2. What Personal Data do we collect?
Some of the personal data we collect is mandatory for the provision and functioning of PURE, while other personal data is considered optional, designed to enhance your user experience. Please be aware that without providing the mandatory personal data, we won't be able to grant you access to PURE.
a. When visiting the Website and/or App
When you visit the Website or App, we can process the following categories of Personal Data from you:
- Technical Data: IP address, operating system, date and time of access, country from which PURE is accessed (based on IP address), browser type, referrer URL, log-in data, and device type;
- Tracking Data: See Article 5 below.
When you participate in our Pure Dating app Creator Community Program via the Website, we collect information you voluntarily provide through a short online form, including your full name, location, Instagram and/or TikTok username, and email address. This information is used solely to assess your suitability for potential collaboration opportunities and to contact you regarding creator partnerships with PURE. The data collected is not linked to any PURE User account. Participation is entirely voluntary and independent of using PURE.
b. When creating an account
When you create your PURE account, you voluntarily provide us with certain information. In this way, we can process the following categories of your Personal Data, which are either mandatory or optional for creating account and using PURE:
Mandatory:
Identity data:
- Gender (man, woman or non-binary);
- Sexual orientation (heterosexual, bisexual, lesbian, gay, queer or asexual);
- Date of birth;
Profile data:
- Account data, including User ID.
Optional:
Contact data:
- Email address (see Article 8 of this Privacy Policy);
Profile data:
- Identity data, details about your ad (personal description, height, spoken languages);
- Sexual and other preferences (turn-ons).
c. When using PURE
When you use PURE, you voluntarily provide us with certain information. When you add information to your user profile, interact with us or other users, you make the choice to share your certain personal information with us. In this way, we can process the following categories of your Personal Data, some of which are optional, while others are mandatory to enable you to use PURE to its fullest potential and enhance your overall experience:
Optional:
- Location data, including geographical position, time identifier;
PURE is designed to help you engage with other users located nearby to you. We use your location data (e.g., by using the GPS on your mobile device) to enable the intended functionality of PURE. This will be enabled only if you explicitly give us permission to access your location. You can disable this at any given time by changing the location permissions on your device or in the browser. Please keep in mind that when you use PURE, other users can view your location data and they may use it for purposes you did not intend, or disclose it to individuals or entities outside of our control and without our and your knowledge. The information you provide may be subject to abuse, misuse, and monitoring by others, and you share this information at your own risk.
- Transactional data, including information about the application process, contract content, contract management and execution;
- Financial data, including billing and payment information;
- Usage data, being User’s content and material which has been submitted by Users as “Personal ads and Profile”, including pictures, as well as content and material which has been submitted in the chat conversations, including videos, audio, pictures, and text messages sent when communicating with others (collectively, “User Submissions”) are processed in order to secure and operate services and keep our user community safe. To protect our users and our platform, and to comply with applicable law, including child-safety and online-safety obligations that may apply in certain jurisdictions, we may use a combination of manual moderation and automated systems to detect, review, and address unlawful or prohibited content and conduct on PURE, including fraud, scams, exploitation, and child sexual abuse material (“CSAM”). This may include the review of Personal ads and content shared in chat conversations, including pictures, videos and text. For certain safety functions, including CSAM detection, the content itself and/or derived data such as hashes, results, scores, or related technical indicators may be transmitted to specialised service providers for processing. Where required by applicable law, or where potential CSAM or serious child-safety risks are identified, relevant data may be reported to the appropriate authorities. Where our systems identify potential CSAM or other serious safety risks, the content may be subject to additional analysis and review by our trained human moderators. Where relevant, flagged content may lead to further review and enforcement action in accordance with our Terms and Conditions (here).
- Usage data, being pictures and videos that you upload, publish or provide in any other way. In order to add this kind of content, you first have to give us permission to access your photo album/gallery and/or your camera. You can revoke photo and camera access at any time through your device’s Settings menu;
- Information about the images (e.g. metadata), such as the location of a photo and device information. If users choose to share images on PURE and use them in their ads, they also consent to the sharing of metadata related to those images. This serves as a tool for the moderation process, aimed at preventing potential scams and other fraudulent activities. In our commitment to prioritizing users’ privacy, the collected location data is approximate and generalized rather than precise. It is important to note that this data is used solely for moderation purposes and is treated with the utmost confidentiality and security.
- Usage data, including activity data, online interactions with us and with other users; as well as technical and interaction data collected through analytics and session replay tools (see Article 6 below) that help us understand how PURE is used, improve functionality, and resolve technical issues;
- Sexual identity data, including sexual orientation and other sexual preferences (turn-ons and types of connections you prefer);
- Marketing and communications data, including your marketing preferences, your insights into our products and services, responses and testimonials your provide us when you participate in surveys, market studies or answering questions;
- Marketing and communications data, including information that is used for participation in different contests, events and promotions we provide;
- For Users in the European Union: If you submit report on illegal content under Digital Services Act (DSA) via email, we collect the information that you give us in the form,
- If you contact our customer support team, we collect the information you give us during the interaction,
- If you appeal a decision made by us to revoke your license, authorization to access and/or use PURE, and terminate your account pursuant to our Terms and Conditions, we may ask for the Apple Private Relay email address (the randomised email ending with @privaterelay.appleid.com) or the original email used for registering on PURE to identify duplicate accounts following automatic bans, as this helps us locate the original account in our database and address the issue, and
- Identity data, being a photographic image of you and/or your form of identification to confirm your date of birth when appealing our decision to revoke your license, authorization to access and/or use PURE, and terminate your account for failure to comply with our minimum age requirements, or to verify the authenticity of your profile in the event of a suspected breach of our Terms (see more here).
- Biometric data, you have an option to voluntarily complete a profile Photo verification process to earn a Verification badge. The provided in-app feature allows us to confirm a match between the captured photos during the process and the ones you’ve uploaded to your profile on PURE.
For all users, the photos captured during the Photo verification process are stored on our servers and are used only for the core functionality of this feature. These photos are then compared exclusively on the server side to confirm a match. We do not and will not use collected biometric data to personally identify users. All biometric data collected during the comparison process will be securely stored on our servers, will not be shared with any third parties, and will be handled in strict accordance with our privacy and data protection standards. Even if the process was not successful, biometric data will be retained in our systems in accordance with Section 11 below for as long as necessary to fulfill the purposes described in this subsection.
For iOS users, the provided feature also leverages Apple’s TrueDepth API to ensure liveness detection, verifying that the person submitting the photo is physically present and following instructions to move their face (e.g., turning the head to the right or left). None of the data collected by the TrueDepth API is persistently stored on your device or leaves your device. We do not store or retain any data captured directly by the TrueDepth API on our servers, nor do we share any data with third parties. If you have any questions or concerns related to the handling of your personal data in regard to this topic, please contact us by email at [email protected].
The Verification badge, if awarded, is for informational purposes only and may be automatically removed if you change or remove the submitted picture, or if the face does not match during a subsequent check. You can remove your Verification badge by deleting your account. Upon account deletion, any biometric data collected during the process, as described above, will also be permanently deleted. If you choose to cancel the Photo verification process at any point before its completion, no biometric data related to this process will be retained. For more details about the Photo verification feature, please see our Terms and Conditions (here).
For Users in the United States: In jurisdictions where biometric privacy laws apply, our collection, use, storage, and retention of biometric data in connection with the Photo Verification process is further governed by our Biometric Data Privacy Policy (here).
d. Age Verification
To enforce our minimum age requirements, protect minors, and safeguard the safety and integrity of PURE, we may require certain users to complete an Age Verification process before they can access or continue using certain features of PURE. This may apply where age verification is required by applicable law, where age-estimation or age-verification tools form part of the access flow in a particular jurisdiction, and/or where our systems or human moderators identify indicators of a potential breach of our Terms and Conditions or applicable guidelines, including but limited to suspected underage users or fake accounts. Where Age Verification is required, it is typically carried out through an automated step-by-step process provided by our third-party partner Veriff and may involve the submission of a government-issued identity document and a face scan or liveness photo to confirm eligibility. See more in our Terms and Conditions (here).
After the Age Verification process, Veriff provides PURE with the verification outcome in the form of a pass-or-fail result, together with limited related information made available to PURE in connection with the verification. This may include certain data points generated or extracted during the verification process, such as gender, estimated gender, estimated age, and the user’s date of birth. PURE uses the pass-or-fail result only to decide whether the user may access or continue using PURE and, where appropriate, whether account restrictions or enforcement action should be applied for failure to satisfy age verification requirements or for breach of our Terms and Conditions. Veriff’s verification flow may involve automated analysis of the submitted information and related verification checks, including the processing of photos or video of the verification session, face scans and other measurements, and a comparison with submitted documents. PURE does not receive the source images, face snapshots, biometric templates, or other underlying biometric data processed by Veriff. To initiate the verification flow, we share with Veriff only an internal unique identifier assigned to the User.
Veriff collects, processes, and stores the underlying verification data on its side. According to Veriff’s current retention framework, session data used for identity verification may be retained for 90 days in active storage and then for up to 3 years in secure archive, subject to Veriff’s applicable retention settings and policies. Veriff may also process certain verification data, which may include biometric or other data generated during the verification flow, for its own purposes, including fraud prevention, service development and improvement, and machine learning training or related purposes, where it acts in its own capacity and on its own legal basis. To see how your data is collected, processed, and retained by Veriff, please refer to Veriff’s Privacy Notice (here) and their Data Retention Policy (here). PURE retains the verification result and related review or appeal data only for as long as necessary for account management, compliance, and dispute-resolution purposes, unless a longer retention period is required by law or is necessary for the establishment, exercise, or defence of legal claims.
If the automated procedure cannot be completed for any reason (for example, if the service is unavailable), we may invite you to undergo a manual review of your government-issued document by one of PURE’s trained human moderators. Veriff is not involved in this fallback process, which happens on PURE’s side and outcome is stored exclusively on PURE’s systems. Any personal data processed by PURE in connection with such manual review will be retained only for as long as strictly necessary for the verification, review, appeal, compliance, or dispute-resolution purpose for which it was collected, and then deleted in accordance with this Privacy Policy. Users have also the right to request human review and contest a verification-related decision.
