TraitMatch Privacy Policy
Version 1.8 — Effective 5 November 2026
This Privacy Policy explains how TraitMatch (“TraitMatch”, “we”, “us”, “our”) collects, uses, shares, and protects personal data when you use the TraitMatch mobile application, website, and related services (the “Service”). TraitMatch is the trading name; the controller is identified in Section 1.
Our commitment
• Privacy by design — product, security, and legal reviews consider privacy before shipping features.
• Plain language — we prefer clear explanations over jargon.
• Security investment — we maintain technical and organisational measures and improve them as safety and threats evolve.
• Your control — Settings include data export, account deletion, discovery pauses, visibility toggles, Art. 9 consent withdraw, and notification preferences.
California / similar US state residents: see the Regional Privacy Addendum at https://traitmatch.pages.dev/regional-privacy and in Settings → Legal.
1. Who we are (controller)
Controller: TraitMatch
Registered address: Bratislava, Slovak Republic
Privacy / data subject requests: [email protected]
DPO (if designated): [email protected]
Support: [email protected]
Legal / regulatory contact: [email protected]
Website: https://traitmatch.pages.dev
Imprint: https://traitmatch.pages.dev/imprint
If you live in the EEA/UK, TraitMatch is the data controller for the Service unless we state otherwise for a specific feature. If we appoint an EU/UK representative under Art. 27 GDPR, those details will be published at https://traitmatch.pages.dev/privacy and on the Imprint page.
2. Where this Policy applies
This Policy covers personal data processed through the Service: account, profile, personality/trait assessments, matching, messaging (including end-to-end encrypted match DMs and other chat modes), Ponds (group rooms), virtual economy (Mir Coin, Premium, Boost, and related entitlements), safety/moderation, customer support, and our public website. If a specific feature publishes its own notice, that notice applies for that feature together with this Policy.
3. Data we collect
Depending on how you use the Service, we may process the categories below. Not every user provides every field.
A. Information you give us
• Account — email and/or phone, username, authentication credentials/tokens (hashed passwords or provider tokens), internal account and session identifiers
• Profile — display name, date of birth/age, photos/videos/voice clips you upload (may need camera, microphone, or gallery permission), bio, interests, gender identity, looking-for preferences, lifestyle attributes (e.g. drinking, smoking, children preferences, religion, ethnicity/nationality, activity, education, occupation, languages), city and nationality fields used for discovery
• Special category data (GDPR Art. 9) — sexual orientation and, where you choose, data revealing religious/philosophical beliefs or ethnic origin. Processed only with your explicit consent (Art. 9(2)(a)) unless another Art. 9 condition applies (e.g. legal claims). You may withdraw consent in Settings → Discovery & privacy
• Trait / assessment data — answers to personality and values tests; derived trait scores/labels for compatibility and Premium filters (entertainment / self-description, not medical diagnosis)
• Communications — match 1:1 DMs (see encryption below); group chats and Ponds content (not end-to-end encrypted on our servers); paid direct messages where offered; message reactions, edits, recalls, gifts, and conversation settings (mute, pin, wallpaper, nicknames) where enabled
• Purchases and virtual economy — store purchase receipts/tokens, Premium/Boost/hide/DM/skip/extra-like entitlements, Mir Coin wallet balance and ledger entries (credits, spends, transfers between users where allowed), promo/redemption codes you enter
• Support — messages you send to privacy/support/legal inboxes and related ticket metadata
• Optional surveys / research / promotions you choose to join — responses and entry details as disclosed at the time
• Verification materials — if you use profile verification (e.g. selfie or ID check when we offer it), we process those materials solely for verification and safety
B. Information from others
• Sign-in providers (e.g. Google, Apple Sign-In, email/phone via Firebase Authentication) — identifiers and basic account details they share with your permission per their policies
• Other users — reports, blocks, safety tips, or content that mentions or depicts you
• Promo/referral partners — only where you use a code or program we disclose; limited attribution data for fraud prevention and commission accounting
• Where lawful, limited safety signals from partners or public sources used to prevent fraud or harm (not used for advertising profiles)
C. Information generated when you use the Service
• Usage and activity — logins and sessions, features used, likes/skips/passes/matches, profile views sent and received, feed interactions, filters, search/browse behaviour, Ponds posts/comments/reactions, test completion, undo actions, blocks
• Device / technical — device type/OS, app version, language/units, approximate network info, IP address (via our API and edge providers for security and abuse prevention), push notification tokens and delivery preferences; we do not collect advertising IDs for behavioural ads while we do not ship ads/analytics SDKs
• Inferences — compatibility rankings, trait labels, and feed ordering derived from your tests, preferences, and activity to operate matching (see Section 5)
• Location — city/nationality from profile; approximate distance matching. Precise GPS coordinates are stored only if you grant location permission for features that need them; you can revoke in device settings
• Presence — last-active signals used for product features (e.g. discovery freshness), not sold to third parties
• Cross-device — when you sign in on multiple devices we link sessions to your account so chat, wallet, and preferences stay consistent
• Security and abuse — rate-limit counters, moderation queue metadata, automated and human review notes tied to your account where relevant
D. End-to-end encrypted match DMs
• We store ciphertext, cryptographic envelopes, and conversation metadata (participants, timestamps, delivery/read indicators, mute/pin/block). We store public encryption keys needed for the protocol; we do not hold private keys that decrypt 1:1 message plaintext on our servers.
• Plaintext exists on participants’ devices; key or device loss may make prior messages unrecoverable.
• Chat media for match DMs: captions encrypted like text; image bytes encrypted on-device before upload where that feature is enabled. TLS protects data in transit.
E. Consent, legal, and rights records
• Terms acceptance, Art. 9 consent grants/withdrawals, cookie/SDK consent choices (when shown), marketing opt-outs, and similar events may be logged in our privacy rights audit log (`privacy.rights_events`) with timestamp, source, and status — to demonstrate compliance and honour withdrawals
F. What we do not collect by design (today)
• We do not run third-party behavioural advertising or analytics SDKs in the production app (e.g. Firebase Analytics, Crashlytics, ad networks) unless we enable them later and obtain consent where required.
• We do not sell your personal data for money.
• We do not receive full payment card numbers — stores handle payment.
4. Why we use data and legal bases (GDPR Art. 6 / 9)
• Provide and maintain the Service (account, profile, matching, messaging, Ponds, wallet/entitlements) — contract (Art. 6(1)(b))
• Age gate (18+), security, fraud prevention, abuse detection, rate limiting — legitimate interests / legal obligation (Art. 6(1)(f)/(c))
• Trait tests and compatibility ranking — contract; special-category profile fields — explicit consent (Art. 9(2)(a))
• Distance and discovery filters — contract; location/GPS where required by local law — consent
• Safety, moderation, illegal-content duties (including child safety) — legitimate interests / legal obligation. For E2E DMs we cannot scan plaintext on servers; we rely on reports, metadata, account signals, and excerpts you share when reporting
• Product notifications you enable (e.g. match/like/message pushes via Firebase Cloud Messaging) — consent and/or contract depending on type; marketing-style pushes default off
• Server-side reliability and aggregate product statistics (e.g. counts of signups, matches, purchases by category) for internal staff dashboards — legitimate interests (operate, secure, and improve the Service); dashboards use aggregated metrics, are access-controlled, and are not used to sell data or to target ads to users
• Billing entitlements via app stores — contract
• Promo/referral programs — contract / legitimate interests (fraud prevention, accounting)
• Legal compliance, disputes, lawful requests from authorities — legal obligation / legitimate interests. We can disclose account data and stored ciphertext; we cannot provide decrypted 1:1 DM plaintext we do not possess
• Marketing push / email — consent (Art. 6(1)(a)); default off; withdraw in Settings
• Optional surveys/research — consent or legitimate interests as disclosed when you join
• Recording consent and rights requests — legal obligation / legitimate interests (accountability)
Where we rely on legitimate interests, we balance them against your rights. You may object as described in Section 11.
5. Automated matching, profiling, and recommender systems
We use automated processing (including profiling) to suggest and order profiles in Match and related discovery from your preferences, filters, trait scores, activity, blocks, and distance. This processing is necessary to provide the core dating/matching Service.
• Logic (high level): compatibility scores from completed tests and profile fields; hard filters (age, distance, looking-for, blocks); feed ordering and quotas; Premium filters where purchased.
• Significance: this affects which profiles you see and in what order; it does not by itself produce legal or similarly significant effects (e.g. employment or credit) without separate human safety review.
• Your controls: adjust filters, pause discovery (“Show me in Match”), block users, withdraw Art. 9 fields, delete account.
• Human review: moderation and safety enforcement involve human review; you may appeal moderation via [email protected].
• EU Digital Services Act: where applicable, this recommender is used to suggest content/profiles you may wish to interact with; it is not a generic “social feed” ad product. Contact [email protected] for regulatory correspondence.
6. How we share data
We do not sell your personal data for money. We do not share data with advertising networks for interest-based ads while we do not run those products.
We share only as needed:
• Other members — profile and Ponds content you choose to show (visibility settings apply). Be careful what you post publicly; once another user sees it, we cannot control their copies or screenshots
• Processors — hosting, database, CDN/media storage, push, authentication (see https://traitmatch.pages.dev/subprocessors), under data processing agreements and, where required, Standard Contractual Clauses
• Payment platforms — Google Play, Apple App Store (or another store we enable)
• Authorities / safety — when required by law, valid legal process, or to protect rights, safety, or integrity of the Service (including child safety reports)
• Corporate transactions — merger, acquisition, or asset transfer under appropriate safeguards and notice where required
• With your direction — e.g. when you ask us to export data to you or participate in a promotion you opt into
Staff and contractors with a need-to-know may access personal data under confidentiality, access controls, and training — for engineering, support, moderation, billing reconciliation, and security — not for unrelated personal use.
If another member requests a copy of their data, they receive their own content and metadata; we will not hand out your private data to someone else without a lawful basis.
7. International transfers
Some processors (e.g. Cloudflare, Google/Firebase, Supabase regions) may process data outside the EEA/UK. Where required, we use adequacy decisions, Standard Contractual Clauses (EU Commission 2021/914), or equivalent tools. Details and regions: https://traitmatch.pages.dev/subprocessors. You may request a copy of safeguards via [email protected].
8. Retention
• Active account/profile: while the account is open
• After deletion request: short recovery window (typically up to 7 days) so you can reinstate by signing in; then deletion or irreversible anonymization of personal data within 30 days, except limited records we must keep by law or for safety/fraud/disputes
• After a ban: a limited safety retention window may apply so we can investigate harm and prevent ban evasion, then delete or anonymize as above
• E2E DM ciphertext/metadata: while needed for chat delivery and limited security/abuse windows; no 1:1 DM plaintext on our servers
• Non-E2E chat/Ponds content: while the conversation/post exists and for limited backup/safety windows
• Safety reports / enforcement: as needed for investigation, claims, regulatory duties, and child-safety cooperation
• Purchases/entitlements/wallet ledger: as required for accounting, tax, and store reconciliation
• Consent, Terms acceptance, and rights-event records: kept as evidence of compliance for periods permitted by law (typically several years where accountability requires)
• Support tickets: kept as needed to resolve your request and improve support quality
• Server logs and security records: short rolling retention unless needed for an incident
• Backups: rotated and purged on a limited schedule
• Long inactivity: accounts may be removed after a long dormancy period (see Terms / Guidelines), with notice where required
Account pause/freezing is not a substitute for deletion. Uninstalling the app stops local collection on that device but does not delete your server account — use in-app or web deletion for that.
9. Security
We use TLS in transit, access controls, least-privilege administration, staff authentication for internal tools, and secure storage practices. Match 1:1 DMs use client-side end-to-end encryption so plaintext is not available to our servers under normal operation. E2E does not hide metadata (who talked when), stop compromised devices, or stop peers from copying content. No system is 100% secure. Report suspected compromise to [email protected]. We may suspend accounts if we detect a security risk.
10. Personal data breaches
If we become aware of a personal data breach likely to pose a risk to your rights and freedoms, we will notify the competent supervisory authority without undue delay and, where required by law, notify affected users with the nature of the breach, likely consequences, and measures taken. Contact [email protected] if you believe your account was compromised.
11. Children
The Service is 18+ only. We do not knowingly collect data from anyone under 18. If we learn a user is under 18, we delete the account and related data. Report suspected underage accounts in-app or to [email protected]. See https://traitmatch.pages.dev/child-safety.
12. Your rights and controls
Subject to applicable law (including GDPR), you may have the right to:
• Access / know — including a portable copy where required
• Rectify inaccurate data
• Erase (“right to be forgotten”)
• Restrict or object to certain processing (including objecting to legitimate-interest processing where applicable)
• Data portability (structured, commonly used format where technically feasible)
• Withdraw consent (Art. 9 sensitive fields; marketing; cookies/SDKs when enabled) without affecting prior lawful processing
• Not be subject to a decision based solely on automated processing that produces legal or similarly significant effects, except as allowed by law with safeguards (see Section 5)
• Lodge a complaint with a supervisory authority
EEA/UK — Slovak supervisory authority: Úrad na ochranu osobných údajov SR (https://dataprotection.gov.sk). You may also complain to your local authority.
Tools:
• In-app — edit profile; Settings → Download my data; Delete account; pause discovery; notification and visibility toggles; Art. 9 withdraw; cookie/SDK preferences when shown
• Device permissions — camera, photos, microphone, location, notifications (revoke in OS settings; some features may stop working)
• Web deletion — https://traitmatch.pages.dev/account-deletion
• Email — [email protected] (subject: “Privacy request”)
We may need to verify your identity before fulfilling requests. We may refuse manifestly unfounded or excessive requests, or requests that would reveal another person’s data, trade secrets, or undermine security. We generally respond within one month under GDPR (extensions up to two further months where complex, with notice).
US state “sale/share/targeted advertising” opt-outs: see https://traitmatch.pages.dev/regional-privacy. Today we do not sell personal information for money or run advertising SDKs.
13. Cookies and similar technologies
See the Cookie Policy: https://traitmatch.pages.dev/cookies. Summary: website uses essential local storage (theme); app uses essential session/security storage and FCM push tokens; optional analytics/marketing SDKs are off until consent where we add them. Marketing push is separate and defaults off. “Do Not Track” browser signals are not standardised; we do not use behavioural ad trackers today.
14. Third-party links and user-generated content
Profiles and Ponds may contain links or content from other users. We are not responsible for third-party sites’ privacy practices. Report illegal or harmful content in-app.
15. Changes
We may update this Policy. We will change the version and effective date and notify you in-app or by email where required. Where consent is needed for new processing, we will ask for it before the change takes effect for that processing.
16. Contact
Privacy / data rights: [email protected]
Support: [email protected]
Legal / DSA / regulatory: [email protected]
Child safety: [email protected]
Postal: Bratislava, Slovak Republic
