Privacy · FOUND LOVE

1.Controller

The controller responsible for processing personal data on found-love.com, found-love.at and found-love.info is:

Detail will follow before launchName or company name, address and email address of the controller. [to be added before launch]

As things stand, appointing a data protection officer is not mandatory.

Open point (legal review)Check whether a data protection officer must be appointed because of large-scale processing of special categories (Art. 37(1)(c) GDPR).

2.Principles

Data minimisation: we only collect what is necessary for matchmaking, safety and the contract.
Separate data classes: identity, profile, matching, trust & safety, billing, moderation and audit are kept in separate tables.
No advertising, no selling of data, no analytics or tracking tools, no third-party content (not even externally loaded fonts).
We never store ID images, ID numbers, raw biometric data, religious affiliation, your exact location or IP addresses in plain text.
You decide on sensitive information yourself: we infer nothing from photos, messages or behaviour.

3.What data we process

Account: ExamplesEmail address, password (only as Argon2id hash), language, status, role; PurposeLogin, account management, contract communication
Session: ExamplesRandom session token (stored only as a hash), expiry; PurposeStaying signed in, signing out on all devices
Identity: ExamplesDate of birth, timestamps of phone, identity, age and photo confirmation, phone number and provider identifier only as HMAC hash, verification service used; PurposeAdulthood (18+), real people, protection against duplicate accounts
Profile: ExamplesDisplay name, height, occupation, city, coordinates rounded to approx. 1 km, free texts, profile hidden yes/no; PurposeShowing you to suitable people
Gender identity and pronouns: ExamplesGender identity (woman, man, non-binary, self-described or “prefer not to say”), optional self-description (max. 40 characters), optional pronouns, visibility (gender identity hidden by default, pronouns visible by default); PurposeMutual matching; shown only as you allow (special category, see section 5)
Photos: ExamplesRe-encoded image files without EXIF/GPS data, dimensions, order, moderation status; PurposeProfile, moderation
Search preferences: ExamplesWho you would like to meet (one or more gender identities or “open to everyone”), age range, distance, height range; PurposeMatching; who you are looking for is never visible to others (special category, see section 5)
Sexual orientation (optional): ExamplesOnly if you state it: one or more options, optional self-description, visibility (hidden by default) – in a separate table; PurposeShown on your profile as you allow. Not used for matching (special category, see section 5)
Matching answers: ExamplesAnswers to situational questions, answers marked as non-negotiable, values, interests, priorities, partner wishes; PurposeCompatibility profile and explanations
Derived data: ExamplesCompatibility profile, assessments and explanations of suggestions, each with engine version; PurposeSuggestions, traceability
Behavioural signals: ExamplesInterest / no interest in suggestions with the traits of the suggested person; hints derived from them; PurposeLearning matching – only with consent
Messages: ExamplesContent, timestamps, read status, automatic safety flags; PurposeCommunication, protection against scams
Trust & safety: ExamplesSafety signals (e.g. failed logins, reports), risk assessments, blocks, known devices (only as an irreversible key of the browser identifier, without IP address, 90 days); PurposeProtection against fake profiles, bots and scams; notice when you sign in from a new device
Moderation: ExamplesReports, measures with statement of reasons, appeals; PurposeNotice and action, complaints
Consents: ExamplesType, version, granted/withdrawn, timestamp; PurposeProof under Art. 7(1) GDPR
Audit: ExamplesWho performed which sensitive action and when – without content, passwords or ID data; PurposeSecurity, traceability
Billing: ExamplesPlan, status; in future payment references; PurposeNot active at present – payments are disabled

Data class	Examples	Purpose
Account	Email address, password (only as Argon2id hash), language, status, role	Login, account management, contract communication
Session	Random session token (stored only as a hash), expiry	Staying signed in, signing out on all devices
Identity	Date of birth, timestamps of phone, identity, age and photo confirmation, phone number and provider identifier only as HMAC hash, verification service used	Adulthood (18+), real people, protection against duplicate accounts
Profile	Display name, height, occupation, city, coordinates rounded to approx. 1 km, free texts, profile hidden yes/no	Showing you to suitable people
Gender identity and pronouns	Gender identity (woman, man, non-binary, self-described or “prefer not to say”), optional self-description (max. 40 characters), optional pronouns, visibility (gender identity hidden by default, pronouns visible by default)	Mutual matching; shown only as you allow (special category, see section 5)
Photos	Re-encoded image files without EXIF/GPS data, dimensions, order, moderation status	Profile, moderation
Search preferences	Who you would like to meet (one or more gender identities or “open to everyone”), age range, distance, height range	Matching; who you are looking for is never visible to others (special category, see section 5)
Sexual orientation (optional)	Only if you state it: one or more options, optional self-description, visibility (hidden by default) – in a separate table	Shown on your profile as you allow. Not used for matching (special category, see section 5)
Matching answers	Answers to situational questions, answers marked as non-negotiable, values, interests, priorities, partner wishes	Compatibility profile and explanations
Derived data	Compatibility profile, assessments and explanations of suggestions, each with engine version	Suggestions, traceability
Behavioural signals	Interest / no interest in suggestions with the traits of the suggested person; hints derived from them	Learning matching – only with consent
Messages	Content, timestamps, read status, automatic safety flags	Communication, protection against scams
Trust & safety	Safety signals (e.g. failed logins, reports), risk assessments, blocks, known devices (only as an irreversible key of the browser identifier, without IP address, 90 days)	Protection against fake profiles, bots and scams; notice when you sign in from a new device
Moderation	Reports, measures with statement of reasons, appeals	Notice and action, complaints
Consents	Type, version, granted/withdrawn, timestamp	Proof under Art. 7(1) GDPR
Audit	Who performed which sensitive action and when – without content, passwords or ID data	Security, traceability
Billing	Plan, status; in future payment references	Not active at present – payments are disabled

4.Purposes and legal bases

Contract (Art. 6(1)(b) GDPR): account, profile, matching, suggestions, messages, account management, data export and deletion.
Explicit consent (Art. 9(2)(a) GDPR) “Matching by your search preferences”: gender identity, self-description, pronouns and who you would like to meet – for matching and display according to your visibility settings. Matching is not possible without this consent.
Separate explicit consent (Art. 9(2)(a) GDPR) “Voluntary information on orientation”: optional information about your sexual orientation. It is not required to use the service.
Consent (Art. 6(1)(a) GDPR): learning matching from behavioural signals; product news by email. Both are voluntary.
Legitimate interest (Art. 6(1)(f) GDPR): trust & safety – detecting fake profiles, bots and scams, rate limits, safety hints in chat, audit log. Our interest and that of all members: a safe platform.
Legal obligation (Art. 6(1)(c) GDPR): age limit, notice and action under the Digital Services Act, tax and commercial retention (once payments are active).

Open point (legal review)Finalise the legal basis for identity verification (contract vs. legitimate interest vs. consent) and for the processing of message content by the safety scanner.

5.Special categories of personal data

FOUND LOVE is for every adult. We treat gender identity, sexual orientation and who you would like to meet as three separate pieces of information.

Gender identity and search: your gender identity together with who you would like to meet can reveal your sexual orientation. According to the case law of the Court of Justice of the EU (C-184/20), even such indirect disclosure is sufficient. That is why we ask for your explicit consent “Matching by your search preferences” before matching. A suggestion only happens if you are looking for each other; after that the compatibility engine assesses every combination with the same rules. If you withdraw consent, your profile is hidden immediately and you receive no further suggestions.

Sexual orientation: stating it is optional. It is only stored with the separate consent “Voluntary information on orientation”, in a separate table, hidden from everyone by default and not used for matching. If you withdraw this consent or clear the information, it is deleted immediately.

Visibility: gender identity hidden by default, pronouns visible by default (only if given), orientation hidden by default. “Prefer not to say” is never shown as a gender. Nobody sees who you are looking for.
No inference: we never infer gender or orientation from photos, faces, messages or behaviour. There is no biometric categorisation and no facial analysis (cf. Art. 5(1)(g) AI Act). Profile photos are only checked automatically for sexually explicit content – with an image model on our own servers, without sharing with third parties; our team reviews unclear cases, and you can appeal a rejection.
No use for advertising or for rating people.

We ask no questions about religion, health, sex life, political opinions or ethnic origin. Photos are not analysed biometrically.

Open point (legal review)Check whether the consent “Matching by your search preferences” for a core contractual service is “freely given” within the meaning of Art. 7(4) GDPR; whether gender identity on its own is a special category or only in combination with the search; wording of both consent texts.

6.Profiling and automated decisions

Matching is profiling: your answers form a compatibility profile that is compared with others. The logic is rule-based, deterministic and versioned (currently MATCH_ENGINE_V1). There is no beauty rating and no use of language models for suggestions or moderation.

Weighted areas are life goals, closeness & relationship, conflict, communication, values, everyday life, personality, self-stated preferences and interests. Your own priorities increase the weight of an area.
Before any assessment, mutual conditions apply: you are looking for each other, and age and distance fit for both. Gender identity only acts as this filter, never as a factor in the assessment. Orientation is not used.
Fundamental contradictions you have marked as non-negotiable exclude a suggestion.
For every suggestion you see the key reasons and possible points of friction.
You can change your answers at any time.

In our assessment, the selection of suggestions does not have legal or similarly significant effects within the meaning of Art. 22 GDPR. Regardless of that: final restrictions or bans of an account are always decided by someone from our team. Automated safety measures are provisional and reversible, and you can have every decision reviewed.

Open point (legal review)Have the Art. 22 GDPR assessment confirmed for suggestions and for provisional automated safety measures.

7.Joining the launch list

If you join the launch list before we launch, we only store your email address, your chosen language and the times you signed up and confirmed. No profile or dating information is collected.

Purpose: to tell you about the launch and to assign the promised Premium bonus to you (legal basis: your consent by joining and confirming, Art. 6(1)(a) GDPR). There are no other marketing emails – only the confirmation and one message at launch.

We delete unconfirmed addresses after 30 days. You can leave the list at any time using the link in every email; your entry is then deleted. If you later sign up with the same address, the entry is assigned to your account and deleted together with the account.

8.Recipients and processors

Other members you are suggested to only see what is necessary for matchmaking: display name, age, city, rounded distance, photos, profile texts, verification badges and the explanation of the suggestion – plus gender identity, pronouns and orientation only as far as you have shared them. Never visible: email address, phone number, date of birth, ID data and who you are looking for.

The following categories of processors are planned. The specific providers have not yet been chosen:

Hosting and database (target: data centre in the EU)
Photo storage (S3-compatible, EU)
Email delivery
Text messages for phone confirmation
Identity verification (ID Austria or a specialised service)
Payment processing – only once paid plans are offered

Detail will follow before launchNames, registered offices and safeguards of the processors. [to be added before launch]

Open point (legal review)For ID Austria as an identity route: clarify the role (independent controller vs. processor) and the attributes transferred.

9.Transfers to third countries

We plan to process all data within the EU. Should a provider process data outside the EEA, we will provide information here on the safeguards under Art. 44 et seq. GDPR.

10.Retention

Account, profile, photos, matching data: Retention (draft)Until the account is deleted
Messages: Retention (draft)Until a participant deletes their account or the conversation ends; details open
Sexual orientation (optional): Retention (draft)Until you clear it, withdraw consent or delete your account – then immediately
Behavioural signals: Retention (draft)Until consent is withdrawn or the account is deleted
Confirmation codes and links: Retention (draft)10 minutes (text code) or 24 hours (email link)
Sessions: Retention (draft)At most 30 days, immediately on sign-out
Safety signals, reports, measures: Retention (draft)For as long as needed to avert risks and handle possible appeals; specific period open
Consent records, audit log: Retention (draft)Specific period open

Data	Retention (draft)
Account, profile, photos, matching data	Until the account is deleted
Messages	Until a participant deletes their account or the conversation ends; details open
Sexual orientation (optional)	Until you clear it, withdraw consent or delete your account – then immediately
Behavioural signals	Until consent is withdrawn or the account is deleted
Confirmation codes and links	10 minutes (text code) or 24 hours (email link)
Sessions	At most 30 days, immediately on sign-out
Safety signals, reports, measures	For as long as needed to avert risks and handle possible appeals; specific period open
Consent records, audit log	Specific period open

Open point (legal review)Set specific retention periods for messages, trust & safety data, moderation records, audit log and consent records (incl. limitation periods and DSA duties).

11.Cookies

We only use strictly necessary cookies:

Session cookie (fl_session): keeps you signed in; httpOnly, at most 30 days.
Language cookie (fl_lang): remembers whether you chose German or English; 12 months.
Security cookie (fl_known): set after a successful login so that other people’s login attempts don’t slow you down on this device; contains only an irreversible check value, no email address; httpOnly, 180 days.
Device cookie (fl_dev): a random identifier for this browser, set when you sign in (or if your connection doesn’t provide a reliable address); it lets us recognise a sign-in from a new device (security notice by email) and limit abuse – switching networks (Wi-Fi, mobile data) doesn’t change it; we only store an irreversible check value; httpOnly, 12 months.

There are no analytics, advertising or tracking cookies and no third-party content. That is why no cookie banner is needed (§ 165(3) Austrian TKG 2021).

12.Security of processing

Encrypted transmission (HTTPS)
Passwords only as Argon2id hashes
Pseudonymisation of IP addresses and phone numbers (HMAC)
Photos stored privately, delivered only via short-lived signed links
Server-side authorisation checks on every access, audit log for sensitive actions

13.Your rights

Access (Art. 15 GDPR) – also as a data export in your account
Rectification (Art. 16)
Erasure (Art. 17) – directly in your account
Restriction of processing (Art. 18)
Data portability (Art. 20)
Objection to processing based on legitimate interests (Art. 21)
Withdrawal of consent at any time with effect for the future (Art. 7(3)) – in your account under consents

You also have the right to lodge a complaint with the Austrian Data Protection Authority: Barichgasse 40–42, 1030 Vienna, dsb.gv.at.

14.Data protection impact assessment

Under the Austrian DPIA Regulation (BGBl. II No. 278/2018) and the explanations of the Data Protection Authority, matchmaking platforms that create user profiles are among the processing operations requiring a data protection impact assessment. It will be carried out before launch.

Open point (legal review)Carry out and document the data protection impact assessment.

15.Changes

We will inform you in advance of material changes. Every version has a version number; consents given are stored with the respective version.

Your data, clearly explained.