Last updated: May 26, 2026
This privacy policy describes how the Service Provider (hereinafter "we") processes personal data of visitors and Users of the Portal. Defined terms have the same meaning as in the Terms of Service.
1. Data controller
The controller of personal data is the Service Provider, whose contact details are published in the Portal footer. For data-protection inquiries, please use the same address; we respond within 30 days (with an option to extend to 60 days if necessary).
2. What data we collect
- Data provided by the User: information entered in the Listing — name/nickname, phone number, age, location, listing language, description, photos, search direction and other options, optional e-mail.
- Technical data: to the extent necessary, request logs and browser-identifying data (including IP address), used to ensure security, moderation and the technical operation of the Service.
- Payment data: the metadata of the message sent for an SMS payment (sender's phone number, message content, timestamp, payment reference). We do not process bank-card or account data.
- Special category data (GDPR Art. 9): A dating Listing may reveal data about the User's sex life or sexual orientation. The legal basis for processing such data is GDPR Art. 9(2)(e) — data manifestly made public by the data subject through publishing the Listing.
3. Purposes of processing and legal bases
We process data for the following purposes:
- Provision of the Service — publishing, browsing and answering Listings, processing SMS payments (GDPR Art. 6(1)(b) — performance of contract).
- Compliance with legal obligations — including accounting and tax reporting (Art. 6(1)(c)).
- Legitimate interest — preventing fraud, spam and abuse, moderation, security and technical operation of the Service (Art. 6(1)(f)).
4. Categories of recipients
We never sell personal data to third parties. To provide the Service, we use processors of the following categories:
- application hosting and database service providers;
- content delivery (CDN) and cyber-security service providers;
- payment service partners for SMS payments;
- e-mail delivery service providers;
- technical monitoring service providers.
Each processor processes data on our behalf under a written contract solely for the purpose of providing the Service. A current list of specific processors is available on request from the data subject.
We may also disclose data to competent authorities (police, prosecutor's office, courts) where we have a legal obligation to do so.
5. International data transfers
Where data is transferred outside the European Economic Area (EEA), we apply appropriate safeguards — primarily the European Commission's Standard Contractual Clauses (SCCs) or the EU–US Data Privacy Framework (DPF), depending on the processor.
6. Retention periods
We retain personal data only for as long as necessary for the purposes of processing:
- Listing data — until the Listing is deleted, followed by a short archive period;
- payment records — 7 years under the Estonian Accounting Act;
- technical logs — no longer than is necessary for the administration of the Service.
7. Cookies and browser storage
The Portal uses only strictly necessary cookies and local storage (e.g. to remember city preference and to record acknowledgement of the cookie notice). No third-party analytics, advertising or tracking cookies are used. Cookies can be managed and cleared in your browser at any time.
8. Data subject rights
Under the General Data Protection Regulation (GDPR), the User has the following rights:
- Right of access — to obtain a copy of personal data concerning them.
- Right to rectification — to have inaccurate data corrected.
- Right to erasure ("right to be forgotten") — to request deletion (except where we have a statutory obligation to retain).
- Right to restriction of processing — to have processing temporarily suspended.
- Right to data portability — to receive personal data in a structured, commonly used format.
- Right to object — to object to processing based on legitimate interest.
- Right to lodge a complaint with a supervisory authority — the Estonian Data Protection Inspectorate (aki.ee).
Rights may be exercised through the contact published in the Portal footer.
9. Security
We apply appropriate technical and organisational measures to protect data. No measures provide 100 % security; we will notify the User and the Data Protection Inspectorate without undue delay if we become aware of a personal data breach likely to result in a high risk to the data subject's rights and freedoms.
10. Children
The Portal is intended exclusively for persons at least 18 years of age. We do not knowingly collect personal data of minors. If we learn that a minor has posted a Listing on the Portal, we will remove it without delay.
11. Changes to this privacy policy
The current version of this privacy policy is always available via the link in the Portal footer. We will notify Users of material changes by a notice on the Portal. Continued use of the Service after publication of changes is deemed acceptance.
12. Contact
Please use the contact published in the Portal footer for data-protection inquiries and requests. Questions of liability, disputes and applicable law are governed by section 8 of the Terms of Service.
