← Swoonsign · Privacy · Terms
This notice covers the closed beta (TestFlight, iOS).
Privacy Policy, beta of the Swoonsign app
Beta version 0.2, published on [PUBLICATION DATE TO BE COMPLETED].
This policy explains what data we process when you use the beta version of the app, why we do it, how long we keep it and how to exercise your rights. If anything is unclear, contact us (section 13).
In short:
- The app is for adults only (18+).
- You chat with characters generated by artificial intelligence. They are never humans.
- Your conversations and some questionnaire answers are sensitive data (romantic and sex life, sexual orientation). We only process them with your explicit consent.
- We do not sell your data. There is no advertising during the beta, and we never target ads based on your sensitive data.
- Your data is hosted in the European Union (Ireland, AWS region
eu-west-1). Character replies are generated by Mistral AI, a French company, through its EU service. - During the beta, Mistral AI may keep messages sent to it for up to 30 days to detect abuse. On 19 October 2026 we asked Mistral AI for zero data retention; that request is still pending.
- You can delete your account from within the app at any time.
1. Who is responsible for your data?
| Data controller (individual) | [NAME, ADDRESS IN BELGIUM TO BE CONFIRMED] |
| Company number (BCE/KBO) | [BCE NUMBER, IF ANY, TO BE CONFIRMED] |
| Privacy contact | privacy@<domaine> (support and DPO address for data copy requests) |
| Data Protection Officer (DPO) | [TO BE COMPLETED: not appointed yet] |
| Lead supervisory authority | Data Protection Authority (APD/GBA, Belgium) (section 13) |
2. What data do we process?
| Category | Examples | Source |
|---|---|---|
| Account | Technical ID, email address (magic-link sign-in), Apple or Google ID if you use that sign-in | You, Apple or Google |
| Profile | First name or nickname, pronouns (optional) | You |
| Date of birth | Used to check that you are 18+. If you agree, it is also used to work out your sun sign | You |
| Birth time and place (optional) | Used only to calculate your rising sign. The calculation runs on your phone. This information is never sent to our servers and never stored. We keep only your rising sign, encrypted | You |
| Intimate preferences (sensitive data) | Gender of the characters you want to discover (may reveal your orientation), desired intensity, limits, relationship tone, character types, tropes, pace, love language | You (questionnaire) |
| Conversations (sensitive data) | Your messages, character replies, summaries, "facts" saved in the Journal (e.g. a friend's name, a life event) | You and the AI |
| Personalisation | Character personality changes, relationship level, swipes, matches, blocked characters | Calculated by the app |
| Safety | Reports, moderation decisions, anonymised crisis events (no text), suspensions | You and our systems |
| Subscription | Subscription status and receipts sent by Apple. We never see your payment card details | Apple, via RevenueCat |
| Technical | Push token, pseudonymised technical logs, scrubbed crash reports | Your device |
| Consents | Your choices, with the date and the version of the text you accepted | Our systems |
| Wellbeing and check-in (may reveal health information) | Time spent and night-time sessions over a rolling 7 days, the excessive-use signal, when wellbeing messages were shown, and your answer to the check-in "How are you feeling right now?" (4 possible answers: "Fine, I just wanted to chat", "I need some rest", "A bit lonely lately" and "Not good at all") | You and our systems |
What we do not collect:
- your location or contacts;
- your photos (no photos are requested during the beta);
- your advertising ID;
- your birth time and place (they never leave your phone).
Other people you mention. If you talk about other people (friends, family, exes), their information is processed in the same way as your conversations. Please share only what is necessary.
3. Why, and on what legal basis?
| Purpose | Legal basis (GDPR) |
|---|---|
| Create and manage your account | Performance of a contract (Art. 6(1)(b)) |
| Check that you are 18+ and protect minors | Legitimate interest and child-protection obligations (Art. 6(1)(f) / 6(1)(c)) |
| Suggest compatible characters (matching) based on your intimate preferences | Contract (Art. 6(1)(b)) and your explicit consent for sensitive data (Art. 9(2)(a)) |
| Run conversations, memory and evolving personality | Contract (Art. 6(1)(b)) and your explicit consent (Art. 9(2)(a)) |
| Send your messages to the AI provider (Mistral AI) to generate replies | Your explicit consent, collected before anything is sent |
| Astrology (sun sign, rising sign) | Your consent (Art. 6(1)(a)), optional |
| Send you messages from characters (notifications) | Your consent (phone permission) |
| Preventing excessive use (wellbeing messages, check-in, suggested break) | Legitimate interest in protecting users (Art. 6(1)(f)) and, for any health data, your explicit consent (Art. 9(2)(a)), as in our impact assessment |
| Safety, moderation, crisis detection, abuse prevention | Legitimate interest and legal obligations (Art. 6(1)(f) / 6(1)(c)). For sensitive data, your explicit consent (Art. 9(2)(a)) |
| Manage your subscription | Contract (Art. 6(1)(b)) and accounting obligations (Art. 6(1)(c)) |
| Audience measurement and service improvement | Your consent (optional) |
| Improve models using your conversations | Only if you opt in (off by default). In every case, we do not allow Mistral AI to train its models on your data |
| Handle your rights requests | Legal obligation (Art. 6(1)(c)) |
Matching and personalisation are profiling. They are used only to suggest characters and adapt how characters behave. They have no legal or similarly significant effect on you. The "Why this match?" button explains the criteria used.
4. Your consents
When you sign up, we ask for separate consents. No box is pre-ticked.
| Code | What it covers | Required? |
|---|---|---|
| C1 | Terms of use and content rules | Yes |
| C2 | Processing of your conversations (sensitive data) | Yes, this is the core of the service |
| C3 | Processing of your intimate preferences (sensitive data) | Yes, this is the core of the service |
| C4 | Sending your messages to Mistral AI to generate replies | Yes, this is the core of the service |
| C5a | Using your date of birth for astrology | No |
| C5b | Using your birth time and place for your rising sign (calculated on your phone) | No |
| C6 | Using your conversations to improve our models | No (off by default) |
| C7 | Audience measurement | No |
You can withdraw any consent at any time in two taps, under Settings → Privacy. The related data is then deleted within 24 hours. If you withdraw C2, C3 or C4, the app can no longer work, so we will offer to delete your account.
5. Artificial intelligence: what you should know
- The characters are AI. They are not human and do not have feelings. An "AI" badge is shown everywhere, with regular reminders.
- How are replies generated? By Mistral AI models (France), through their EU-hosted service. We send what is needed to reply: the character description, a summary of your chats, up to 20 saved facts and the latest messages. We never send your email or account ID (data is pseudonymised).
- Retention at Mistral AI. Without zero data retention, Mistral AI keeps these exchanges for 30 rolling days to detect abuse, then deletes them. We requested zero data retention on 19 October 2026. Until it is granted, the 30-day period applies. We turn off the use of our data for training Mistral AI's models.
- Memory. A character remembers at most 20 facts about you. The "Don't remember anything sensitive" switch stops it from saving intimate information. The Journal shows what the character remembers about you. You can delete one fact in one tap, or wipe everything for a character. A new fact can take up to 10 messages to appear in the Journal.
- Content limits. No nudity and no explicit sexual content. All characters are 25 or older.
6. Crisis detection and protection
For your safety, messages are automatically scanned for signs of serious distress, such as suicidal thoughts. If such a sign is detected:
- the character does not reply;
- the app shows help lines for your country (checked on 19 October 2026):
- France: 3114 (suicide prevention, 24/7) and SOS Amitié 09 72 39 40 50;
- United States and Canada: 988;
- UK and Ireland: Samaritans 116 123;
- Spain: 024;
- Belgium: 0800 32 123 (French) or 1813 (Dutch);
- Switzerland: 143;
- elsewhere: 112 (911 in North America);
- we only record that an alert happened, anonymised and without the text of your message;
- we do not contact anyone on your behalf.
We also look for signs that a minor is using the app. In that case the account is suspended and we ask for verification. If the user is confirmed to be a minor, their data is deleted.
Wellbeing and excessive use
If you spend a lot of time in the app (for example more than 4 hours a day for 3 days, or often at night), we let you know gently:
- first, a message suggests you get some rest or see the people close to you. It is a fixed, pre-written line: it is not generated by the AI, and Mistral AI learns nothing about this signal or your check-in;
- then, a screen asks how you are feeling, with 4 answers: "Fine, I just wanted to chat", "I need some rest", "A bit lonely lately" and "Not good at all". Answering is optional: the "Not now" button lets you skip. If you answer "Not good at all", we show you the helplines for your country.
This wellbeing data and your check-in answer are never sent to the character or to Mistral AI. They are used only, on your phone and on our servers, to show these screens and to pause commercial offers and spontaneous messages the next day. They are kept for 30 rolling days, then deleted. Our wellbeing statistics are anonymous aggregates only.
7. Who receives your data?
Access is limited to authorised people: during the beta, that is the project owner, who handles safety and moderation. They access data only for moderation and support, and every access is logged. Our service providers (processors) handle data on our behalf under contracts that comply with Article 28 GDPR:
| Provider | Role | Data location |
|---|---|---|
| Supabase (Supabase Pte. Ltd., Singapore) | Hosting: database, authentication, server functions | EU (Ireland, eu-west-1) |
| Mistral AI (France) | Reply generation, summaries, moderation | EU |
| RevenueCat (USA) | Subscription management (pseudonymous ID and receipts only) | USA |
| Expo (650 Industries, USA) | Push notifications (neutral content: "New message") | USA |
| Sentry (Functional Software, USA) | Scrubbed crash reports (no conversation content) | EU (Frankfurt), some metadata in the USA |
| Email provider [TO BE COMPLETED] | Sign-in links and confirmation emails | EU [to be confirmed] |
| Analytics tool [TO BE COMPLETED], only if you accept C7 | Pseudonymised usage statistics, never your questionnaire answers or conversations | EU [to be confirmed] |
Apple (TestFlight, App Store, Sign in with Apple, payments) and Google (if you sign in with Google) also process data, as independent controllers under their own policies.
The detailed, up-to-date list is published here: [LINK TO BE COMPLETED to subprocessors page].
We do not sell your data. We share no questionnaire answers and no conversations with ad networks, attribution tools or analytics tools. There is no advertising during the beta.
8. Transfers outside the European Union
Your conversations and profile are hosted in the EU. However, some providers are based outside the EU: Supabase in Singapore, and RevenueCat, Expo and Sentry in the USA. They may access some data from abroad (support, metadata). These transfers are covered by the European Commission's Standard Contractual Clauses and, where applicable, the EU–US Data Privacy Framework. You can ask us for a copy of these safeguards (section 13).
9. How long do we keep your data?
| Data | Retention |
|---|---|
| Account, profile, questionnaire, conversations, Journal, personality, relationship level | As long as your account exists. Deleted after 24 months of inactivity, with a warning email one month before [to be confirmed] |
| A fact deleted from the Journal | Deleted immediately and removed from the summary |
| Birth time and place | Never stored |
| Sun sign and rising sign | Until you withdraw consent or delete your account |
| Copy at Mistral AI | Up to 30 days while zero data retention is pending; no retention once it is granted |
| Backups | 7 days at most on the Pro plan, then overwritten automatically. On the Supabase Free plan (beta), there are no backups; the 7-day window will apply once we move to Pro |
| Ordinary reports | While your account exists (12 months at most), then deleted or anonymised |
| Wellbeing data and check-in answer | 30 rolling days, then deleted; never sent to Mistral AI |
| Technical logs | 30 rolling days, with no content and no email |
| Crisis events | Anonymised, no text (statistics only) |
One rule: when you delete your account, everything is erased (section 10). Only three exceptions, required by law, remain, and they are kept to a strict minimum:
| Exception | What is kept | Where | How long |
|---|---|---|---|
| Invoices and proof of purchase | Transaction ID, product, amount, date | Issued and kept by Apple and RevenueCat (not with us) | Under their own legal obligations |
| Proof of your consents | Which consent, which text version, when, and any withdrawal. No messages and no questionnaire answers | Restricted-access archive | 5 years after your account is deleted |
| Serious reports (e.g. content involving a minor) | The report, the decision and only the evidence strictly needed | Safety lead only | 12 months (unless an authority's request is pending) |
Any accounting records of the publisher are kept for the period required by Belgian law [period to be confirmed]. They contain neither your messages nor your questionnaire answers.
10. Deleting your account
In the app: Settings → Account → Delete my account (3 taps at most).
- Everything is erased: from our systems within 24 hours, and from backups within 7 days (on the Pro plan). On the Supabase Free plan (beta), there are no backups; the 7-day window will apply once we move to Pro. Only the three legal exceptions in section 9 remain.
- At Mistral AI, it is gone no later than 30 days after it was sent while zero data retention is pending (no retention after that).
- You receive a confirmation email.
- Remember to cancel your subscription in your Apple account settings: deleting your account does not stop it automatically. The app gives you a direct link.
11. Your rights
You have the right to:
- access your data and get a copy of it (portability);
- rectify it;
- erase it;
- restrict processing;
- object to processing;
- withdraw your consent at any time;
- give instructions on what happens to your data after your death (French law, if you live in France).
| Right | How |
|---|---|
| Rectification | In the app: My profile, questionnaire, Journal |
| Erasure | In the app (section 10); delete a Journal fact in one tap |
| Withdrawing consent | Settings → Privacy |
| Access and portability | During the beta, by email to privacy@<domaine>. We reply within 30 days at most, with a readable export (e.g. JSON or HTML) sent securely. Self-service export will come in a later version |
| Other rights | By email to privacy@<domaine> |
We may ask you to confirm that the request comes from you, for example by replying from the email address linked to your account.
12. Security
- Hosting in the EU.
- Encryption in transit (TLS).
- Encryption of stored sensitive data: conversations, facts, summaries, intimate answers, astrological signs, consents.
- Strict separation between accounts.
- Limited admin access, protected by two-factor authentication and logged.
- Pseudonymised data sent to the AI provider.
- Scrubbed technical reports.
If a data breach creates a risk for you, we notify the Belgian Data Protection Authority (APD/GBA) within 72 hours. If the risk is high, we notify you as well.
13. Contact and complaints
- For any question or request: privacy@<domaine>.
- You can also lodge a complaint with the Belgian Data Protection Authority (APD/GBA), our lead supervisory authority: Rue de la Presse 35, 1000 Brussels, Belgium · phone +32 2 274 48 00 · contact@apd-gba.be · www.autoriteprotectiondonnees.be (contact details checked on 19 October 2026 on its official website).
- You can also contact the supervisory authority of the EU country where you live or work (Article 77 GDPR), for example the CNIL in France (www.cnil.fr). In the UK, the competent authority is the ICO.
14. Minimum age
The app is not allowed for anyone under 18. If you think a minor is using it, tell us at privacy@<domaine>: we will suspend the account and delete the data.
15. Changes
We may update this policy, for example before public launch or when we add new features (generated photos, rewarded ads, web payments). We will tell you about any significant change in the app before it takes effect. If the change requires your consent, we will ask for it again.