Privacy Policy

Honest Dating Privacy Policy

Effective Date: 17.09.2026

Last Updated: 17.09.2026

1. Introduction

Welcome to Honest Dating.

Honest Dating (“Honest Dating,” “HD,” “we,” “us,” or “our”) is a dating and social connection platform operated by Vumira d.o.o., a company registered in the Republic of Slovenia.

Our mission is to help people overcome loneliness through meaningful human connections.

Trust, fairness, transparency, privacy, and personal autonomy are fundamental to how we design and operate our Service.

This Privacy Policy explains:

What personal information we collect.
Why and how we process that information.
How human and biometric verification works.
How sensitive profile information is handled.
What other members can see.
How we use automated moderation.
Which third parties may process information on our behalf.
How long information is retained.
Your privacy rights and how to exercise them.

This Policy applies to our website, mobile application, registration process, and all related Honest Dating services (collectively, the “Service”).

We process personal data in accordance with applicable data-protection legislation, including the European Union General Data Protection Regulation (“GDPR”) and the Slovenian Personal Data Protection Act (“ZVOP-2”), where applicable.

2. Data Controller

The controller responsible for determining the purposes and means of processing personal data is:

Vumira d.o.o.
Operator of Honest Dating
Republic of Slovenia

Registered Address: Rakuševa ulica 8, 1000 Ljubljana, Slovenia
Company Registration Number: 7427093000
Privacy Contact: privacy@honestdating.co
General Contact: info@honestdating.co
Website: https://www.honestdating.co/

If we are legally required to appoint a Data Protection Officer or another designated privacy representative, the relevant contact details will be published here.

3. Eligibility and Age Requirements

Honest Dating is exclusively intended for adults aged 18 or older.

During registration, applicants must provide their date of birth.

The Service uses the supplied date of birth to determine whether the applicant meets the minimum age requirement.

Honest Dating's standard registration process does not independently establish a person's actual age through government-issued identification.

Our human-verification process establishes that a real person completed the required verification procedure. It must not be interpreted as verification of legal identity, legal name, or actual age.

If we become aware that an account belongs to an individual under 18, we will take appropriate action, including restricting or terminating the account and handling associated information in accordance with applicable law.

We do not knowingly provide the Service to minors.

4. Personal Information We Collect

The categories of personal information we process depend on the features you use and the information you choose to provide.

4.1 Registration and Account Information

During registration and account management, we collect or receive:

First name.
Gender.
Date of birth.
Email address, where supplied by the authentication provider.
Apple or Google authentication identifiers.
Internal account identifier.
Registration date.
Account status.
Authentication and session information.
Records of applicable legal acceptance and consent.

We use Apple and Google authentication so members do not need to create a separate Honest Dating password.

Certain core registration details are protected after registration to support account integrity.

Requests to correct protected information may require additional verification.

4.2 Human Verification and Biometric Information

Honest Dating uses Didit as its launch human-verification provider.

The verification process may involve:

A live facial capture.
Liveness and anti-spoofing checks.
Facial measurements or biometric representations.
Verification-session identifiers.
Verification outcomes.
Information needed to compare the main profile photograph with the person who completed verification.
Relevant account-integrity and duplicate-detection signals, where implemented.

Our objectives are to establish that a real person completed the verification process and that the main profile photograph is consistent with that person.

We do not describe this process as government identity verification.

Further information is provided in Section 8.

4.3 Profile Information

Honest Dating processes the information you provide when building and maintaining your profile.

Depending on the applicable profile fields, this includes:

Main profile photograph.
Additional Gallery photographs.
Sexual orientation.
Dating intention.
Height and body type.
Languages spoken.
Country of origin.
Religion and related preferences.
Social orientation.
Going-out preferences.
Living arrangement.
Diet.
Exercise preferences.
Alcohol, smoking, and recreational-drug preferences.
Pets.
Children-related information.
Education level.
Current study.
Work status.
Political views.
Personal interests.

Certain information may reveal special categories of personal data under the GDPR. Additional safeguards apply to such information.

4.4 Optional Profile Features

Members may voluntarily provide additional information through optional profile features, including 100 Questions for Us.

We process the answers you submit and the information necessary to display and compare them according to the feature's rules.

Completing 100 Questions for Us is optional.

4.5 Discover and Connection Information

When you use Discover and connection features, we process relevant information including:

Discovery preferences and filters.
Applicable account visibility and matching settings.
Romantic Likes and their accompanying reasons.
Friendship Offers and their accompanying reasons.
Matches and established Friendships.
Connection status and timestamps.
Unmatching and blocking activity.
Relevant account restrictions.

Romantic Like reasons remain private until the applicable mutual Like establishes a Match.

Friendship Offer reasons become visible to the recipient when the offer is delivered.

4.6 Messages and Communications

When you communicate through Honest Dating, we process information necessary to operate the relevant features.

This may include:

Message content.
Sender and recipient identifiers.
Conversation identifiers.
Message timestamps.
Delivery and communication status.
Relevant voice and video call metadata.
Associated safety reports, where applicable.

Honest Dating does not routinely record or store the audiovisual content of voice or video calls.

If audiovisual recording functionality is introduced in the future, we will provide appropriate notice and establish the necessary legal basis before implementing it.

4.7 Target Me Information

When you use Target Me, we process:

Submitted post content.
Selected audience criteria.
Identity-display mode.
Reply style.
Publication and expiration information.
Public discussion content.
Private replies.
Applicable moderation results.
Reports and relevant audit records.

Target Me uses relevant member information to determine whether recipients meet the author's selected audience criteria.

Recipients may access the applicable “Why am I seeing this?” explanation.

Where Incognito is available, the author's profile identity is concealed from other members through the relevant interface.

Incognito does not make the author anonymous to Honest Dating.

4.8 Membership and Payment Information

Honest Dating operates a member-selected pricing model called Your Fairness.

Following the applicable free period, members select their contribution at the end of each monthly membership period.

Members may choose a different amount each month, from the available prices of USD $1–$10.

We process information including:

Membership status.
Applicable billing periods.
Monthly contribution selections.
Payment transaction identifiers.
Payment dates and amounts.
Payment status.
Refunds and disputes.
Relevant accounting records.

Payments are processed through authorized payment infrastructure, including Stripe where applicable.

We do not need to store complete payment-card credentials in our own application systems to administer membership payments.

4.9 Technical and Security Information

We process technical information necessary to operate and protect the Service.

Depending on the implementation, this may include:

IP address.
Device and application information.
Operating system.
Application version.
Authentication and session records.
Error and diagnostic information.
Security events.
Relevant feature activity.
Account activity timestamps.

We do not use advertising identifiers to build behavioral advertising profiles.

4.10 Location Information

Honest Dating uses location information to support relevant discovery, distance calculations, and location-based Target Me criteria.

Depending on your permissions and the applicable feature, this may involve device-provided location information or other location-related data.

Our privacy design follows these principles:

Request location permissions when needed for the relevant feature.
Collect no more location precision than reasonably necessary.
Use location information to calculate eligibility and approximate distance.
Do not display precise coordinates to other members.
Do not provide other members with access to your underlying device location.
Do not maintain continuous location-history tracking as part of the standard Service.

You may manage device-location permissions through your device settings.

Restricting location access may affect features that require location information.

4.11 Reports, Support, and Safety Information

When you contact us, submit a report, or participate in a safety investigation, we may process:

Your correspondence.
Relevant account identifiers.
Reported content.
Information supplied as evidence.
Investigation notes.
Moderation decisions.
Appeals.
Applicable enforcement and audit records.

Access to this information is restricted to appropriately authorized personnel.

5. Sources of Personal Information

We receive personal information from:

You: Through registration, profile creation, communication, feature use, consent choices, and support interactions.

Authentication providers: Apple and Google, where you authorize authentication.

Verification providers: Didit, in connection with the applicable verification process.

Other members: Through interactions, communications, Friendship Offers, and reports.

Payment providers: Through information necessary to administer membership payments.

Your use of the Service: Through relevant technical, security, and operational events.

Authorized service providers: Where necessary to operate, maintain, or protect Honest Dating.

6. Purposes and Legal Bases for Processing

We process personal information only where an applicable legal basis exists.

The relevant basis depends on the information and purpose involved.

Processing purpose – Applicable legal basis:

Creating and administering your account – Performance of a contract
Providing profile, discovery, connection, and communication features – Performance of a contract, together with additional consent where required
Processing biometric verification information – An applicable GDPR Article 6 basis and Article 9 condition, including explicit consent where relied upon
Processing special-category profile information – An applicable Article 6 basis and Article 9 condition, including explicit consent where relied upon
Operating Target Me – Performance of a contract, together with additional consent where required
Processing membership payments – Performance of a contract
Maintaining statutory financial records – Compliance with a legal obligation
Preventing fraud and protecting platform security – Legitimate interests or legal obligation, as applicable
Investigating reports and enforcing platform rules – Legitimate interests, contractual necessity, or legal obligation, as applicable
Responding to valid legal requests – Compliance with a legal obligation or another applicable basis
Maintaining essential operational analytics – Legitimate interests, subject to applicable safeguards
Sending optional marketing communications – Consent or another legally permitted basis
Operating non-essential cookies and similar technologies – Consent where required

Where we rely on legitimate interests, we assess the relevant purpose against the rights and freedoms of affected individuals.

Where processing relies on consent, you may withdraw that consent in accordance with applicable law.

Withdrawal does not affect processing lawfully carried out before withdrawal.

7. Sensitive Personal Information and Explicit Consent

Honest Dating processes certain categories of information that receive additional protection under applicable data-protection law.

These may include:

Sexual orientation.
Religious beliefs.
Political opinions.
Biometric information processed for unique identification.
Other special-category information voluntarily disclosed through supported features.

Where processing falls within Article 9 of the GDPR, we identify an applicable Article 9 condition in addition to the relevant Article 6 legal basis.

7.1 Separate Consent

Where we rely on explicit consent, we request it through a separate, affirmative action before the relevant processing begins.

Consent for biometric verification is requested separately from consent concerning sensitive profile information.

Where applicable, we also explain which information may be displayed to other eligible members or used for Discover and Target Me audience selection.

Accepting our Terms of Service or acknowledging this Privacy Policy does not, by itself, constitute explicit consent to process special-category personal data.

7.2 Consent Records

We maintain appropriate records of consent, including:

The relevant consent purpose.
The applicable notice or consent version.
The member's affirmative selection.
The timestamp.
Applicable withdrawal or change history.

7.3 Withdrawal of Consent

You may withdraw consent through the available privacy controls or by contacting us.

Withdrawal does not affect the lawfulness of processing performed before withdrawal.

If consent is necessary for a feature that cannot lawfully operate without it, we will explain the resulting feature restriction or account-management options.

We will not treat withdrawal as permission to retain or continue processing information without another valid legal basis.

7.4 Sensitive Information and Advertising

We do not sell sensitive personal information.

We do not use biometric information, sexual orientation, religious beliefs, or political opinions to deliver third-party behavioral advertising.

8. Didit Human and Biometric Verification

8.1 Verification Provider

Honest Dating uses Didit for human verification at launch.

Didit processes verification information to support the checks configured by Honest Dating.

The relevant responsibilities, data flows, processing locations, and retention arrangements are governed by the applicable provider configuration and contractual documentation.

8.2 Purpose

The verification process helps establish that:

A real person completed the required liveness verification.
The main profile photograph is consistent with the person who completed verification.

It also supports appropriate account-integrity and anti-impersonation measures.

This process does not establish a member's legal identity or independently verify their actual age.

8.3 Explicit Consent

Before biometric verification begins, members are presented with a separate explanation of the processing and asked to provide explicit consent where this is the applicable Article 9 condition.

The explanation identifies:

The verification purpose.
The categories of information involved.
Didit's role.
Applicable retention arrangements.
The consequences of declining or withdrawing consent.
How to exercise relevant privacy rights.

Verification does not begin before the required consent is obtained.

8.4 Data Minimization

Honest Dating configures the verification integration to receive only the information necessary for the relevant verification and account-integrity purposes.

Raw verification media should not be transferred to or retained by Honest Dating's systems where a verification result or other less intrusive information is sufficient.

8.5 Provider Model Improvement

Honest Dating's launch privacy configuration does not authorize Didit to use member verification information for optional model training or improvement on Honest Dating's behalf.

The relevant provider setting must be disabled before processing live member information.

8.6 Processing Location

Our launch configuration prioritizes Didit's available EU processing arrangements.

Any applicable international access or transfer remains subject to the safeguards described in Section 14.

8.7 Retention

Our standard retention target for Didit verification-session information and associated verification media is 30 days.

A reusable biometric representation may be retained separately only where necessary to support an implemented verification or account-integrity function, supported by an appropriate legal basis and documented retention arrangement.

If retained, it must be subject to restricted access, purpose limitation, periodic necessity review, and deletion when no longer justified.

The retention and deletion arrangements must also be consistent with Didit's technical capabilities and applicable contractual commitments.

8.8 Additional Notice

Further operational details are provided through the Biometric Data & Verification Notice presented in connection with registration.

9. Information Visible to Other Members

Honest Dating is designed to facilitate meaningful human connections. Certain information is therefore intentionally shared with other eligible members.

9.1 Profile Visibility

Depending on applicable settings and eligibility rules, members may see:

Your main profile photograph.
First name and age.
Approximate distance.
Profile attributes.
Gallery content.
Interests.
Answers provided through 100 Questions for Us.

Information displayed through the Service is subject to the relevant account-status, visibility, and blocking rules.

9.2 Romantic Likes

The reason accompanying a romantic Like remains private until the applicable mutual Like establishes a Match.

9.3 Friendship Offers

The reason accompanying a Friendship Offer is visible to its recipient immediately upon delivery.

9.4 Private Communications

Private messages are intended for the participants in the relevant conversation.

Access by authorized Honest Dating personnel is restricted to appropriately justified operational, security, legal, or safety purposes.

9.5 Target Me

Target Me posts are delivered according to the author's selected audience criteria and applicable platform rules.

Public Discussion content may be visible to the eligible discussion audience.

Private Replies are visible to the relevant participants rather than the wider audience.

Incognito conceals the author's profile identity from other members through the relevant interface, but does not prevent Honest Dating from identifying the account for legitimate moderation, security, operational, or legal purposes.

10. Automated Processing and AI Moderation

Honest Dating uses automated processing to support account integrity, verification, audience eligibility, and content safety.

Target Me submissions are subject to moderation before publication.

Our recommended launch architecture uses a server-side AI moderation service, with OpenAI API as the proposed provider, subject to completion of the necessary contractual, technical, and privacy review.

10.1 Information Used for Moderation

Moderation is limited to information reasonably necessary to assess the relevant submission.

Depending on the circumstances, this may include:

Submitted text.
Selected audience criteria.
Relevant targeting combinations.
Applicable safety context.
Information necessary to assess potential abuse.

Biometric information is not provided to the text-moderation system.

10.2 Moderation Outcomes

A submission may be:

Approved.
Rejected.
Referred for additional review.

Members must not attempt to circumvent moderation.

10.3 Human Review

Human review is available for appropriate escalations, appeals, and consequential enforcement decisions.

Where automated decision-making falls within Article 22 of the GDPR, we comply with the applicable legal conditions and safeguards, including rights concerning human intervention and contesting decisions where required.

10.4 AI Training and Secondary Uses

We do not authorize optional use of member content to train third-party general-purpose AI models as part of the intended launch moderation configuration.

Relevant provider settings and contractual arrangements must reflect this restriction.

11. Membership and Payment Privacy

Honest Dating's Your Fairness model allows members to evaluate their experience before selecting their monthly contribution.

Following the applicable free period:

Members choose one of ten contribution amounts, ranging from USD $1 to USD $10.
The choice is made at the end of each applicable monthly membership period.
Members may select a different amount every month.
All contribution amounts provide equal access to the Service.

We process contribution selections and related transaction information for membership administration, payment processing, accounting, and applicable legal obligations.

Your contribution amount does not determine your Discover visibility, eligibility for connections, or access to additional features.

We do not create desirability rankings based on how much members pay.

Payment providers may process additional information under their applicable privacy terms.

12. Service Providers and Data Recipients

We share personal information only where necessary for a legitimate purpose and supported by an appropriate legal basis.

The categories of recipients relevant to Honest Dating include:

Provider – Purpose

Didit – Human and biometric verification
Apple – Authentication
Google – Authentication
Stripe – Payment processing, where implemented
Approved AI moderation provider – Target Me content-safety assessment
Hosting and infrastructure providers – Application operation and secure storage
Communication infrastructure providers – Messaging and supported calling features
Security and operational providers – Service reliability, fraud prevention, and diagnostics
Professional advisers – Legal, accounting, and compliance services

The final list of active production providers will be maintained in our applicable privacy documentation and internal processing records.

Plivo is not part of the standard launch registration process. If phone verification is introduced in the future, we will update the relevant disclosures before processing phone numbers for that purpose.

We require appropriate contractual, security, confidentiality, and data-protection arrangements according to each provider's role.

Where a provider acts as our processor, it must process personal data under the applicable documented instructions and legal obligations.

We do not sell member profiles, private conversations, or biometric information to advertisers or data brokers.

13. Cookies, Analytics, and Tracking

Our website and application may use cookies, software development kits, or similar technologies.

We follow a privacy-first approach.

13.1 Essential Technologies

Essential technologies may be used for:

Authentication.
Session management.
Security.
Consent-preference storage.
Necessary website and application functionality.

These technologies are limited to their necessary purposes.

13.2 Optional Technologies

Non-essential analytics and similar technologies are disabled until any legally required consent has been obtained.

Members must be able to reject optional technologies without losing access to essential functionality.

Withdrawal must be available through an accessible preference-management mechanism.

13.3 Advertising

Honest Dating does not use third-party behavioral advertising trackers as part of its intended launch configuration.

We do not sell personal data for targeted advertising.

13.4 Analytics

Operational analytics should prioritize aggregated or appropriately minimized information.

We avoid unnecessary collection of sensitive profile attributes, private message content, or precise location information for general analytics.

Further details about any implemented cookies and similar technologies will be provided in our Cookie Policy or relevant consent interface.

14. International Data Transfers

Honest Dating is operated from Slovenia and may use providers that process information in other countries.

Where personal data is transferred outside the European Economic Area, we apply an appropriate transfer mechanism under applicable law.

Depending on the circumstances, this may include:

An applicable European Commission adequacy decision.
Standard Contractual Clauses.
Additional technical, contractual, or organizational safeguards.
Another valid legal transfer mechanism.

We assess relevant international transfers according to the nature of the information, the recipient, the destination, and applicable legal requirements.

Where required, supplementary safeguards are implemented.

You may contact us to request further information about applicable transfer arrangements.

We do not represent all Honest Dating processing as exclusively EU-based merely because our primary verification or hosting configuration uses European infrastructure.

15. Data Retention

We retain personal information only for as long as reasonably necessary for the purposes described in this Policy, subject to applicable legal obligations.

The following schedule establishes our intended standard retention rules.

15.1 Standard Retention Schedule

Data category – Standard retention

Active account and profile information – While the account remains active
Ordinary profile data following account deletion – Normally deleted or anonymized within 30 days
Didit verification sessions and associated media – Target maximum of 30 days
Reusable biometric information, if implemented – Only while necessary for the documented verification purpose, subject to consent, periodic review, and applicable deletion requirements
Expired Target Me content – Normally deleted within 30 days of expiration
Private conversations – Retained while the applicable account/conversation remains retained; normally deleted within 30 days of applicable account deletion, subject to justified exceptions
Ordinary application and security logs – Normally 90 days
Routine moderation records – Normally 12 months after case closure
Serious safety or fraud evidence – According to a documented, case-specific retention decision
Payment and statutory accounting records – According to applicable statutory requirements; certain records may require retention for 10 years or another legally prescribed period
Consent records – As necessary to demonstrate compliance during the relevant processing and applicable legal limitation period
Routine backups – Normally overwritten or deleted within 30 days

15.2 Exceptions

Information may be retained longer where necessary and legally justified, including for:

Compliance with a legal obligation.
A valid preservation request or legal hold.
An ongoing safety or fraud investigation.
The establishment, exercise, or defense of legal claims.
An unresolved payment dispute.
Another documented purpose supported by an appropriate legal basis.

Extended retention is not automatic or indefinite.

Where appropriate, retained information is restricted from ordinary operational use.

15.3 Data Minimization

We periodically assess whether retained information remains necessary.

Where the relevant purpose no longer justifies retention, information is deleted or anonymized as appropriate.

Temporary feature content is not automatically retained indefinitely merely because it once appeared in the Service.

16. Account Deletion

You may request deletion of your Honest Dating account through the applicable account settings or by contacting us.

Following a valid deletion request:

The account is removed from active participation.
The profile is removed from Discover.
Ordinary account and profile information is deleted or anonymized under the applicable retention schedule.
Relevant verification information is handled according to its documented deletion requirements.
Membership and payment records are handled in accordance with applicable legal obligations.
Information subject to a valid legal hold or another justified retention requirement may be preserved.

Account deletion does not necessarily remove information independently retained by another member or information that must lawfully be preserved.

We do not retain deleted accounts indefinitely merely for possible future commercial use.

17. Your Privacy Rights

Where the GDPR applies, you have the following rights, subject to applicable legal conditions and exceptions.

Right of access: Request confirmation of whether we process your personal data and obtain access to relevant information.

Right to rectification: Request correction of inaccurate personal information.

Right to erasure: Request deletion where the applicable conditions are met.

Right to restriction: Request restriction of qualifying processing.

Right to data portability: Receive qualifying personal information in a structured, commonly used, machine-readable format and request transmission to another controller where applicable.

Right to object: Object to processing based on legitimate interests or other applicable grounds.

Right to withdraw consent: Withdraw consent at any time where processing relies on consent.

Rights concerning automated decision-making: Exercise applicable rights relating to decisions falling within Article 22 of the GDPR.

Right to lodge a complaint: Contact a competent data-protection supervisory authority.

To exercise your rights, contact: privacy@honestdating.co

We may request reasonable information necessary to verify your identity.

We respond within the timeframe required by applicable law, generally within one month under the GDPR, subject to legally permitted extensions.

18. Marketing and Service Communications

We may send necessary service-related communications concerning:

Authentication and account security.
Verification.
Membership and payment administration.
Important account changes.
Material legal or policy updates.
Relevant safety matters.

These communications are distinct from optional promotional marketing.

Where required, we obtain appropriate consent before sending optional marketing communications.

You may unsubscribe from optional marketing using the available controls.

Unsubscribing does not prevent necessary service-related communications.

19. Information Security

We implement appropriate technical and organizational measures designed to protect personal information against unauthorized access, disclosure, alteration, loss, and misuse.

Our security requirements include, as applicable:

Encryption in transit.
Appropriate encryption of stored information.
Restricted access to sensitive information.
Role-based administrative permissions.
Secure authentication and session management.
Protection of biometric information.
Controlled administrative exports.
Audit logging.
Security monitoring.
Appropriate incident-response procedures.
Regular review of access permissions.

We apply additional safeguards to particularly sensitive information, including biometric and special-category data.

No digital service can guarantee absolute security.

Where a personal-data breach triggers a legal notification obligation, we notify the relevant supervisory authority and affected individuals as required by applicable law.

20. Law Enforcement and Legal Disclosure

We may preserve or disclose personal information where required or otherwise legally permitted, including in connection with:

Valid court orders.
Lawful investigative requests.
Applicable regulatory obligations.
Serious threats to personal safety.
Fraud or unlawful activity.
The establishment, exercise, or defense of legal claims.

Official requests are assessed under our separate Law Enforcement Guidelines & Request Protocol.

We do not provide unrestricted access to member information merely because an authority requests it.

Any disclosure remains subject to the applicable legal framework and relevant privacy safeguards.

21. Changes to This Privacy Policy

We may update this Policy to reflect changes in:

The Service.
Data-processing activities.
Technology providers.
Applicable legislation.
Security practices.
Operational requirements.

The current version will be published on our website.

Where required, we will notify members of material changes and obtain additional consent before beginning processing that requires it.

Changes to this Policy do not retrospectively authorize processing for which a separate valid legal basis was required.

22. Contact Information and Complaints

For privacy questions, personal-data requests, or concerns about how your information is handled, contact:

Vumira d.o.o.
Operator of Honest Dating
Republic of Slovenia

Registered Address: Rakuševa ulica 8, 1000 Ljubljana, Slovenia
Company Registration Number: 7427093000

Privacy Email: privacy@honestdating.co
General Contact: info@honestdating.co
Website: https://www.honestdating.co/

You also have the right to lodge a complaint with a competent supervisory authority.

The supervisory authority in Slovenia is:

Information Commissioner of the Republic of Slovenia
Informacijski pooblaščenec

Website: https://www.ip-rs.si/

If you reside in another EU or EEA country, you may also have the right to contact your local competent supervisory authority.