SOU · PRIVACY POLICY · v2.1 — 14 JULY 2026

Privacy Policy

This Privacy Policy explains how the SOU application ("the App") processes personal data on behalf of its individual data controller Gökhan Camcı ("SOU", "we"). Data Controller contact: HELLO@SOUPRIVATE.COM · POSTAL · ISTANBUL

§ 1. Data We Process

• Identity verification data: your name and date of birth; an identity-document image processed transiently by the in-app verification service; three private verification selfies stored in server-only storage; and, where you separately consent, an optional encrypted face template. The identity-document image itself is not persisted by SOU.
• Contact data (e-mail address, phone number)
• Application answers, profile prompts (converted into an OpenAI embedding for matching similarity — subject to explicit consent)
• Photographs (Firebase Storage, owner-only; transmitted to Google Cloud Vision for a safety scan)
• Location: if you opt in, nearby presence is rounded to roughly 111 m, becomes ineligible for scans after five minutes, and is physically deleted by the next scheduled cleanup. A separate rounded matching-location record may be retained for up to 90 days. Exact coordinates are not shown to members. Automatic check-in is primarily evaluated on device; a venue search or selected coordinate may be sent to Nominatim.
• Membership and subscription status (RevenueCat ID)
• Chat messages (Firestore, restricted to current and former conversation participants; subject to OpenAI moderation and conversation health analysis for community safety)
• Behavioural metrics (response rate, no-show record, drop decisions)
• Voice intro recording (sent to OpenAI Whisper for transcription; the raw audio is deleted after 90 days)
• Categories inferred from your profile text and in-app preferences (values, interests, communication style) and a reliability indicator computed from your drop decisions — used only for matching
• Device identifiers (push token, error logging via Sentry)

§ 2. Legal Basis (GDPR Art. 6 / Art. 9)

Consent, performance of a contract, and the controller's legitimate interests. For special-category personal data (facial photograph, identity document) explicit consent is the sole lawful basis and is collected within the app via the AI Consent screen.

§ 3. International Transfers

The following third-party processors may be located in the United States or the EU; transfers are made on the basis of explicit consent and Standard Contractual Clauses (SCC):

• OpenAI (USA) — Transient identity-image and selfie analysis, profile/prompt embedding, message moderation and conversation-health analysis, editorial generation, and voice transcription; provider retention settings remain subject to production-account verification.
• Persona Inc. (USA, legacy/conditional) — Legacy KYC inquiry data only if the remaining integration is configured; it must be disclosed until decommissioning is proven.
• Google Cloud Vision (USA/EU) — Safety (NSFW) scan of uploaded photographs
• OpenStreetMap Nominatim (EU) — Venue-adding address lookup (coordinate→address)
• RevenueCat (USA) — Subscription mirror
• Google / Firebase / Google Cloud — Authentication, database, functions, storage, key management and image safety. The current technical configuration uses Firestore nam5 and Functions europe-west1; processing is therefore not EU-only.
• Resend or Postmark (configuration-dependent) — Transactional email
• Sentry (conditional on an EU-hosted project) — Minimized and scrubbed crash/performance diagnostics
• Apple App Store (USA/EU) — App Store + IAP

§ 4. Retention Periods

Data is retained for as long as membership is active. On account deletion a 30-day soft-delete period applies, after which permanent erasure follows. Certain data may be retained to meet legal obligations (financial records 5 years; security incident reports for the applicable statutory period).

§ 5. Your Rights (GDPR Art. 15–22)

• Right to know whether your personal data is being processed
• Right to know the purposes for which it is processed
• Right to rectification, erasure, and anonymisation
• Right to know which third parties have received your data
• Right to object to outcomes of automated decision-making (matchmaking algorithm)
• Right to compensation for damage

To exercise your rights: kvkk@souprivate.com. To lodge a complaint with the relevant supervisory authority (e.g. the ICO or your local DPA): ico.org.uk.

§ 6. Children

The App does not serve users under the age of 18. Age is checked through the current in-app identity-verification flow; applications identified as underage are rejected and deleted.

§ 7. AI and Automated Decision-Making

Match suggestions are partly automated: editorial text generation with OpenAI and (where explicit consent is given) converting your profile prompts into embeddings to compute a similarity score. In addition, your messages (OpenAI moderation + conversation health analysis), your photographs (Google Cloud Vision) and your voice intro (OpenAI Whisper) are processed automatically for safety and quality. HOUSE is a direct SOU introduction: an eligible pair may be selected by the system or by an authorised editor, and a conversation may open without mutual likes or user approval. You may object to an automated selection and request an explanation and human review. Consent-based AI processing can be declined or withdrawn in the App.

§ 8. Security Measures

• TLS 1.3 transport encryption
• Firebase Firestore at-rest AES-256 encryption
• Auth tokens stored in iOS Keychain / Android Keystore
• Sentry PII redaction
• Firebase Security Rules deny-by-default
• Legacy Persona webhook authentication and replay protection while that integration remains configured

§ 9. Updates

You will be notified in the app when this policy is updated. Current version: v2.1 · 14·07·2026.