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.
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:
- Gender (man, woman or non-binary);
- Sexual orientation (heterosexual, bisexual, lesbian, gay, queer or asexual);
- Date of birth;
- Account data, including User ID.
Optional:
- Email address (see Article 8 of this Privacy Policy);
- 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;
- 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 ensure user safety and prevention and detection of scams, fraudulent activities, and violations of laws and regulations, principles, guidelines and other PURE policies, we use a combination of manual moderation and automated systems to monitor and review pictures and texts from chat conversations and Personal ads. This approach is in strict compliance with data protection regulations and is undertaken to meet the legal requirements imposed by specific countries concerning the transmission of explicit content. For this purpose, pictures and texts from chat conversations will be anonymized and stripped of personal information to protect your privacy, thereby ensuring data protection against unauthorized access or disclosure. We will not attempt to re-identify this anonymized data. For more details about this, please see our Terms and Conditions (here);
- 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;
- Sexual identity data, including sexual orientation and other sexual preferences (turn-ons and types of connections you prefer);
- Your insights into our products and services, responses and testimonials your provide us when you participate in surveys, market studies or answering questions;
- Information that is used for participation in different contests, events and promotions we provide;
- 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 our ban decision, 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
- 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).
We receive most of your Personal Data directly from you. To the extent permitted by applicable law, we can also obtain your Personal Data from publicly available sources or from public authorities and other third parties (e.g., service partners, internet analysis services). Personal data we share with third parties is regulated by Article 8 of this Privacy Policy.
d. Age Verification
To comply with age-restriction laws that require age checks based on government-issued documents to ensure that no minor gains access to age-restricted services, every user in selected territories must complete an Age Verification process before using the PURE app and interacting with other users. The standard Age Verification route using facial-recognition technology is carried out through an automated step-by-step process provided by our third-party partner Veriff. See more in our Terms and Conditions (here).
After the Age Verification process, Veriff will provide PURE with a pass-or-fail result, accompanying it with basic data points that confirm and justify their decision on Age Verification. We do not receive the source images, face snap-shots, any kind of collected biometric data or biometric templates from Veriff. This data is collected, processed and stored on Veriff’s side. To see how your data is collected, processed and retained, please see Veriff’s Privacy Notice (here). Veriff retains the selfies, ID photographs submitted by you and other data captured and collected during Age Verification in its live environment for 90 days. Thereafter, all such data is transferred to Veriff’s secure archive and retained for up to three years, in accordance with Veriff’s Data Retention Policy. To enable the launch of the Age Verification process, we will only share with Veriff an internal unique identifier, which is assigned to each User on PURE.
If the automated procedure cannot be completed for any reason (for example, because 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 as the process is happening on PURE’s side and outcome is stored exclusively on PURE’s systems and collected data is processed according to this Privacy Policy. Collected personal 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.