Data Processing Agreement

Legal Basis for Processing

Consent (Article 6(1)(a)): You have given clear consent for us to process your personal data for specific purposes, including AI-powered analysis of dating conversations and profile optimization.

Contract Performance: Processing is necessary for the performance of our service agreement with you, including providing personalized icebreakers, conversation analysis, and dating advice.

Legitimate Interests: Processing is necessary for our legitimate interests, such as improving service quality, preventing fraud, and ensuring platform security, provided these do not override your fundamental rights.

Legal Obligations: Processing is necessary to comply with applicable legal requirements, including data retention laws and law enforcement cooperation where legally mandated.

Withdraw Consent: You may withdraw your consent at any time without affecting the lawfulness of processing based on consent before its withdrawal. Withdrawal can be done through app settings or by contacting our DPO.

Types of Data We Process

Profile Information: Name, age, gender, dating preferences, bio text, and other profile details you provide during account creation and setup.

Conversations: Chat messages and conversation history between you and Loveberry's AI assistant, including questions asked and advice provided.

Photos and Screenshots: Dating app screenshots, profile photos, and conversation screenshots you upload for analysis and icebreaker generation.

Usage Analytics: Feature usage patterns, interaction frequency, session duration, and in-app navigation data used to improve service quality.

Device Information: Device type, operating system, app version, and unique device identifiers required for service delivery and security purposes.

Connections Data: Information about your dating connections, relationship status tracking, and interaction history managed within the app.

AI Processing Activities

Conversation Pattern Analysis: AI analyzes uploaded conversation screenshots to identify communication patterns, tone, and context for generating relevant reply suggestions.

Dating Profile Optimization: AI reviews your dating profiles and match profiles to provide personalized icebreaker suggestions and conversation starters.

Relationship Advice Generation: AI processes conversation context and user queries to provide personalized dating guidance and relationship insights.

Anonymized Model Training: De-identified and aggregated data may be used to improve AI model accuracy. Individual users cannot be identified from training data.

Natural Language Processing (NLP): Text analysis of conversations and profiles to understand sentiment, intent, and communication style for better recommendations.

Pattern Recognition: Identification of successful conversation patterns and relationship dynamics to inform advice quality and relevance.

Data Protection Measures

End-to-End Encryption: All data transmitted between your device and our servers is encrypted using industry-standard TLS 1.3 protocols, ensuring data integrity in transit.

Data Minimization: We collect only the minimum amount of data necessary to provide our services. Unnecessary data fields are never requested or stored.

Purpose Limitation: Your data is processed exclusively for the purposes stated in this agreement and our privacy policy. We never sell or share data for unrelated purposes.

90-Day Auto-Delete: Uploaded screenshots and temporary processing data are automatically deleted after 90 days. You can request earlier deletion at any time.

Access Controls: Strict role-based access controls ensure only authorized personnel can access personal data, with all access logged and audited.

Regular Security Audits: We conduct periodic security assessments and penetration testing to identify and address potential vulnerabilities proactively.

Anonymization and Pseudonymization: Where possible, data is anonymized or pseudonymized to reduce privacy risks during processing and storage.

International Data Transfers

Server Locations: Primary data processing occurs on servers located in the United States. Backup and redundancy systems may be located in the European Union.

Standard Contractual Clauses (SCCs): For transfers outside the EEA, we rely on European Commission-approved Standard Contractual Clauses to ensure adequate data protection.

GDPR Chapter V Compliance: All international data transfers comply with GDPR Chapter V requirements, including adequacy decisions and appropriate safeguards.

Certified Data Centers: Our infrastructure providers maintain SOC 2 Type II, ISO 27001, and other relevant certifications ensuring physical and logical security of data.

Your Rights Under GDPR/CCPA

Right of Access: You can request a complete copy of all personal data we hold about you, provided in a commonly used electronic format within 30 days.

Right to Rectification: You can request correction of any inaccurate or incomplete personal data we hold about you at any time through the app or by contacting us.

Right to Erasure ("Right to be Forgotten"): You can request deletion of your personal data when it is no longer necessary for the purposes for which it was collected.

Right to Restrict Processing: You can request that we limit the processing of your personal data in certain circumstances, such as when you contest data accuracy.

Right to Data Portability: You can request to receive your personal data in a structured, commonly used, machine-readable format and transmit it to another controller.

Right to Object: You can object to processing based on legitimate interests or for direct marketing purposes. We will cease processing unless compelling legitimate grounds exist.

Right to Withdraw Consent: Where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.

Right to Lodge a Complaint: You have the right to lodge a complaint with a supervisory authority if you believe your data protection rights have been violated.

Data Retention Periods

Active User Data: Profile information and preferences are retained for the duration of your active account. Data is preserved as long as you maintain an active account with us.

Screenshots: Uploaded screenshots and images are automatically deleted after 90 days. You may request immediate deletion at any time through app settings.

Conversations: Chat history with Loveberry is retained for 6 months, after which it is anonymized and aggregated for service improvement purposes.

Analytics Data: Usage analytics and behavioral data are retained for 12 months in identifiable form, then anonymized for long-term trend analysis.

Legal Requirements: Certain data may be retained longer if required by applicable laws, regulations, or legal proceedings, even after account deletion.

Deleted Accounts: Upon account deletion, all personal data is permanently removed within 30 days, except where retention is legally required.

Third-Party Processing

Cloud Infrastructure: Our servers and data storage are hosted on industry-leading cloud platforms with enterprise-grade security certifications and compliance standards.

AI Service Providers: We use third-party AI models for natural language processing and conversation analysis. Data shared with AI providers is minimized and governed by strict data processing agreements.

Analytics Services: Anonymized usage data may be processed by analytics providers to help us understand and improve service performance and user experience.

Contractual Protection: All third-party processors are bound by Data Processing Agreements (DPAs) that require them to process data only on our instructions and maintain appropriate security measures.

Due Diligence: We conduct thorough due diligence on all third-party processors, including security assessments and compliance verification, before engaging their services.

GDPR

Full compliance with the EU General Data Protection Regulation

CCPA

Compliant with the California Consumer Privacy Act

ISO 27001

Information security management system standards

How to Delete Your Account & Data

Open the Loveberry app and go to the Haven tab (your profile).

Scroll down and tap "Delete Account".

Review the confirmation screen, then type DELETE and confirm.

Your account will be immediately deactivated and all personal data permanently removed within 30 days.

Profile information — name, email, dating preferences, and all account settings

Uploaded screenshots and photos — all images are permanently deleted from our servers

Match and connection data — all contacts, conversation history, and relationship insights

AI-generated content — all icebreakers, reply suggestions, and coaching conversations

Subscription data — subscription status and purchase history associated with your account

Anonymized analytics — de-identified, aggregated usage data that cannot be linked back to you may be retained for service improvement.

Legal obligations — certain transaction records or data required by law may be retained for the legally mandated period.

Note: Account deletion is permanent and cannot be undone. If you have an active subscription, please cancel it through the App Store or Google Play before deleting your account to avoid future charges. Deleting your account does not automatically cancel store-managed subscriptions.