Spothint ("the app", "we", "us") is a real-life-first dating app: two people who notice each other in person can each report the encounter, and if the reports match, an automated AI verification step confirms it is mutual before revealing any profile or personal information. You can also publish a public listing describing an encounter, for the other person to find and claim.
This policy explains what personal data we process, why, on what legal basis, with whom we share it, how long we keep it, and what rights you have. It applies to the Spothint mobile app and to the website spothint.com.
Simone Vallifuoco, individual based in Italy
Certified email (PEC): simone.vallifuoco@pec.it
Email: info@spothint.com
We have not appointed a Data Protection Officer, as we are not required to. For any privacy matter, write to info@spothint.com.
| Data | Purpose | Legal basis (GDPR) |
|---|---|---|
| Account data (email, authentication credentials; name and email from Google or Apple if you sign in with them. With Apple you can hide your email: we then receive only an address created by Apple that forwards messages to you) | Create and secure your account, sign you in | Performance of a contract (Art. 6(1)(b)) |
| Profile data (first name, last name, date of birth, gender, language, country) | Create your profile, verify you are 18+, show compatible people, show listings from your country | Performance of a contract (Art. 6(1)(b)); legitimate interest in keeping minors off the app (Art. 6(1)(f)) |
| Gender preference (who you want to meet) | Match you with compatible people; shown together with your gender on your public listings | Your explicit consent (Art. 6(1)(a) and Art. 9(2)(a)), because it can reveal your sexual orientation |
| Location: the place of an encounter you report, and your device's precise location only when you choose to use it | Check whether two reports describe the same place and time window; show listings near an area you choose | Your consent (Art. 6(1)(a)), given through a dedicated in-app notice and your device's location permission |
| Profile photo (optional) | Show your photo to confirmed matches; automatic moderation to block explicit, violent or hateful content | Performance of a contract (Art. 6(1)(b)); legitimate interest in user safety (Art. 6(1)(f)) |
| Encounter descriptions, public listings and verification answers | Confirm whether a match is genuine; publish your listing if you choose to | Performance of a contract (Art. 6(1)(b)) |
| Chat messages, including photos, videos and voice messages you send | Let two confirmed matches talk to each other | Performance of a contract (Art. 6(1)(b)) |
| Push notification tokens | Notify you of new matches and messages | Performance of a contract (Art. 6(1)(b)); you can turn notifications off in your device settings |
| Reports and blocks (of users, of single chat messages and of public listings), including a copy of the reported content kept as evidence (chat messages, the profile photo of the reported person, the text of a reported listing), and a log of the moderation actions taken (for example suspensions and removals) | Protect users, review reports, enforce our Terms | Legitimate interest in user safety (Art. 6(1)(f)) |
| AI verification logs | Detect errors and improve the reliability of verification | Legitimate interest (Art. 6(1)(f)), limited to the retention period in Section 7 |
Some data is required to use the app (account, profile data, gender preference, the place and time of the encounters you report). Without it we cannot provide the matching service. Your profile photo is optional.
We do not use analytics, advertising or tracking tools in the app.
Withdrawing consent. You can withdraw consent at any time: disable location permission in your device settings, or delete your account to stop the processing of your gender preference. Withdrawal does not affect processing done before it.
Photos, videos and voice messages in chat. They are visible only to the two people in the conversation, and the other person can save photos and videos to their device. Before a file is stored we remove its metadata, including the GPS position that phones record in photos and videos. The app uses the microphone only while you record a voice message, and the camera only when you choose to take a photo or video to send.
Location in detail. The app reads your device's location only when you tap "use my current location", while reporting an encounter or choosing the area in which to browse listings, and never in the background. You can also pick a point on the map instead. The area you browse is sent to our servers only to filter listings and is not stored. We also record the country of each report and listing, worked out on our own servers from its place using a map of national borders (no third party receives it), so that by default you see listings from the country set in your profile. You can change your country at any time in the app. The place of a private report is never shown to anyone: after a confirmed match, the other person may see at most a general place name.
Public listings. If you publish a public listing, its text, its place (shown as a point on the map), the date and time of the encounter, and your gender and gender preference are visible to all signed-in users. Your name, photo and other profile details are not shown, and are revealed only to a person who claims the listing and is confirmed as a match. If you add a hidden description to verify who claims your listing, it is never shown to anyone: it is used only to generate verification questions. You can close or delete a listing at any time.
Information about other people. When you describe an encounter, your description is about another person, who may not use Spothint or may not have reported the encounter. Please describe only what is needed to recognise the encounter, and do not include sensitive details (health, religion, ethnicity, etc.). The text of a private report is never shown to anyone; the verification questions generated from it are shown to the other person in a possible match, so avoid details you would not want them to read. The text of a public listing is visible to all users, including the person described. You can delete a report or listing at any time.
Whether a match is confirmed is decided by an automated system. It compares the time and place of the two reports, the encounter descriptions, and the answers each person gives to verification questions, and assesses whether they are consistent with a genuine mutual encounter. The outcome is either "confirmed" (profiles are revealed to each other) or "not confirmed" (nothing is revealed).
This processing is necessary to provide the service you requested (Art. 22(2)(a) GDPR). You have the right to request human review of a decision, to express your point of view, and to contest the decision, by writing to info@spothint.com.
Other automated safety measures work the same way and can be reviewed on request:
We do not use facial recognition and do not extract biometric data (such as face geometry) from photos.
These providers do not receive your name, contact details or exact location. Under Google's terms for these paid services, Google does not use your data to train or improve its models; Google may keep inputs for a limited period solely to detect abuse of its services. We do not use your data to train AI models either.
We do not sell your personal data and do not share it for targeted advertising. We share data only with service providers that process it on our behalf and under our instructions (data processors):
| Provider | Service | Location |
|---|---|---|
| Render (Render Services, Inc.) | Hosting of our servers and website | Servers in Frankfurt, EU; USA-based company |
| Neon (Neon, Inc.) | Database | Servers in AWS Frankfurt, EU; USA-based company |
| Google (Firebase Authentication, Google Sign-In) | Sign-in and account security | USA and other countries |
| Google (Cloud Storage for Firebase) | Profile photo storage | USA (us-east1) |
| Google (Firebase Cloud Messaging) | Push notifications | USA and other countries |
| Google (Maps Platform: Maps, Places, Geocoding) | Map display, place search and address lookup; receives the map area, the place you search or select, and your location when you use it | USA and other countries |
| Google (Gemini API) | Match verification | USA and other countries |
| Google (Cloud Vision API) | Photo moderation | USA and other countries |
| Apple (Sign in with Apple, Apple Push Notification service) | Sign-in with your Apple ID; delivery of push notifications to iPhones | USA and other countries |
We may also disclose data where required by law or by a binding request from a public authority, or to establish, exercise or defend legal claims.
Some providers are located, or may process data, outside the European Economic Area, in particular in the United States. When this happens we rely on the EU-US Data Privacy Framework (for certified providers) or on the European Commission's Standard Contractual Clauses, included in the providers' data processing terms. You can request more information about these safeguards by writing to info@spothint.com.
| Data | Retention |
|---|---|
| Account, profile, matches, chat messages | Until you delete your account |
| Encounter reports and public listings (including their place) | Until you delete the report or your account |
| AI verification logs | Deleted after 90 days, and in any case when you delete your account |
| Blocks | Until you delete your account |
| Reports of users, chat messages and public listings, with the copy of the reported content kept as evidence | Until a moderator closes the case, then 180 days, even if the accounts or the listing involved have been deleted in the meantime |
| Log of moderation actions (suspensions, reactivations, removed listings, decisions on reports and photos) | 12 months |
| Record of a moderator's decision on a profile photo held for review (a rejected photo is deleted at the decision) | 30 days after the decision |
| Database backups | Overwritten within 30 days |
Encounter reports stay active so that a match can be found even if the other person reports the encounter later.
Evidence of reports. When you report a user or a chat message, we copy the reported message and up to the 10 messages before it (text, photos, videos and voice messages, from both people), and the profile photo of the reported person, so that a human moderator can review the case. When you report a public listing, we copy its text, place, date and the first name of its author. These copies are kept separately from the chat and the listing, so they are not erased if the reported person deletes the messages, the listing or their account: otherwise anyone could avoid moderation by deleting them. They are deleted 180 days after the case is closed. We keep them on the basis of our legitimate interest in user safety (Art. 6(1)(f) GDPR) and, where relevant, to establish or defend legal claims (Art. 17(3)(e) GDPR).
Account deletion. You can delete your account in the app, under your profile. Deletion is permanent and immediate: your profile, encounter reports, public listings, matches, chat history and AI verification logs are erased (not deactivated). If you were part of a confirmed match, the shared chat history with that person is deleted as well, including photos, videos and voice messages, since the conversation belongs to both of you. Reports you made or received, the copy of the reported content and the log of moderation actions about you are kept without your account as described above. If you signed in with Apple on an iPhone, we also revoke the app's access to your Apple ID; on other devices you can remove it in your Apple ID settings. Residual copies in database backups are overwritten within 30 days. If you cannot access the app, you can request deletion by writing to info@spothint.com from the email linked to your account.
Under the GDPR you have the right to:
To exercise your rights, write to info@spothint.com. We reply within one month (extendable by two months for complex requests, in which case we will tell you). We may ask you to confirm your identity, for example by writing from the email linked to your account.
Data is transmitted over encrypted connections (TLS) and stored with providers that encrypt data at rest. Access to production data is restricted to the data controller. Photo metadata (including GPS tags) is removed before storage. Notifications never include names, places or message text. No system is completely secure: if a data breach is likely to put your rights at risk, we will notify you and the competent authority as required by law.
Spothint is only for people aged 18 or over. We check your date of birth at registration and block accounts under 18. If we learn that a user is under 18, we delete their account and data. If you believe a minor is using the app, write to info@spothint.com.
The website spothint.com does not use cookies, analytics or tracking tools and does not collect personal data. Our hosting provider may keep standard technical logs (such as IP addresses) for a short period for security purposes.
United States. Depending on your state of residence (for example California, Virginia, Colorado, Connecticut, Texas), you may have the right to know, access, correct, delete and obtain a portable copy of your data, and to opt out of sale, targeted advertising and profiling. We do not sell personal data, do not share it for targeted advertising, and do not use it for profiling with legal or similarly significant effects. We treat precise geolocation and data revealing sexual orientation as sensitive data and process it only with your consent. If we deny a request, you can appeal by replying to our answer with the subject "Appeal"; we will respond within 45 days, and if you disagree with the outcome you can contact your state Attorney General. We do not discriminate against you for exercising your rights. Our app and website do not respond to "Do Not Track" signals, as they do not track users across third-party sites or services.
Brazil. Under the LGPD you have the rights listed in Section 8, including confirmation of processing, anonymisation, and information about the entities we share data with. You can also complain to the ANPD.
Other countries. Wherever you live, you can exercise the rights in Section 8 by writing to info@spothint.com, and we will apply any additional protection your local law provides.
We may update this policy. If we make material changes, we will notify you in the app or by email before they take effect and, where the law requires it, ask for your consent again. The date at the top shows the latest version.