Privacy Policy

1. Controller

Data controller: Maxim Marinin, sole trader (ατομική επιχείρηση), Fylis 274, 11253 Athens, Greece. Contact for privacy requests: info@lukingo.com (in English and Greek). Full details are in the Legal notice.

2. Special categories of data

Using Lukingo necessarily reveals information about your sex life and sexual orientation — for example who you are looking for, your orientation, your desire matrix, your ads, your messages and even the fact that you are a member. This is special-category data under Art. 9 GDPR.

We process it only on the basis of your explicit consent (Art. 9(2)(a) GDPR). You give it with a separate checkbox when you sign up, apart from accepting the Terms, and we record the date and the version of this policy. We cannot provide the service without this data, so this consent is needed to create an account.

Orientation and the desire matrix are optional. Who you are looking for is required, because matching does not work without it.

You can withdraw your consent at any time in Account → Privacy & data, or by deleting your account. Withdrawal deletes your desire matrix and orientation and archives your ads; it does not affect processing that happened before. To remove everything, including who you are looking for, delete your account.

3. What we collect

Account data: e-mail address, username, password (stored only as a hash), date of birth (to confirm you are 18+; other members see only your age), and records of the consents you gave (date and policy version).

Profile and ads: gender, who you are looking for, orientation and desire matrix (optional), location (country and city — never precise GPS), and the texts and photos you upload. Photos uploaded through our uploader are re-encoded, which removes embedded location data (EXIF/GPS).

Verification (optional): the selfie you send to get the “Verified” badge. A moderator compares it with your photos, and it is deleted after the decision. We do not use face recognition or any other biometric processing.

Messages between members. They are stored on encrypted disks of our database provider (encryption at rest). They are not end-to-end encrypted. Only the participants can see them in the app. When a message is reported, the reported message and the conversation context before it are copied into the report so that a moderator can review it; otherwise our staff do not read messages, except to comply with a legal obligation.

Profile and ad views and follows. When you view a profile or ad while not in incognito mode, we record the view together with your gender, age band, country and city. The owner sees only aggregated statistics — never names, and groups of fewer than five people are hidden. Your identity is removed from view records after 90 days and the records are deleted after 13 months.

Reports: if you report content, we keep the report (reason, explanation, link and, for messages, the copied conversation context). If you report without an account, we also keep the name and e-mail address you give us, if any.

Technical data: IP address (also used to determine your approximate country, for example to apply regional restrictions), device and browser data, and the cookies and local storage listed in section 9.

Payments are not available yet. When they are, card data will be processed by the payment provider; we will receive only a transaction reference, the plan and its status — never full card numbers.

4. Purposes and legal bases

Providing the service — account, profile, ads, matching, messages and view statistics: performance of our contract with you (Art. 6(1)(b) GDPR) and, for special-category data, your explicit consent (Art. 9(2)(a)).

Safety and moderation — handling reports and preventing fraud, abuse, commercial sex and use by minors: our legitimate interest and that of other members in a safe service (Art. 6(1)(f)) and our legal obligations, including under the Digital Services Act (Art. 6(1)(c)).

Billing and tax, once payments exist: legal obligation (Art. 6(1)(c)).

The keyword filter can refuse a text automatically. This is not a decision with legal or similarly significant effects on you, and you can always ask for a human review (see Terms, section 6).

5. Discretion

When payments are introduced, bank statements will show a neutral merchant descriptor. Incognito mode hides your profile from people you haven’t contacted, and your visits are not recorded in other members’ statistics. Private photos are visible only to you and our moderators. The “Hide” button (or pressing Esc twice) leaves the site instantly. We never sell personal data and do not use it for advertising.

6. Retention

Your data is kept while your account exists. When you delete your account, your profile, photos, ads, desire matrix, consent records and the conversations you took part in (for both participants) are deleted immediately. Residual copies in our provider’s encrypted backups disappear within 7 days.

Some data is deleted sooner: archived and rejected ads 90 days after they were archived or rejected; notifications after 12 months; verification selfies right after the moderator’s decision. In profile and ad view records your identity is removed after 90 days, and the records are deleted after 13 months.

We keep some records longer because the law or safety requires it, without your identity once your account is deleted: moderation decisions; reports, deleted 3 years after they were handled, except reports about minors, trafficking and non-consensual content, which we keep as long as authorities may need them; and, once payments exist, payment and tax records for the period required by Greek tax law.

7. Your rights

You have the right to access, rectify and erase your data, to data portability, to restrict or object to processing, and to withdraw your consent at any time.

You can do most of this yourself: “Download my data (JSON)” and “Delete my account” in your account, Account → Privacy & data to withdraw consent, and your profile settings to change or delete fields. For anything else write to info@lukingo.com; we answer within one month.

You can also lodge a complaint with a data protection authority — in Greece the Hellenic Data Protection Authority (www.dpa.gr), or the authority of the country where you live or work.

8. Processors and transfers

Supabase Inc. (USA) — database, authentication and file storage, hosted in the EU (Ireland, AWS eu-west-1).

Vercel Inc. (USA) — website hosting; server functions run in the EU (Dublin), and its global edge network may route requests through other regions.

Account e-mails are sent by our e-mail delivery provider (currently Supabase’s built-in mailer; Resend, Inc. (USA), using its EU sending region, once enabled).

Chat translation: when you tap “Translate”, the message is translated on your device if your browser can do it (Chrome, Edge). Otherwise, once this is enabled, only the message text — without your name or profile — is sent to Google LLC (USA, Gemini API, paid service; Google does not use it to train its models); the translation is stored with the message and deleted together with it.

These US providers are bound by data processing agreements with the EU Standard Contractual Clauses and/or certification under the EU–US Data Privacy Framework. Payment providers will be added here before payments launch.

We disclose data to authorities only where the law requires it — for example on a valid order, or when we must report a suspected criminal offence that threatens someone’s life or safety (Art. 18 DSA). Other members see only what you publish in your profile and ads.

9. Cookies and local storage

We use only cookies and storage that are strictly necessary or that remember choices you made yourself: age_ok — your 18+ confirmation (1 year); sb-… — your login session, set only when you log in; NEXT_LOCALE — your language (1 year); geo — the location you chose (180 days); tz — your time zone, so that times are shown correctly; nocta_theme — your light or dark theme, kept in your browser’s local storage.

We do not use analytics, advertising or tracking cookies, so no consent banner is needed. If this ever changes, we will ask for your consent first.