Privacy Policy

Privacy Policy of Evîn 

 

Last Updated: February 14, 2026

 

Welcome to Evîn, operated by Evîn App, a company registered in the European Union.

This Privacy Policy explains how we collect, use, share, and protect your personal data when you use our mobile application, website, and related services (collectively, the “App”).
By creating an account or using Evîn, you agree to this Privacy Policy.

 

1. Scope and Applicability

 

This Privacy Policy applies globally to all users of Evîn. It covers data collected through our App, website, or other platforms and complies with international data protection regulations, including
the EU General Data Protection Regulation (GDPR) and the California Consumer Privacy Act
(CCPA/CPRA).

 

2. Data We Collect

 

2.a Information You Provide

When creating and using your account, we collect:
• Full name, date of birth, gender, and sexual orientation
• Email address and/or phone number
• Profile photos, bio, preferences, and interests
• Messages, chat history, and shared media
• Payment details (for premium features)

 

2.b Automatically Collected Information
We automatically collect:
• Device identifiers, IP address, operating system, and app version
• Usage data (profiles viewed, features used, interactions)
• Location data (with your permission) to show nearby users
• Cookies and tracking technologies for analytics and personalization

 

2.c Information from Third Parties
We may receive limited information from:
• Social media or sign-in providers (Google, Apple, META)
• Advertising and analytics partners
• Payment processors

 

2.d Facial Biometric Data ⭐ NEW
What We Collect:
• A selfie photo captured during registration
• A 128-dimensional mathematical representation (face embedding) of your facial features

 

How We Collect It:
• Using your device’s camera during the registration process
• Face detection and analysis occur on your device using Apple’s Vision framework
• Processing happens entirely on your device (not on our servers)

 

Why We Collect It:
• To verify you’re a real person (anti-bot measure)
• To prevent fake accounts and scammers
• To improve platform safety and trust
• To maintain an authentic dating community

 

How We Process It:
• Face detection uses Apple’s Vision framework (built into iOS)
• Only the final photo and mathematical embedding are uploaded to our secure servers
• Embeddings are stored as encrypted binary data (512 bytes)
• We do not use facial recognition for tracking, advertising, or any other purpose
• Face verification is performed once during registration only

 

Your Rights:
• You can request deletion of your biometric data at any time
• Deleting your account will automatically delete all biometric data
• Data is retained only as long as your account is active

 

3. How We Use Your Data

 

We process your personal data to:
• Create and manage your Evîn account
• Match you with other users based on preferences and location
• Enable chat and communication features
• Personalize and improve the App experience
• Detect and prevent fraud, spam, and security breaches
• Send updates, offers, and notifications (with your consent)
• Comply with legal obligations and regulatory requirements

 

3.a Biometric Data Usage Limitations ⭐ NEW

We Use Biometric Data ONLY For:
✅ One-time verification during registration
✅ Preventing fake accounts and bots
✅ Platform safety and security

 

We DO NOT Use Biometric Data For:
❌ Tracking your activity across the app
❌ Advertising or marketing purposes
❌ Sharing with third parties
❌ Facial recognition or surveillance
❌ Re-verification on subsequent logins
❌ Matching or recommendations

 

3.b Third-Party Technologies ⭐ NEW

Apple Vision Framework: We use Apple’s Vision framework (built into iOS) to detect and analyze
faces during registration. This processing happens entirely on your device and does not send data
to Apple or any third party. The framework is privacy-focused and complies with Apple’s privacy
standards.

 

Firebase (Google Cloud): We use Firebase services for secure data storage and authentication.
All data is encrypted in transit and at rest. Firebase complies with GDPR and international data
protection standards.

 

3.c App Store Privacy Disclosures ⭐ NEW

As required by Apple’s App Store, we disclose:
Data Type: Face Data (biometric identifier)
Purpose: Fraud Prevention, Account Security, App Functionality
• Linked to You: Yes
• Used for Tracking: No
• Shared with Third Parties: No

 

4. Legal Bases for Processing (GDPR)

 

For users in the EU/EEA, we rely on the following legal bases:
Consent – for marketing, location sharing, cookies, and biometric data collection
Performance of a contract – providing the Evîn service
Legitimate interests – fraud prevention, safety, and analytics
Legal obligation – compliance with applicable laws

 

5. Sharing of Personal Data

 

We may share data only as necessary:
• With other users, according to your privacy settings
• With service providers (hosting, analytics, payment, support) under strict confidentiality
• With law enforcement or authorities where required by law
• During business transfers (e.g., merger, acquisition, restructuring)

For international data transfers, we implement EU Standard Contractual Clauses and equivalent
safeguards. We do not sell your personal data.

 

Biometric Data Sharing: We NEVER share your facial biometric data (photos or embeddings)
with third parties. This data is stored securely in Firebase (Google Cloud) with encryption and is
accessible only to you.

 

6. Location Data

 

Evîn uses your location (if you allow access) to display users near you. You can disable location
access at any time through your device settings. If disabled, certain features may not function
correctly.

 

7. Messages and Chat

 

Chats and messages between users are stored securely. To maintain a safe community, Evîn may automatically scan chats for violations of our Community Guidelines (e.g., spam, fraud, or illegal content). Private messages are not shared publicly.

 

8. Data Retention

 

We retain your personal data only as long as necessary:
• While your account remains active
• As required by law or to resolve disputes
• Some anonymized data may be retained for analytics

 

8.a Biometric Data Retention ⭐ NEW

Retention Period:
• Biometric data (selfie photos and face embeddings) are retained as long as your account is active
• Upon account deletion, biometric data is permanently deleted within 30 days
• Backups may persist for up to 90 days for disaster recovery purposes
• After 90 days, all biometric data is permanently and irreversibly deleted

 

How to Delete:
• Delete your account via app settings: Profile → Settings → Delete Account
• Contact us at info@evinapp.net to request deletion
• We will confirm deletion within 30 days

You may delete your account at any time via the App or by contacting us at info@evinapp.net.

 

9. Data Security

 

We use industry-standard security measures to protect your personal data, including:
• Encrypted data transmission (SSL/TLS)
• Secure storage and authentication
• Regular security audits and access controls

 

9.a Biometric Data Security ⭐ NEW

Storage:
• Selfie photos: Stored in Firebase Storage (Google Cloud, europe-west1 region) with encryption
• Face embeddings: Stored in Firebase Storage as encrypted binary files (512 bytes)
• Verification metadata: Stored in Firebase Realtime Database with access controls

 

Access:
• Only you can access your biometric data
• We cannot access or view your face embeddings
• Strict access controls prevent unauthorized access
• User-specific security rules enforce privacy

 

Encryption:
• All data encrypted in transit (HTTPS/TLS 1.3)
• All data encrypted at rest (AES-256, Firebase default encryption)
• Face embeddings are mathematical representations, not reversible to photos
• Multi-layer security architecture

While we strive to protect your data, no system is completely secure.

You share information at your own risk.

 

10. Your Rights (GDPR & CCPA)

 

Depending on your jurisdiction, you may have the right to:
• Access, correct, or delete your data
• Restrict or object to processing
• Withdraw consent at any time
• Receive a copy of your data (data portability)
• Opt out of “sale” or “sharing” of personal data (for California users)

 

Biometric Data Rights:
• Request access to your biometric data
• Request deletion of your biometric data at any time
• Withdraw consent for biometric data collection (will prevent account creation)
• Receive confirmation of deletion within 30 days

To exercise your rights, contact us at info@evinapp.net. We will respond to valid requests within applicable legal timeframes (30 days for GDPR, 45 days for CCPA).

 

11. Children’s Privacy

 

Evîn is strictly intended for users aged 18 years and older. We do not knowingly collect or process personal data from minors. If we learn that data from a minor has been collected, we will delete it immediately.

 

12. International Data Transfers

 

As a global platform, your information may be processed in countries outside your residence.

We ensure that appropriate data protection safeguards (such as EU Standard Contractual Clauses)
are implemented to protect your data wherever it is processed.

Biometric Data Location:
• Primary storage: Europe (europe-west1 region, Belgium)
• Backup storage: Europe (multi-region for redundancy)
• No biometric data is transferred outside the EU

 

13. Cookies and Tracking Technologies

 

Evîn uses cookies and similar technologies to:
• Authenticate users
• Remember preferences
• Analyze usage and improve performance
• Deliver relevant ads (where applicable)

You can control or delete cookies via your device or browser settings.

 

14. Changes to This Privacy Policy

 

We may update this Privacy Policy periodically to reflect changes in our App, legal requirements,
or technologies. The latest version will always be available in the App and on our website, with the
updated date at the top.

 

Material Changes: If we make material changes (e.g., new data collection practices), we will notify you via email or in-app notification at least 30 days before the changes take effect.

 

15. Contact Us

 

If you have any questions, concerns, or requests regarding this Privacy Policy, please contact us at:

📧 Email: info@evinapp.net
🌐 Website: www.evinapp.net
🩷 Company: Evîn App, Postbus 79055, 1070NC Amsterdam

 

Data Protection Officer: For GDPR-related inquiries, contact info@evinapp.net

 

16. Jurisdiction and Governing Law

 

This Privacy Policy shall be governed by and interpreted in accordance with the laws of the European Union, without regard to conflict of law principles. Users located in other jurisdictions
may be subject to local data protection laws in addition to this policy.

 

17. State-Specific Biometric Privacy Notices ⭐ NEW

 

For Illinois Users (Biometric Information Privacy Act – BIPA)

Notice and Consent: We collect facial biometric identifiers (face embeddings) as described in
Section 2.d of this policy. By creating an account, you provide written consent to this collection.

 

Retention and Destruction: Biometric data is retained for the duration of your account and
permanently deleted within 30 days of account deletion, as specified in Section 8.a.

 

Purpose: Biometric data is collected solely for fraud prevention and account verification, not for commercial purposes.

 

Your Rights:
• You may refuse to provide biometric data, but this will prevent account creation
• You may withdraw consent by deleting your account
• You may request deletion at any time

For Texas Users (Capture or Use of Biometric Identifier Act – CUBI)

 

Notice: We collect biometric identifiers (facial geometry) for security and fraud prevention purposes. This data is not sold or disclosed to third parties except as required by law.

 

Consent: By creating an account, you consent to the collection and use of biometric identifiers as
described in this policy. For Washington Users (Biometric Privacy Law)

 

Consent: Biometric data is collected with your express consent during the registration process.

 

Notice: We provide clear notice of the purpose, duration, and use of biometric data in this policy.

For California Users (CCPA/CPRA – Sensitive Personal Information)

 

Sensitive Personal Information: Facial biometric data is considered “sensitive personal
information” under California law.

 

Right to Limit Use: You have the right to limit our use of sensitive personal information to only what is necessary to provide the Evîn service. We already limit biometric data use to account verification only.

 

No Sale: We do not sell or share your biometric data with third parties for cross-context
behavioral advertising.

 

Retention: Biometric data is retained only as long as necessary for account verification and is deleted within 30 days of account deletion.

 

18. Compliance Certifications

 

GDPR Compliance:
• Legal basis for processing: Consent and legitimate interests

• Data Protection Impact Assessment (DPIA) completed for biometric processing

• EU Standard Contractual Clauses for international transfers
• Right to erasure (deletion) honored within 30 days

 

CCPA/CPRA Compliance:
• Biometric data classified as sensitive personal information
• No sale or sharing of biometric data
• Right to deletion honored within 45 days
• Opt-out mechanisms available

 

Apple App Store / Google Playstore Compliance:
• Privacy nutrition labels completed
• Face data usage disclosed
• On-device processing prioritized
• User consent obtained before collection

 

Firebase/Google Cloud Compliance:
• Data Processing Agreement (DPA) in place
• GDPR-compliant data processing
• EU data residency (europe-west1)
• Encryption at rest and in transit

 

19. Transparency Report

 

Biometric Verification Statistics (Updated Quarterly):

• Total users verified: [To be updated]
• Verification success rate: [To be updated]
• Fake accounts prevented: [To be updated]
• Data deletion requests processed: [To be updated]

We are committed to transparency and will publish quarterly reports on our biometric verification
system’s performance and privacy practices.

 

20. Frequently Asked Questions (FAQ)

 

Q: Why do you collect facial biometric data?

A: To verify you’re a real person and prevent fake accounts, bots, and scammers from joining our platform.

 

Q: Is my face data shared with anyone?

A: No. Your facial biometric data is never shared with third parties, advertisers, or other users.

 

Q: Can I use Evîn without providing biometric data?

A: No. Face verification is required during registration to maintain platform safety and authenticity.

 

Q: How is my biometric data stored?

A: Encrypted in Firebase Storage (Google Cloud, EU region) with strict access controls. Only you
can access your data.

 

Q: What happens to my biometric data if I delete my account?

A: It is permanently deleted within 30 days. Backups are removed within 90 days.

 

Q: Do you use my face for facial recognition across the app?

A: No. Face verification is used once during registration only. We do not track or recognize you
using facial recognition.

 

Q: Is face verification required on every login?

A: No. You verify once during registration. Subsequent logins use email and password only.

 

Q: What if I get a new phone?

A: You can log in on any device using your email and password. No face re-verification is required.

 

Q: How accurate is the face verification?

A: Our system has a ~95% acceptance rate for valid faces and effectively blocks fake accounts.

 

Q: Can I request a copy of my biometric data?

A: Yes. Contact info@evinapp.net to request a copy of your data under GDPR or CCPA rights.

 

21. Updates and Amendments

 

Version History:
v1.0 (November 25, 2025): Initial privacy policy
v2.0 (February 14, 2026): Added facial biometric data collection, Apple Vision framework
usage, Firebase details, state-specific notices, and enhanced security disclosures

 

Notification of Changes: Users will be notified of material changes via email and in-app notification at least 30 days before changes take effect.

 

22. Your Consent

 

By using Evîn, you acknowledge that you have read and understood this Privacy Policy and
consent to the collection, use, and processing of your personal data, including facial biometric
data, as described herein.

 

For Biometric Data: By creating an account, you provide explicit, informed consent for the
collection and processing of your facial biometric data for the purposes stated in this policy.

 

Withdrawal of Consent: You may withdraw consent at any time by deleting your account. This will result in the deletion of all your data, including biometric data, within 30 days.

Thank you for trusting Evîn with your data. We are committed to protecting your privacy and maintaining a safe, authentic dating community. 

 

🩷 Evîn Dating App 🩷 

Last Updated: February 14, 2026

Effective Date: February 14, 2026

Version: 2.0