Privacy Policy

1. General Information

As the operator of the LOVAFE platform ("Platform"), we take the protection of your personal data very seriously. We process your personal data confidentially and in accordance with applicable data protection laws. This Privacy Policy explains which personal data we process, for what purposes, and which rights you are entitled to under applicable data protection legislation. When you use LOVAFE, various personal data may be processed depending on the nature and scope of your use. Personal data means any information relating to an identified or identifiable natural person.

2. Controller and Data Protection Officer

The sole controller responsible for data processing in connection with LOVAFE is: CG Media UG (haftungsbeschränkt) Theatinerstraße 11, c/o Norton Rose Fulbright LLP80333 Munich, Germany. If you have any questions regarding data protection, wish to obtain information about the collection, processing, or use of your personal data, or wish to request correction or deletion of your personal data, please contact us at the address above or via email at: support@lovafe.com. We have also appointed a Data Protection Officer who can be reached at: sanin@ooda.ai

3. Categories of Personal Data Processed

3.1 Account Data
This includes your name, email address, date of birth, place of residence, and encrypted login credentials.
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‍3.2 Profile Data
We process information you voluntarily provide in your profile, such as profile photos, interests, personal descriptions, relationship preferences, and search criteria.
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‍3.3 Communication and Interaction Data
This includes all content and information generated through the use of our communication and matching features, including messages, interactions with other users (e.g., likes, matches, profile views, communication), and communications with support.
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3.4 Usage Data
We collect information about how you interact with the Platform, including features used, frequency and nature of interactions, and other usage and behavioral data necessary for the provision, security, optimization, and development of our services.
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3.5 Technical Data
When using the Platform, technical information may be generated, including IP addresses, device and operating system information, log data, cookie information, and comparable technical identifiers.

‍3.6 Location Data
If you enable corresponding features, we process GPS coordinates exclusively on the basis of your consent to provide location-based services such as proximity searches, check-ins, or similar functions.
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3.7 Identification Data
If you use identity verification services on the Platform, we process the data required for this purpose through designated service providers.
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3.8 Payment and Billing Data
If you use paid features, we process transaction and billing data (e.g., transaction identifiers, payment dates, and payment amounts). Payment processing itself is carried out by external payment service providers (app store providers).
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‍3.9 Data Processed Through AI Technology
We partially use AI-supported technologies to provide functions such as matching, abuse detection, and moderation support. This may involve processing profile data, interaction data, and usage behavior to the extent necessary. Such processing may include profiling within the meaning of Article 4(4) GDPR to analyze user preferences and provide personalized recommendations and security assessments. No solely automated decision-making within the meaning of Article 22 GDPR takes place.

4. Sensitive Data Processing

LOVAFE may process special categories of personal data within the meaning of Article 9 GDPR, particularly information relating to sexual orientation and other sensitive information (e.g., health data, ethnic origin, or religious beliefs). Such information may be contained in designated profile fields, free-text fields, messages, descriptions, or uploaded content. Such data is processed exclusively on the basis of your explicit consent pursuant to Article 9(2)(a) GDPR.

5. Purposes and Legal Bases of Processing

5.1 Provision of the Platform
We process account, profile, communication, interaction, usage, and technical data to provide all functionalities of the Platform. Legal basis: Article 6(1)(b) GDPR.This includes your name, email address, date of birth, place of residence, and encrypted login credentials.
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‍5.2 Compliance with Legal Obligations
We process personal data where necessary to comply with legal obligations. Legal basis: Article 6(1)(c) GDPR.
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‍5.3 Abuse Prevention and Platform Integrity
We process personal data to ensure the security and integrity of the Platform, including the detection and prevention of spam, bots, fake profiles, fraud, and other misuse. Legal basis: Article 6(1)(f) GDPR.This includes all content and information generated through the use of our communication and matching features, including messages, interactions with other users (e.g., likes, matches, profile views, communication), and communications with support.
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5.4 Recommendation Systems
The Platform uses algorithmic systems to generate profile recommendations, matches, and search results. These systems are based on automated analysis of user behavior and preferences (profiling). Legal basis: Articles 6(1)(b) and 6(1)(f) GDPR.We collect information about how you interact with the Platform, including features used, frequency and nature of interactions, and other usage and behavioral data necessary for the provision, security, optimization, and development of our services.
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5.5 Identity Verification
If you choose to verify your identity, we process the necessary data for authenticity verification, fraud prevention, and compliance with our Terms of Use. Legal basis: Articles 6(1)(a) and 6(1)(b) GDPR.

‍5.6 Processing of Location Data
If location sharing is enabled, we process GPS data to provide location-based functions. Legal basis: Article 6(1)(a) GDPR.
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5.7 Use of AI-Supported Systems
We use AI-supported technologies to enhance functionality, security, and user experience, including personalized recommendations, abuse prevention, and content moderation. Legal basis: Articles 6(1)(b) and 6(1)(f) GDPR. Where special categories of data are processed, Article 9(2)(a) GDPR applies.
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5.8 Improving AI Systems
Personal data may also be used to test, improve, and further develop our AI systems. Where possible, data is aggregated, anonymized, or pseudonymized. Legal basis: Article 6(1)(f) GDPR.
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‍5.9 Special Categories of Personal Data
Special categories of personal data are processed only on the basis of your explicit consent pursuant to Article 9(2)(a) GDPR.

6. Cookies and Similar Technologies

We use cookies and similar technologies to ensure the functionality, security, and usability of the Platform.Necessary cookies are used for technical operation, session management, login functionality, security, and stability and are based on Article 6(1)(f) GDPR. We use Sentry to detect technical errors, ensure platform stability, and improve service security.Functional cookies and analytics or marketing tools are used only with your prior consent pursuant to Article 6(1)(a) GDPR. Further details are available in our Cookie Policy.

7. Disclosure of Personal Data to Third Parties

We disclose personal data to third parties where necessary for providing our services, fulfilling contractual or legal obligations, protecting legitimate interests, or based on your consent.Recipients may include:
• Hosting and infrastructure providers;
• Identity verification providers;
• Moderation and security service providers;
• Payment service providers;
• Security solution providers;
• Analytics providers;
• External AI service providers (OODA AI AB, Sweden);
• Email marketing providers (where consent has been provided);
• Public authorities and government bodies where legally required.
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Where personal data is transferred outside the European Economic Area, such transfers take place only in compliance with applicable legal requirements, including the use of EU Standard Contractual Clauses where necessary.

8. Data Retention

We retain personal data only for as long as necessary for the relevant purposes.
• Profile data is retained until your account is deleted.
• Communication and interaction data is retained in accordance with legal requirements or until deleted by you.
• Log and technical data is generally deleted within 90 days unless longer retention is required for security purposes.
• Backups are regularly overwritten and deleted within a short cycle.
After account deletion, associated personal data will generally be deleted within 30 days unless legal retention obligations require otherwise.

9. Your Rights

You may exercise your rights at any time by contacting us.
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9.1 Right of Access
You have the right to obtain confirmation as to whether we process personal data concerning you and to receive information about such processing.
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9.2 Right to Rectification
You have the right to request correction of inaccurate personal data and completion of incomplete personal data.

9.3 Right to Erasure
Under certain circumstances, you have the right to request deletion of your personal data.
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9.4 Right to Restriction of Processing
You may request restriction of processing where the legal requirements are met.
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9.5 Right to Data Portability
You have the right to receive personal data you provided to us in a structured, commonly used, machine-readable format and to transmit that data to another controller where technically feasible.
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9.6 Rights Regarding Automated Decisions and Profiling
You have the right not to be subject to a decision based solely on automated processing that produces legal effects or similarly significant effects concerning you. Where such procedures are used, you have the right to obtain human review, express your point of view, and contest the decision.
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9.7 Right to Object
You may object at any time to processing based on our legitimate interests for reasons arising from your particular situation. You may also object to direct marketing at any time without providing reasons.
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9.8 Right to Withdraw Consent
Where processing is based on your consent, you may withdraw that consent at any time with future effect.
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9.9 Right to Lodge a Complaint
You have the right to lodge a complaint with a competent data protection supervisory authority if you believe the processing of your personal data violates applicable law.

10. Changes to this Privacy Policy

We reserve the right to amend this Privacy Policy where required by law or where necessary due to further development of the Platform. The current version is always available in the app and on our website.

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