal Data Processing (ANSPDCP):

10. Data Security

We implement appropriate technical and organizational measures to protect your personal data, including:

• Encryption of data in transit (TLS/SSL) and at rest.
• Regular security audits and vulnerability testing.
• Access controls and authentication mechanisms.
• Employee training on data protection.
• Incident response procedures for data breaches.

While we take every reasonable precaution, no system is 100% secure. We encourage you to use strong passwords and enable two-factor authentication.

11. Age Restrictions

Kisloba is intended for users aged 18 and older. We do not knowingly collect personal data from anyone under 18. If we become aware that a minor has provided us with personal data, we will take steps to delete such data immediately.

12. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any significant changes via in-app notifications or email. The "Last updated" date at the top reflects the most recent revision.

We encourage you to review this policy periodically to stay informed about how we protect your personal data.

13. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or your personal data, please contact us: