Privacy Policy

1. Data We Collect

We collect the following categories of data:

• Registration data: email address, password (hashed), preferred language.
• Profile data: first name, last name, date of birth, gender, country, city, bio, occupation, education, languages spoken, relationship preferences, photos.
• Compatibility questionnaire: personality and preference responses (encrypted at rest).
• Identity verification documents: ID card or passport, kept for a maximum of 24 hours after verification, then deleted.
• Payment data: only metadata is stored (Stripe ID, plan type, dates). We never store your card numbers.
• Technical data: IP address, browser type, connection logs, cookies.
• Consent data: your authorization choices for each processing purpose.

2. Legal Basis & Purposes

We process your data on the following bases:

• Contract performance: providing the matchmaking service, managing your account, enabling communication between members.
• Consent: processing sensitive questionnaire data, AI coach usage, message translation, video calls, international transfers, non-essential cookies.
• Legitimate interest: service improvement, fraud prevention, platform security, content moderation.

3. Consent Management

During registration, you choose to grant or refuse consent for each processing purpose. You can change your choices at any time from your privacy settings. Withdrawing consent does not affect the lawfulness of processing based on consent given before withdrawal. Some features may be limited if you withdraw consent (e.g., the AI coach requires your agreement to function).

4. Data Retention

We retain your data for the following periods:

• Account and profile data: for the duration of your use, then 3 years after your last login.
• Identity verification documents: deleted within 24 hours of verification.
• Database backups: kept for 7 days.
• Connection logs: kept for 12 months.
• Upon account deletion: all your personal data is permanently erased, including encryption keys, MFA secrets, and associated data.

5. Data Security

We implement advanced security measures:

• AES-256-GCM encryption for all sensitive fields (phone, address, notes, questionnaire responses, AI coaching results).
• Unique encryption key per user (DEK), protected by a master key (KEK) with rotation capability without re-encrypting data.
• Passwords hashed using industry-standard algorithms.
• Two-factor authentication (TOTP) available for administrator accounts.
• Environment isolation (systemd sandboxing), network access restrictions, application firewall.
• Security audits and comprehensive logging of all administrative actions.

6. Artificial Intelligence & Privacy

HeartBridge uses AI for relationship coaching and matching. Your privacy is protected:

• Pseudonymization: before any AI call, your data is anonymized. Your name is replaced with "User", your occupation is generalized.
• Ephemeral identifiers: each AI call uses a random UUID. The AI provider never receives your real identifier.
• Data minimization: only numeric scores (0-100) from the questionnaire are sent, never text responses.
• PII redaction: an automatic filter masks emails, phone numbers, addresses, and other identifying data across all supported languages.
• Encrypted coaching memory: summaries of past sessions are stored encrypted with your personal key, stripped of all identifying information.

Data related to personalized coaching

When you use the personalized coaching service, the following data is processed:

• Data shared with your Coach (with consent): first name, age range, gender, location (country/city), spoken languages, bio, matching preferences, questionnaire progress, subscription status.
• Session data: date, time, duration of coaching sessions, Coach notes, payment status.
• Coach-Client messages: end-to-end encrypted (AES-256-GCM), automatically translated between Coach and client languages. An anti-leak filter automatically redacts personal contact information.
• Your Coach never has access to: your detailed questionnaire answers, private messages with matches, contact details (phone, email), or payment data.
• Legal basis: explicit consent (Article 6(1)(a) GDPR). You can withdraw your consent at any time from your Privacy settings.
• Retention: session data is kept for 3 years after the last session. Messages follow the same retention policy as platform messages.

Coaching and international transfer (PIPL)

For users residing in mainland China: the coaching service may involve data transfer to a Coach located in the European Union. This transfer is performed:

• Based on your explicit and separate consent, in accordance with Article 39 of PIPL.
• With protective measures: data encryption in transit and at rest, data minimization, contact information anti-leak filter.
• Messages are automatically translated and sensitive data (questionnaire) is never transferred.
• You can withdraw your consent and request data deletion at any time.

7. International Transfers

HeartBridge operates between Europe and China. Your data may be processed by:

• Hosting (OVH): France, EU.
• OpenAI (GPT-4): United States — anonymized/pseudonymized data only.
• DeepSeek: China — for Chinese users, anonymized data.
• Stripe: EU/United States — payment data only.
• Agora: United States/Singapore — real-time video streams, not stored.

Standard Contractual Clauses (SCCs) are implemented with processors as applicable. Transfer impact assessments are conducted when required by regulation.

Hosting and cross-border transfers: all personal data is hosted and processed on servers located in France (EU), with OVH. HeartBridge does not operate any servers outside the European Union. For residents of China: in accordance with Articles 38 and 39 of the PIPL, the transfer of your data to France is based on your explicit consent, collected during registration. HeartBridge has initiated a Personal Information Protection Impact Assessment (PIPIA) for this transfer. You are informed that the recipient of your data is HeartBridge Agency (Marseille, France), for the purpose of matrimonial matchmaking, and that you may exercise your PIPL rights at any time at [email protected]. For Russian-speaking users residing outside the EU: your data is processed in France under the protection of the GDPR. By using our service, you expressly consent to this processing.

8. Your Rights

Under the GDPR (and PIPL for Chinese residents), you have the following rights:

• Right of access: obtain a copy of all your personal data.
• Right to rectification: correct inaccurate or incomplete data.
• Right to erasure: request deletion of your data ("right to be forgotten").
• Right to data portability: receive your data in a machine-readable format (JSON).
• Right to object: object to the processing of your data.
• Right to restriction: restrict processing in certain circumstances.

You can exercise these rights from Settings > Privacy, or by contacting [email protected].

You may also file a complaint with the CNIL (French Data Protection Authority): www.cnil.fr.

9. Cookies

We use the following cookie categories:

• Essential cookies: authentication, security, language preferences. Always active.
• Analytics cookies (optional): anonymized audience measurement to improve the service.
• Functional cookies (optional): user experience personalization.

You can manage your cookie preferences at any time from the footer or the Cookies page.

10. Contact

For any questions regarding the protection of your data:

• Data Protection Officer: [email protected]
• General contact: [email protected]
• Postal address: HeartBridge Agency, Marseille, France