Privacy Policy

Last updated: 2026-04-08

This privacy policy explains how personal data is processed when using Couple Clicks.

Couple Clicks is designed so that the core matching flow is synced directly between partner devices. No account is required. Core swipe and match results are not stored as server-side match profiles in our application database.

Controller

José Manuel Matas Villavicencio
Muffendorferstr. 32
53177 Bonn
Germany
Email: info@couple-clicks.com

Data categories

Technical connection data (e.g. IP address, timestamps, signaling and TURN metadata).
Security and abuse-prevention data (e.g. IP-based rate limit counters).
Aggregate usage counter (no per-user profile row in app database).
AI prompt content only when you explicitly use optional AI features.
Local browser data (e.g. session code, settings, and exported result snapshots in Local/Session Storage).

Purposes and legal bases (Art. 6 GDPR)

App delivery and device-to-device connection setup (Art. 6(1)(b) GDPR where required for the service, and Art. 6(1)(f) GDPR for our legitimate interest in secure and stable operation).
IT security, abuse prevention, and rate limiting (Art. 6(1)(f) GDPR).
Optional AI processing only when triggered by user action (Art. 6(1)(b) and/or Art. 6(1)(f) GDPR).

Processors and recipients

Hosting and infrastructure: Hetzner Online GmbH, server location Germany (EU).
Reverse proxy/TLS, peer signaling, and TURN infrastructure on own server setup.
External API for optional AI processing: NVIDIA model services (only when AI action is used).

International transfers

If optional AI processing involves providers outside the EU/EEA, data is transferred only under appropriate safeguards pursuant to Art. 44 et seq. GDPR (for example EU Standard Contractual Clauses).

Retention

Technical and security data is kept only as long as necessary for operation, troubleshooting, and abuse prevention.
Local browser data can be removed by the user at any time through browser data cleanup or app reset.

Your rights under GDPR

Access (Art. 15 GDPR)
Rectification (Art. 16 GDPR)
Erasure (Art. 17 GDPR)
Restriction (Art. 18 GDPR)
Data portability (Art. 20 GDPR)
Objection to processing based on Art. 6(1)(f) GDPR (Art. 21 GDPR)
Withdrawal of consent with future effect where consent was used (Art. 7(3) GDPR)

To exercise your rights, contact privacy@couple-clicks.com.

Supervisory authority

You have the right to lodge a complaint with a data protection supervisory authority. For North Rhine-Westphalia, Germany, this is in particular the State Commissioner for Data Protection and Freedom of Information NRW (LDI NRW): https://www.ldi.nrw.de.

Automated decision-making

We do not use automated decision-making, including profiling, under Art. 22 GDPR.