Privacy Policy

1. Introduction and Scope

Lovinour Ltd. ("Lovinour," "we," "our," or "us") is committed to protecting your privacy and personal data. This Privacy Policy explains how we collect, use, disclose, retain, and safeguard your information when you access our website, mobile applications, and dating concierge services (collectively, the "Services"). This policy applies to all users, including members, network participants, and visitors.

By using our Services, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree with any part of this policy, you must discontinue use of our Services immediately.

2. Information We Collect

2.1 Information You Provide Directly

• Identity data: Full legal name, date of birth, gender, nationality, government-issued identification documents
• Contact data: Email address, phone number, postal address, emergency contact information
• Profile data: Photographs, videos, physical attributes, relationship preferences, lifestyle information, hobbies, interests, values, and personal statements
• Professional data: Occupation, employer, job title, professional biography, LinkedIn profile, net worth range, income verification documents
• Sensitive personal data: Religious beliefs, political views, health conditions (where voluntarily disclosed), dietary preferences, and other special category data you choose to share for matching purposes
• Financial data: Payment card details, billing address, transaction history, bank statements for verification purposes
• Verification data: Identity documents, selfies for photo verification, video verification recordings
• Communication data: Messages, emails, call recordings (where permitted), feedback, and survey responses

2.2 Information Collected Automatically

• Device information: IP address, device type, operating system, browser type, unique device identifiers, mobile network information
• Usage data: Pages visited, features used, time spent on pages, click patterns, search queries, interaction history
• Location data: GPS coordinates (with consent), IP-based location, timezone information
• Cookies and tracking technologies: Session cookies, persistent cookies, web beacons, pixel tags, local storage data
• Log data: Access times, error logs, referral URLs, system activity

2.3 Information From Third Parties

• Social media platforms: Public profile information from LinkedIn, Instagram, or other connected accounts
• Background check providers: Identity verification results, criminal record checks (where legally permitted and with your consent)
• Payment processors: Transaction confirmations, fraud screening results
• Analytics providers: Aggregated usage patterns and demographic insights
• Referral sources: Information from individuals who referred you to our Services, including ambassador referral codes used during signup

2.4 Ambassador and Referral Data

If you participate in or benefit from our Ambassador Referral Program, we collect and process:

• Referral codes used during signup or subscription checkout
• The identity of the ambassador who referred you (for commission tracking purposes only)
• Commission amounts, payout history, and payment method details for ambassadors
• Referral link click data (anonymised IP hash, user agent, timestamp) for fraud prevention

This data is processed on the legal basis of contract performance (to apply your discount and calculate ambassador commissions) and our legitimate interest in preventing fraud.

3. How We Use Your Information

We process your personal data for the following purposes:

• Service Delivery: To provide matchmaking services, facilitate introductions, coordinate dates, and deliver personalized concierge assistance
• Account Management: To create and manage your account, verify your identity, and maintain accurate records
• Communication: To contact you regarding matches, service updates, appointment confirmations, and respond to inquiries
• Personalization: To tailor matches and recommendations based on your preferences, behavior, and feedback
• Payment Processing: To process transactions, manage subscriptions, and handle refunds where applicable
• Safety and Security: To verify user identities, detect and prevent fraud, abuse, and violations of our policies
• Legal Compliance: To comply with applicable laws, regulations, court orders, and legal processes
• Analytics and Improvement: To analyze usage patterns, improve our Services, and develop new features
• Marketing: To send promotional materials (with your consent where required) and conduct market research
• AI and Machine Learning: To train and improve our matching algorithms using anonymized and aggregated data

4. Legal Basis for Processing (GDPR)

If you are located in the European Economic Area, United Kingdom, or similar jurisdictions, we process your data based on:

• Consent: Where you have given explicit consent for specific processing activities
• Contract: Where processing is necessary for the performance of our contract with you
• Legal Obligation: Where we are legally required to process your data
• Legitimate Interests: Where processing is necessary for our legitimate business interests, provided these do not override your fundamental rights
• Vital Interests: Where processing is necessary to protect your life or the life of another person

5. No Sale of Personal Data

Lovinour does not and will never sell, rent, lease, or trade your personal data to any third party for any purpose, including marketing, advertising, or data brokerage. Your information is used exclusively for the operation of our Services. We are the sole custodians of your data and no external party has access to it, except for essential service providers (such as payment processors) who are contractually bound to confidentiality.

All data you provide — including profile information, preferences, photographs, messages, and activity logs — is accessible only to authorized Lovinour administrators and staff who require it for legitimate operational purposes. No other member, third party, or organization can access your private information.

6. Communication Monitoring

To maintain the safety, integrity, and lawful operation of our platform, Lovinour reserves the right to access, review, and monitor private messages and communications between members. This monitoring is conducted by authorized administrators only and is used exclusively for the following purposes:

• Detecting and preventing scams, fraud, or financial exploitation
• Identifying and stopping prostitution, escort services, or other illegal commercial activity
• Preventing harassment, threats, abuse, or dangerous behavior
• Ensuring compliance with our Terms of Service and community standards
• Responding to user reports and safety complaints
• Protecting the safety and wellbeing of all members

By using our Services, you acknowledge and consent to this monitoring. Communications found to contain prohibited activity may result in immediate account suspension, permanent ban, and where applicable, reporting to law enforcement authorities.

7. Information Sharing and Disclosure

7.1 Sharing with Other Members

As part of our matchmaking services, certain profile information will be shared with potential matches. This includes your first name, photographs, age, general location, occupation, and relevant preferences. We will never share your contact information, financial details, or full address without your explicit consent.

7.2 Service Providers

We may share your information with trusted third-party service providers who assist us in:

• Payment processing and fraud prevention
• Identity verification and background screening
• Cloud hosting and data storage
• Email and communication services
• Customer support and CRM systems
• Analytics and performance monitoring

All service providers are contractually prohibited from using your data for any purpose other than providing services to Lovinour. They cannot sell, share, or repurpose your data.

7.3 Legal and Safety Disclosures

We may disclose your information:

• To comply with legal obligations, court orders, or valid legal processes
• To protect the rights, property, or safety of Lovinour, our members, or the public
• To investigate potential violations of our Terms of Service
• In response to lawful requests by public authorities, including national security or law enforcement
• To prevent imminent harm, illegal activities, or threats to personal safety

7.4 Business Transfers

In the event of a merger, acquisition, reorganization, bankruptcy, or sale of assets, your information may be transferred to the successor entity. We will notify you of any such change and any choices you may have regarding your information.

7.5 No Sale — Ever

We reiterate: your personal data will never be sold to third parties under any circumstances. This applies to all categories of personal information we collect, including but not limited to identity data, profile data, communication data, and usage data.

6. International Data Transfers

Your information may be transferred to, stored, and processed in countries other than your country of residence, including the United States and other jurisdictions where data protection laws may differ. When we transfer personal data internationally, we implement appropriate safeguards including:

• Standard Contractual Clauses approved by the European Commission
• Binding Corporate Rules for intra-group transfers
• Certifications such as EU-U.S. Data Privacy Framework (where applicable)
• Your explicit consent for specific transfers

7. Data Retention

We retain your personal data for as long as necessary to:

• Provide our Services and maintain your account
• Comply with legal, accounting, and regulatory requirements
• Resolve disputes and enforce our agreements
• Protect against fraudulent or illegal activity

Specific retention periods: Active account data is retained for the duration of your membership plus 7 years. Financial records are retained for 10 years. Communication logs are retained for 3 years. Verification documents are retained for 5 years after account closure. Anonymized analytics data may be retained indefinitely.

8. Data Security

We implement industry-standard technical and organizational measures to protect your personal data, including:

• Encryption of data in transit (TLS 1.3) and at rest (AES-256)
• Multi-factor authentication for account access
• Regular security audits and penetration testing
• Access controls limiting data access to authorized personnel only
• Secure data centers with physical security measures
• Employee training on data protection and security practices
• Incident response procedures for data breaches

Despite these measures, no method of electronic transmission or storage is 100% secure. We cannot guarantee absolute security of your data. In the event of a data breach affecting your personal information, we will notify you and relevant authorities as required by law.

9. Your Privacy Rights

Depending on your jurisdiction, you may have the following rights:

• Right of Access: Request a copy of your personal data
• Right to Rectification: Request correction of inaccurate or incomplete data
• Right to Erasure: Request deletion of your personal data (subject to legal retention requirements)
• Right to Restriction: Request limitation of processing in certain circumstances
• Right to Data Portability: Receive your data in a structured, machine-readable format
• Right to Object: Object to processing based on legitimate interests or for direct marketing
• Right to Withdraw Consent: Withdraw consent at any time where processing is based on consent
• Right to Lodge a Complaint: File a complaint with your local data protection authority

To exercise these rights, contact us at support@lovinour.com. We will respond within 30 days (or as required by applicable law). We may request verification of your identity before processing your request.

10. California Privacy Rights (CCPA/CPRA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act and California Privacy Rights Act:

• Right to know what personal information we collect, use, and disclose
• Right to delete your personal information
• Right to opt-out of the sale or sharing of personal information
• Right to correct inaccurate personal information
• Right to limit use of sensitive personal information
• Right to non-discrimination for exercising your privacy rights

We do not sell your personal information as defined by CCPA. To exercise your California privacy rights, contact us at support@lovinour.com.

11. Cookies and Tracking Technologies

We use cookies and similar technologies for:

• Essential Cookies: Required for basic functionality and security
• Performance Cookies: Help us understand how visitors interact with our Services
• Functional Cookies: Remember your preferences and settings
• Marketing Cookies: Track advertising effectiveness (with your consent)

You can manage cookie preferences through your browser settings or our cookie consent banner. Disabling certain cookies may impact the functionality of our Services.

12. Third-Party Links and Services

Our Services may contain links to third-party websites, applications, or services. We are not responsible for the privacy practices or content of these third parties. We encourage you to review the privacy policies of any third-party services you access through our platform.

13. Children and Minors

Our Services are not intended for individuals under 18 years of age. We do not knowingly collect personal information from anyone under 18. If we learn that we have collected personal information from a minor, we will take steps to delete that information as soon as possible. If you believe we have collected information from a minor, please contact us immediately.

14. Automated Decision-Making

We use automated systems, including AI and machine learning algorithms, to provide match recommendations and compatibility scores. These automated decisions are based on the preferences and information you provide. You have the right to request human review of significant automated decisions that affect you.

15. Biometric Data

For photo and identity verification purposes, we may collect biometric data including facial geometry from photographs and video submissions. This data is used solely for verification and fraud prevention. We obtain your explicit consent before collecting biometric data and delete it within 3 years of collection or upon account termination, whichever is sooner, unless retention is required by law.

16. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy on our website with a new effective date, and where required, by sending you an email notification. Your continued use of our Services after such changes constitutes acceptance of the updated policy.

17. Contact Information

For questions, concerns, or requests regarding this Privacy Policy, please contact: