Privacy Policy

PRIVACY POLICY

AI² Dating Platform — International Jurisdiction (GDPR)

Last updated: March 25, 2026

This Privacy Policy (hereinafter referred to as the "Policy") describes the procedures for the collection, processing, storage, transfer, and protection of personal data and other information of users of the AI² Dating service (hereinafter referred to as the "Service", "Platform"), accessible on the Internet at the following addresses: ai2.dating, ai2.date (hereinafter referred to as the "Website"), as well as in the form of a mobile application (hereinafter referred to as the "Application").

This Policy has been prepared in accordance with Regulation (EU) 2016/679 (General Data Protection Regulation — GDPR), Directive 2002/58/EC (ePrivacy Directive), and Regulation (EU) 2024/1689 (EU AI Act) with respect to transparency requirements for artificial intelligence systems.

By using the Service, You confirm that You have read this Policy and agree to its terms. If You do not agree with any provisions of the Policy, You should discontinue use of the Service.

1. Scope of This Policy

1.1. This Policy governs the relationship between the data controller (hereinafter referred to as the "Controller", "We") and an individual (hereinafter referred to as the "User", "You", "Data Subject") using the AI² Dating Service, with respect to the collection, processing, storage, and protection of personal data in accordance with Articles 13 and 14 of the GDPR.

1.2. The Policy applies to all personal data that the Controller may obtain about the User during use of the Service, including:

• personal data provided by the User during registration and profile completion;

• data collected automatically during use of the Service (cookies, IP address, device data);

• data provided by the User when completing psychological tests, questionnaires, and surveys;

• biometric personal data obtained during identity verification;

• data related to payment transactions and the internal AI² Token wallet;

• data processed using artificial intelligence technologies;

• special categories of personal data (Article 9 GDPR) voluntarily provided by the User.

1.3. The Policy applies to the Controller's domains: ai2.dating, ai2.date, as well as corresponding mobile applications.

1.4. This Policy does not apply to third-party resources that may be linked from the Service. The Controller bears no responsibility for the actions of third parties who gain access to User data as a result of the User's use of third-party resources.

2. Who Processes the Information

2.1. Data Controller

Private Company "New Reality"

• BIN: 220440900016

• Registered address: Republic of Kazakhstan, Astana, Zhenis Avenue, building 1, office 29

• Email: support@ai2.dating, support@ai2dating.kz

• Phone: +7 (747) 029-43-05

• Website: https://ai2.dating

2.2. Data Protection Officer (DPO)

In accordance with Articles 37–39 of the GDPR, the Controller has appointed a Data Protection Officer. For all matters related to the processing and protection of personal data, You may contact the DPO:

• Email: gdpr@ai2.dating

• Postal address: Republic of Kazakhstan, Astana, Zhenis Avenue, building 1, office 29 — marked "Data Protection Officer"

The DPO ensures compliance with GDPR requirements, handles data subject requests, and liaises with supervisory authorities.

2.3. Applicable Law

Personal data processing is carried out in accordance with:

• Regulation (EU) 2016/679 (General Data Protection Regulation — GDPR);

• Directive 2002/58/EC (ePrivacy Directive) — with respect to cookies and electronic communications;

• Regulation (EU) 2024/1689 (EU AI Act) — with respect to transparency and accountability of artificial intelligence systems;

• applicable national legislation of EU/EEA Member States in which Users reside.

3. Purpose of the Policy

3.1. The purpose of this Policy is to ensure adequate protection of Users' personal data against unauthorized access and disclosure, as well as to fulfill the Controller's information obligations in accordance with Articles 13 and 14 of the GDPR.

3.2. The Policy defines:

• the list of personal data subject to processing;

• purposes and legal bases for processing (Articles 6 and 9 GDPR);

• measures to ensure the security of personal data;

• data subject rights (Articles 15–22 GDPR);

• procedures for handling data subject requests;

• procedures for transferring data to third parties and international transfers;

• retention periods and procedures for the destruction of personal data;

• information about cookies and consent for their use;

• information about the use of artificial intelligence technologies.

3.3. The Controller undertakes not to process personal data in a manner incompatible with the purposes for which it was collected, nor to process data that is excessive in relation to the stated purposes (principle of data minimization, Article 5(1)(c) GDPR).

3.4. The Policy is intended to ensure transparency in the processing of personal data (Article 5(1)(a) GDPR), enabling the User to make informed decisions about using the Service and providing their data.

4. What Information We Collect

4.1. Data Provided During Registration

When creating an account in the Service, the User provides the following data:

• Name (display name in the Service);

• Email address (used for authorization and communication);

• Phone number (if available, for additional verification);

• Date of birth (for age verification — must be at least 18 years old);

• Gender (male / female / other);

• City of residence (for matching by geographic proximity);

• Password (stored in hashed form using the bcrypt algorithm).

When authorizing through third-party services (OAuth), the following additional data may be obtained:

• Google OAuth: name, email, profile photo, Google identifier;

• Telegram OAuth: name, username, Telegram identifier, photo (if available).

4.2. Questionnaire Data

The Service provides a multi-level questionnaire system distributed across 4 levels:

• Level L1 — completed during registration: life values, relationship goals, habits, personality traits, partner preferences, interests;

• Level L2 — extended questionnaire, unlocked after the User begins actively using the Service: attachment style, attitudes toward finances, daily rhythm, emotional intelligence;

• Level L2.5 — intimate compatibility questionnaire, completed at the User's discretion: preferences, boundaries, and expectations in the intimate sphere of relationships;

• Level L2.5+ — dual consent module, unlocked upon mutual consent of both partners: detailed intimate compatibility, including consistency check questions.

Legal basis: Responses to Level L2.5 and L2.5+ questions constitute special categories of personal data (data concerning sexual life and orientation, Article 9 GDPR) and are processed exclusively on the basis of explicit consent of the data subject (Article 9(2)(a) GDPR). See Section 11.

4.3. Psychological Testing

The Service provides the following psychological instruments:

MBTI Typing:

• 64 main questions + 4 tiebreakers;

• 4-point Likert scale;

• Result: personality type (16 types), cognitive functions, expression score (-100..+100).

Fisher Test:

• questions for each of 4 temperament types;

• Likert scale 1-5;

• Result: dominant temperament type, "golden pair" compatibility.

Additional Surveys (more than 40):

• Thematic psychological questionnaires;

• Aimed at refining the compatibility profile;

• Include questions about communication style, life priorities, habits, and relationship expectations.

4.4. Photographs and Visual Content

• Profile photos — images uploaded by the User for display in the profile;

• Album photos — additional photos that the User may add to thematic albums;

• Verification selfie — a facial photograph taken in real time to confirm identity;

• EXIF metadata — technical data extracted from uploaded photos (camera model, date taken, geolocation if available), used to assess photo authenticity (photo_exif_score).

4.5. Biometric Personal Data

As part of identity verification (Face Verification), the Service processes the following biometric data:

• Facial biometric template — a mathematical representation (embedding) of the User's face obtained using the ArcFace neural network;

• Face detection data — coordinates of facial key points determined by the RetinaFace neural network;

• Liveness detection data — results of the Pose Challenge (turning the head in a randomly specified direction), confirming that a live person is in front of the camera;

• Comparison result — a numerical similarity score (cosine similarity) between the verification selfie and profile photos.

Biometric processing is carried out on the basis of explicit consent of the data subject (Article 9(2)(a) GDPR). Biometric data constitutes a special category of personal data (Article 9(1) GDPR). The Controller has conducted a Data Protection Impact Assessment (DPIA) in accordance with Article 35 GDPR for this type of processing. The number of verification attempts is limited to no more than 5 per day.

4.6. Correspondence and Communications

• Chat messages — textual content of messages exchanged between Users within the Service (delivered in real time via SSE — Server-Sent Events technology);

• Typing indicators — technical data indicating that a message is being composed;

• Correspondence metadata — date and time of message sending/reading, participant identifiers;

• AI Care messages — automatically generated AI messages sent to the User based on analysis of their behavior within the Service (proactive support system).

4.7. AI Advisor Data

When using the AI Advisor, the following data is processed:

• AI chat history — text messages sent by the User to the AI Advisor and system responses;

• Analytical report requests (Action Cards) — type of analysis requested, input data (User profile, compatibility scores, test results);

• Generated reports — personalized analytical reports prepared by AI based on User data;

• Usage metadata — frequency of requests, types of queries, processing time.

AI Advisor data processing is carried out using the Mars LLM Service (an internal microservice based on large language models). Data is transmitted in pseudonymized form (Article 4(5) GDPR). For more information on AI transparency, see Section 13.

4.8. Compatibility Scores and Analytics

• Scores across 12 compatibility dimensions: values (VAL, 19%), attachment (ATT, 15%), conflict resolution (CNF, 10%), love languages (LOV, 8%), interests (INT, 10%), finances (FIN, 7%), daily rhythm (DAY, 5%), emotional intelligence (EQ, 7%), psychology (PSY, 7%), physical compatibility (FIS, 7%), intellectual compatibility (INT+, 3%), behavior (BHV, 4%);

• Aggregate compatibility score — a weighted assessment of the couple's compatibility;

• Compatibility matrices: Attachment 4×4, Love Languages 5×5, MBTI 16×16, Fisher 4×4;

• Filtering results — data on the application of strict compatibility filters (e.g., VAL threshold < 40 or incompatible relationship goals).

4.9. Platform Safety Assessment Data

The Service automatically calculates hidden safety scores to protect the User community:

• safety_score — profile safety assessment;

• consistency_score — response consistency assessment (analysis of 8 pairs of contradictory L1 questions);

• reputation_risk — reputational risk assessment;

• Markers and patterns — automatically detected behavioral patterns.

These scores are stored in a de-identified JSON format and are never displayed to the User. They are used exclusively to ensure platform safety and protect other Users on the basis of the Controller's legitimate interest (Article 6(1)(f) GDPR).

4.10. Payment Data and AI² Token

• Internal wallet data — balance in AI² tokens, transaction history (deposits, debits, transfers);

• Subscription data — subscription type (Free / Plus / Premium / VIP), start and end dates, plan change history;

• Payment transactions — transaction identifiers, amounts, payment statuses;

• Digital activation codes — card and flyer codes activated by the User to top up the AI² Token wallet.

Important: The Controller does not store Users' bank card data. Payment processing is carried out exclusively through certified payment gateways compliant with the PCI DSS standard.

4.11. Technical Data

The following data is automatically collected during use of the Service:

• IP address of the User;

• User-Agent — information about the browser and operating system;

• Cookie data — session identifiers, interface settings, language preferences (see Section 10 regarding cookie consent);

• Web Push data — push notification subscription (endpoint, encryption keys p256dh and auth), using the VAPID protocol;

• Analytics data — information collected by Google Analytics systems (page views, user actions, demographic data) — only with consent;

• Access logs — dates and times of access to the Service, requested URLs, server response codes.

5. Legal Bases and Purposes of Processing

5.1. Legal Bases for Processing (Articles 6 and 9 GDPR)

The Controller processes personal data on the following legal bases:

a) Performance of a contract (Article 6(1)(b) GDPR):

• account registration;

• provision of core Service functions (partner matching, chat, compatibility scores);

• payment processing and management of the internal AI² Token wallet;

• fulfillment of subscription obligations;

• processing of L1 and L2 questionnaire data;

• processing of psychological test results.

b) Consent of the data subject (Article 6(1)(a) GDPR):

• sending push notifications;

• data processing by the AI Advisor;

• use of analytical cookies (Google Analytics);

• processing of photo EXIF metadata.

c) Explicit consent for processing special categories of data (Article 9(2)(a) GDPR):

• processing of data concerning intimate life and sexual preferences (L2.5 and L2.5+ questionnaire levels);

• processing of biometric data for unambiguous identification (face verification).

d) Legitimate interest of the Controller (Article 6(1)(f) GDPR):

• ensuring Service security (calculation of safety_score, consistency_score);

• prevention of fraud and abuse;

• improvement of Service quality and user experience;

• analysis of aggregated de-identified data for algorithm development.

The Controller has conducted a Legitimate Interest Assessment for each case of processing based on legitimate interest, establishing that the interests, rights, and freedoms of data subjects do not override the legitimate interests of the Controller. You may request the results of this assessment by contacting the DPO (gdpr@ai2.dating).

e) Legal obligation (Article 6(1)(c) GDPR):

• age verification (must be at least 18 years old);

• storage of transaction data in accordance with tax and financial legislation requirements;

• responding to lawful requests from competent authorities.

5.2. Purposes of Personal Data Processing

The Controller processes personal data for the following purposes:

• Registration and identification — account creation, authorization, identity verification;

• Compatible partner matching — calculation of compatibility scores across 12 dimensions, generation of recommendations;

• Psychological profiling — determination of personality type (MBTI), temperament type (Fisher), attachment style, love languages;

• Facilitating communication — providing chat between Users, sending notifications;

• AI analytics — generation of personalized reports and recommendations using the AI Advisor;

• Identity verification — confirmation of photo authenticity and correspondence to the User's actual appearance;

• Payment processing — accepting payments, managing the AI² Token wallet, activating digital codes;

• Ensuring safety — detection and prevention of fraud, fake accounts, and violations of Service rules;

• Service improvement — analysis of de-identified statistical data to enhance compatibility algorithms and user interface;

• Proactive support (AI Care) — automatic generation of personalized support messages based on the User's behavioral patterns.

5.3. Principle of Data Minimization (Article 5(1)(c) GDPR)

The Controller collects only the data necessary to achieve the stated processing purposes. Completing extended questionnaire levels (L2, L2.5, L2.5+), taking psychological tests, and face verification are voluntary and are not a mandatory condition for using the basic functions of the Service.

6. How We Protect Information

6.1. Organizational Measures

The Controller implements the following organizational measures to protect personal data:

• appointment of a Data Protection Officer (DPO) in accordance with Article 37 GDPR;

• development and approval of internal policies on data processing and protection;

• restriction of personnel with access to personal data and segregation of access rights (principle of least privilege);

• regular training of employees on GDPR requirements and internal security policies;

• conducting Data Protection Impact Assessments (DPIA, Article 35 GDPR) for high-risk processing activities;

• maintaining a Record of Processing Activities (Article 30 GDPR);

• regular internal audits of personal data processing compliance with GDPR requirements.

6.2. Technical Measures

Data Encryption:

• AES-256 (Advanced Encryption Standard) — encryption of special categories of personal data (L2.5+ level responses are stored in the consent_answers table in encrypted form);

• HTTPS/TLS 1.2+ — all data is transmitted over a secure channel;

• bcrypt — hashing of user passwords;

• HMAC-SHA256 — signing of inter-service requests (Mars LLM Service, payment gateway);

• RFC 8291 — push notification encryption (ECDH + HKDF + AES-128-GCM).

Server Security:

• firewall implementation;

• use of intrusion detection and prevention systems;

• regular software updates and vulnerability patching;

• maintaining access logs for information systems;

• encrypted data backups;

• Data Protection by Design and by Default (Article 25 GDPR).

Authorization Protection:

• JWT tokens (JSON Web Token) with limited validity period;

• authorization verification on every request via middleware;

• rate limiting of authorization attempts;

• limiting face verification attempts (no more than 5 per day);

• stateless tokens for Pose Challenge (HMAC-SHA256).

Biometric Data Protection:

• biometric templates (embeddings) are stored in a separate security perimeter;

• biometric processing is performed locally (DeepFace microservice), without transmitting data to third parties;

• access to the verification service is restricted to the internal network;

• a DPIA (Article 35 GDPR) has been conducted for this type of processing.

6.3. Payment Data Protection

The Controller does not store payment card data. Payment processing is carried out through certified payment gateways compliant with the PCI DSS Level 1 standard. Data exchange with the payment gateway is protected by an HMAC key and conducted over an encrypted HTTPS channel.

6.4. Incident Response (Articles 33–34 GDPR)

In the event of a personal data breach or other information security incident, the Controller undertakes to:

• immediately take measures to mitigate the consequences of the incident;

• notify the supervisory authority within 72 hours of becoming aware of the breach (Article 33 GDPR);

• notify the affected data subjects without undue delay if the breach is likely to result in a high risk to their rights and freedoms (Article 34 GDPR);

• document all incidents, including circumstances, consequences, and corrective measures taken;

• conduct an internal investigation and take measures to prevent recurrence.

7. To Whom Information Is Disclosed

7.1. General Principles

The Controller does not sell, rent, or transfer personal data to third parties for commercial purposes. Data is disclosed only in the cases described in this section and to the minimum extent necessary to achieve the relevant purposes. All data recipients (processors, Article 28 GDPR) are bound by appropriate Data Processing Agreements.

7.2. Payment Gateways

When the User makes payments through the Service interface, data is transmitted to the payment gateway to process the transaction. Data transmitted includes:

• transaction identifier;

• payment amount and currency;

• payment description (subscription type or wallet top-up);

• User's email (for receipt delivery).

Payment gateways process bank card data independently in accordance with their own privacy policies and PCI DSS standards.

7.3. Face Verification Service (DeepFace)

Face verification is performed by a local microservice (Python FastAPI) running on the Controller's own server. Biometric data is not transmitted to external providers. The microservice uses open-source neural network models ArcFace and RetinaFace, deployed locally.

7.4. Mars LLM Service (AI Advisor)

Processing of AI Advisor requests is carried out through the internal Mars microservice, hosted on the Controller's infrastructure. Data is transmitted to Mars in pseudonymized form (without direct User identifiers such as name, email, or phone number).

Mars uses language models to generate responses:

• Claude Haiku — for chat consultations (model by Anthropic);

• Claude Sonnet — for analytical reports (model by Anthropic).

Requests to language models contain de-identified profile data and compatibility scores. Anthropic does not use API request data to train its models. Processing through the Anthropic API constitutes an international data transfer (see Section 9).

7.5. Push Notification Services

Browser push provider servers are used for push notification delivery (Google FCM for Chrome, Mozilla Push Service for Firefox, Apple Push Notification Service for Safari). Only encrypted notification payloads are transmitted; push providers are unable to decrypt message content (end-to-end encryption per RFC 8291 protocol).

7.6. Web Analytics Systems

• Google Analytics (Google LLC) — collection of de-identified data on website traffic, user behavior, and traffic sources. Data is transmitted to Google servers and processed in accordance with Google's privacy policy. Activated only after obtaining User consent (in accordance with the ePrivacy Directive).

The User may opt out of data collection by analytics systems by withdrawing cookie consent (see Section 10).

7.7. OAuth Providers

When authorizing through Google or Telegram, the respective providers receive information about the User's authorization in the Service. The scope of data obtained from OAuth providers is determined by their own privacy policies and requested permissions (scopes).

7.8. Other Service Users

Other Service Users may see the following information about You, depending on privacy settings and subscription level:

• display name;

• profile and album photos;

• age, city;

• profile information (L1 questionnaire responses — partial);

• compatibility score (when mutual interest exists);

• psychological type (MBTI, Fisher — if available);

• face verification status.

Not displayed to other Users: email, phone number, intimate questionnaire data (L2.5/L2.5+), payment information, safety scores.

7.9. Disclosure Required by Law

The Controller may disclose personal data in response to a lawful request from competent government authorities in the manner established by applicable law, provided there is a proper legal basis. The Controller will notify the data subject of such a request unless prohibited by law.

8. Retention Period

8.1. General Rules (Article 5(1)(e) GDPR)

Personal data is retained no longer than necessary for the purposes of processing (principle of storage limitation). Upon expiration of the retention period, data is deleted or anonymized.

8.2. Retention Periods by Data Category

| Data Category | Retention Period | Legal Basis |

|---|---|---|

| Account data (profile) | Entire period of Service use + 30 days after account deletion | Performance of contract, Art. 6(1)(b) |

| Questionnaire responses (L1, L2) | Entire period of Service use | Performance of contract, Art. 6(1)(b) |

| Intimate questionnaire responses (L2.5, L2.5+) | Until consent is withdrawn or account is deleted | Explicit consent, Art. 9(2)(a) |

| Psychological test results | Entire period of Service use | Performance of contract, Art. 6(1)(b) |

| Profile photos | Entire period of Service use + 30 days | Performance of contract, Art. 6(1)(b) |

| Biometric data (verification) | 1 year from the date of verification or until consent is withdrawn | Explicit consent, Art. 9(2)(a) |

| Chat correspondence | 3 years from the date of creation or until account deletion | Performance of contract, Art. 6(1)(b) |

| AI Advisor data | 1 year from the date of report generation | Consent, Art. 6(1)(a) |

| Payment transactions | 5 years from the date of the transaction | Legal obligation, Art. 6(1)(c) |

| Cookies and analytics data | Up to 2 years from the last visit | Consent, Art. 6(1)(a) |

| Push subscription data | Until unsubscription or account deletion | Consent, Art. 6(1)(a) |

| Safety scores (platform_assessment) | Entire period of Service use | Legitimate interest, Art. 6(1)(f) |

| Access logs | 6 months | Legitimate interest, Art. 6(1)(f) |

8.3. Data Destruction

Upon expiration of the retention period or upon achievement of the processing purposes, personal data is destroyed within 30 days. Destruction is carried out by:

• deleting records from the database;

• deleting files (photos, documents) from servers;

• overwriting encrypted data;

• recording the fact of destruction in a log.

8.4. Account Deletion

When a User deletes their account:

• profile data, photos, and content are deleted within 30 days;

• encrypted intimate questionnaire data is deleted immediately;

• biometric templates are deleted immediately;

• payment transactions are de-identified but retained for 5 years in accordance with tax legislation requirements;

• de-identified (anonymized) statistical data may be retained indefinitely, as it does not constitute personal data within the meaning of the GDPR.

9. International Data Transfers

9.1. General Principles (Chapter V GDPR, Articles 44–49)

The Controller may transfer personal data to countries outside the European Economic Area (EEA) only where adequate safeguards as provided for by the GDPR are in place.

9.2. Transfers Outside the EEA

The following processing operations may involve data transfers outside the EEA:

a) Anthropic API (Mars LLM Service):

• Data category: pseudonymized profile data and compatibility scores;

• Destination country: United States;

• Safeguards: Standard Contractual Clauses (SCC) approved by Commission Implementing Decision (EU) 2021/914; Anthropic does not use API request data for model training;

• Minimization: only de-identified/pseudonymized data is transmitted.

b) Google Analytics:

• Data category: de-identified analytics data (IP address anonymized);

• Destination country: USA/EU (Google offers storage in the EU region);

• Safeguards: Standard Contractual Clauses (SCC); EU-U.S. Data Privacy Framework.

c) Push providers (Google FCM, Mozilla, Apple):

• Data category: encrypted notification payloads;

• Safeguards: end-to-end encryption (RFC 8291), providers do not have access to the content.

9.3. Your Rights Regarding International Transfers

You have the right to obtain a copy of the appropriate safeguards applied to international data transfers by contacting the DPO at gdpr@ai2.dating.

10. Cookies and Consent (ePrivacy)

10.1. What Are Cookies

Cookies are small text files that are stored on Your device when You visit the Service. They allow the Service to remember information about You and Your preferences.

10.2. Types of Cookies Used

a) Strictly necessary cookies (do not require consent):

• session identifier (JWT token);

• interface language settings;

• cookie consent state.

These cookies are necessary for the functioning of the Service and are set on the basis of legitimate interest (Article 6(1)(f) GDPR) and the exemption from the consent requirement under Article 5(3) of the ePrivacy Directive.

b) Functional cookies (require consent):

• display preferences (theme, font size);

• push notification subscription data;

• PWA installation state.

c) Analytical cookies (require consent):

• Google Analytics — tracking of website traffic, user behavior, and traffic sources, including demographic, interest, and behavioral data (in de-identified form).

Analytical cookies are set only after obtaining the User's explicit consent through a cookie banner in accordance with the ePrivacy Directive.

10.3. Managing Cookies

You can manage cookies in the following ways:

• Via the cookie consent banner — upon Your first visit to the Service, You are offered a choice of cookie categories to which You give consent;

• In browser settings — configuring blocking, deletion, or warnings about cookies;

• For Google Analytics — via the Google Analytics Opt-out Add-on (https://tools.google.com/dlpage/gaoptout);

• Withdrawing consent — You may withdraw previously given cookie consent at any time through the Service settings or by clearing cookies in Your browser.

Please note: disabling strictly necessary cookies may result in the inability to use the Service.

10.4. Local Storage

In addition to cookies, the Service uses browser Local Storage technology to store:

• authorization token (JWT);

• cached profile data;

• interface settings;

• Service Worker data (for PWA functionality).

Local Storage data is not automatically transmitted to the server with each request (unlike cookies) and is used exclusively on the browser side.

11. Processing of Special Categories of Personal Data (Article 9 GDPR)

11.1. General Provisions

In accordance with Article 9(1) GDPR, the processing of special categories of personal data, including data concerning sexual life and sexual orientation, as well as biometric data for the purposes of unambiguous identification, is prohibited except in the cases provided for in Article 9(2) GDPR.

The AI² Dating Service processes the following special categories:

11.2. Data Concerning Sexual Life and Preferences

Data composition:

• Level L2.5 questionnaire responses (about intimate preferences, boundaries, and expectations);

• Level L2.5+ questionnaire responses (in the dual consent module, including consistency check questions: questions #30↔#19, #31↔#2, #32↔#20);

• intimate compatibility calculation results (FIS dimension).

Legal basis: processing is carried out exclusively on the basis of explicit consent of the data subject (Article 9(2)(a) GDPR). Consent is requested separately for each questionnaire level and contains a clear indication of the nature of the data being processed. Consent may be withdrawn at any time without affecting the lawfulness of processing carried out prior to withdrawal (Article 7(3) GDPR).

Protective measures:

• data is stored in encrypted form (AES-256 algorithm) in a separate database table (consent_answers);

• the encryption key is stored separately from the encrypted data;

• decryption is performed only when the data is directly used for compatibility calculation;

• access to Level L2.5+ is granted only upon mutual consent of both partners;

• intimate compatibility data is not displayed in the User's profile to other Users.

Processing conditions:

• completion of the L2.5 and L2.5+ questionnaires is entirely voluntary;

• the User may withdraw consent and request data deletion at any time, while their account and other data are preserved;

• upon withdrawal of consent, encrypted data is deleted immediately.

11.3. Biometric Personal Data

Data composition:

• facial biometric template (embedding) — a mathematical vector obtained by the ArcFace neural network;

• facial key point coordinates (landmarks) — determined by the RetinaFace neural network;

• liveness detection results — Pose Challenge data.

Legal basis: processing is carried out on the basis of explicit consent of the data subject (Article 9(2)(a) GDPR). The Controller has conducted a Data Protection Impact Assessment (DPIA) in accordance with Article 35 GDPR.

Processing purposes:

• confirming that profile photos correspond to the User's actual appearance;

• protecting the community from fake accounts and fraud;

• enhancing trust between Users.

Protective measures:

• processing is performed locally on the Controller's servers (DeepFace microservice, without transmission to third parties);

• the number of verification attempts is limited to 5 per day;

• biometric templates are stored in a separate protected perimeter;

• retention period — 1 year from the date of verification or until consent is withdrawn (whichever occurs first).

Processing conditions:

• face verification is entirely voluntary;

• refusal to undergo verification does not restrict access to the core functions of the Service (but may reduce other Users' trust in the profile);

• the User may withdraw consent for biometric data processing by contacting the DPO at gdpr@ai2.dating.

11.4. Photo EXIF Metadata

When photos are uploaded, the Service automatically extracts and analyzes EXIF metadata (camera model, date taken, GPS coordinates if available, software). The data is used for:

• assessing photo authenticity (photo_exif_score);

• detecting signs of image manipulation;

• calculating the safety score (safety_score).

GPS coordinates from EXIF metadata are not used for User geolocation and are not displayed to other Users. Extracted data is stored in a de-identified numerical format.

12. Your Rights (Articles 15–22 GDPR)

As a data subject, You have the following rights under the GDPR. To exercise any of the rights listed below, contact the DPO at gdpr@ai2.dating or at the postal address specified in Section 2.2. The Controller undertakes to respond to Your request within one month (Article 12(3) GDPR), with the possibility of an extension of up to two additional months where necessary.

12.1. Right of Access (Article 15 GDPR)

You have the right to obtain confirmation from the Controller as to whether Your personal data is being processed, as well as the following information:

• purposes of processing;

• categories of data being processed;

• recipients or categories of recipients of the data;

• envisaged retention periods;

• information about Your rights (rectification, erasure, restriction, objection);

• information about the sources of data (if not obtained from You);

• information about automated decision-making, including profiling (Article 22 GDPR);

• information about international transfers and safeguards (Article 46 GDPR).

You have the right to obtain a copy of the personal data being processed free of charge. A reasonable fee may be charged for additional copies.

12.2. Right to Rectification (Article 16 GDPR)

You have the right to request the immediate rectification of inaccurate personal data, as well as the completion of incomplete data. Most data can be corrected by You directly through the Service interface (profile editing, retaking tests).

12.3. Right to Erasure / "Right to Be Forgotten" (Article 17 GDPR)

You have the right to request the erasure of Your personal data where:

• the data is no longer necessary for the purposes for which it was collected;

• You withdraw consent and there is no other legal basis for processing;

• You object to processing and there are no overriding legitimate grounds for continued processing;

• the data has been unlawfully processed;

• erasure is required for compliance with a legal obligation.

You may delete Your account through the Service settings or by submitting a request to gdpr@ai2.dating.

Exceptions: The Controller may refuse to erase data that is necessary for compliance with a legal obligation, for the establishment, exercise, or defense of legal claims, and in other cases provided for in Article 17(3) GDPR.

12.4. Right to Restriction of Processing (Article 18 GDPR)

You have the right to request the restriction of processing of Your personal data in the following cases:

• You contest the accuracy of the data — for the period of verification;

• the processing is unlawful, but You prefer restriction of processing instead of erasure;

• the Controller no longer needs the data, but it is required by You for the establishment, exercise, or defense of legal claims;

• You have objected to processing (Article 21 GDPR) — pending verification of whether the Controller's legitimate grounds override Yours.

12.5. Right to Data Portability (Article 20 GDPR)

You have the right to receive the personal data You have provided in a structured, commonly used, and machine-readable format (JSON), and to transmit that data to another controller without hindrance from the Controller, where processing is based on consent or a contract and is carried out by automated means.

12.6. Right to Object (Article 21 GDPR)

You have the right to object at any time to the processing of Your personal data carried out on the basis of legitimate interest (Article 6(1)(f) GDPR), on grounds relating to Your particular situation. The Controller will cease processing unless it demonstrates compelling legitimate grounds that override Your interests, rights, and freedoms.

In particular, You may object to:

• calculation of safety scores (safety_score, consistency_score);

• processing of access logs;

• use of data for algorithm improvement.

12.7. Right to Withdraw Consent (Article 7(3) GDPR)

You have the right to withdraw consent for the processing of personal data at any time. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.

Please note: withdrawal of consent for processing data necessary for the functioning of the Service on the basis of a contract entails the inability to continue using the Service and deletion of the account.

Withdrawal of consent for the processing of special categories of data (intimate questionnaire, biometrics) does not automatically result in account deletion — only the corresponding data categories are deleted.

12.8. Rights Regarding Automated Decision-Making and Profiling (Article 22 GDPR)

The AI² Dating Service uses automated data processing for:

• calculation of compatibility scores across 12 dimensions;

• determination of psychological type (MBTI) and temperament type (Fisher);

• generation of potential partner recommendations;

• calculation of safety scores (safety_score, consistency_score);

• generation of analytical reports by the AI Advisor.

Important: these automated processes do not produce decisions that have legal effects or similarly significantly affect the User. Compatibility scores and recommendations are of an auxiliary nature and do not restrict the User's legal capacity.

Nevertheless, You have the right to:

• obtain information about the logic of automated processing;

• contest the results of automated processing;

• request human intervention in decision-making;

• express Your point of view.

12.9. Right to Lodge a Complaint with a Supervisory Authority (Article 77 GDPR)

If You believe that the Controller is violating Your data protection rights, You have the right to lodge a complaint with a Data Protection Supervisory Authority in an EU/EEA Member State:

• of Your habitual residence;

• of Your place of work; or

• of the place of the alleged infringement.

A list of EU Supervisory Authorities is available on the European Data Protection Board (EDPB) website: https://edpb.europa.eu/about-edpb/about-edpb/members_en

You may also contact the Controller or DPO directly:

• DPO: gdpr@ai2.dating

• Support: support@ai2.dating

• Phone: +7 (747) 029-43-05

The Controller undertakes to review the request within one month from the date of receipt.

13. AI Transparency (EU AI Act)

13.1. General Provisions

In accordance with the requirements of Regulation (EU) 2024/1689 (EU AI Act), the Controller ensures transparency in the use of artificial intelligence technologies within the Service.

13.2. AI Systems Used in the Service

a) Compatibility Algorithm (ScoringEngine):

• Purpose: calculation of compatibility scores across 12 dimensions based on questionnaire data and psychological test results;

• System type: deterministic algorithm (not machine learning), based on scientifically grounded psychological models;

• Input data: questionnaire responses, MBTI and Fisher test results;

• Output data: numerical compatibility scores (0–100%) for each dimension and an aggregate score;

• EU AI Act risk category: does not fall within the high-risk category.

b) AI Advisor (Mars LLM Service):

• Purpose: generation of personalized textual responses and analytical reports;

• Technology: large language models (Claude Haiku for chat, Claude Sonnet for analytics) by Anthropic;

• Input data: pseudonymized profile data, compatibility scores, User's question text;

• Output data: textual responses and structured analytical reports;

• EU AI Act risk category: general-purpose AI system (GPAI); used as an auxiliary tool, does not make decisions on behalf of the User;

• Limitations: the AI Advisor does not replace professional psychological assistance; generated recommendations are informational in nature.

c) DeepFace (Face Verification):

• Purpose: biometric identity verification (1:1 comparison);

• Technology: ArcFace (recognition) and RetinaFace (detection) neural networks, deployed locally;

• Input data: facial photograph (selfie);

• Output data: numerical similarity score (cosine similarity) and a verified/not verified decision;

• EU AI Act risk category: biometric verification system (not identification); requires explicit consent;

• DPIA: conducted in accordance with Article 35 GDPR.

d) AssessmentService (Hidden Safety Assessment):

• Purpose: automatic detection of potentially dangerous profiles to protect the community;

• Technology: rule-based algorithm (deterministic), not machine learning;

• Input data: L1 questionnaire responses, behavioral patterns;

• Output data: safety_score, consistency_score, reputation_risk;

• Transparency: results are not displayed to the User; used internally for moderation;

• EU AI Act risk category: does not fall within the high-risk category (not ML, does not make decisions with legal consequences).

e) AI Care (Proactive Support):

• Purpose: generation of personalized support messages;

• Technology: rule-based system + LLM (when connected to Mars);

• Input data: User behavioral patterns (activity, interactions);

• Output data: textual support messages;

• EU AI Act risk category: auxiliary system, does not make decisions.

13.3. Your Rights Regarding AI

In accordance with the EU AI Act and GDPR, You have the right to:

• know that You are interacting with an AI system (the AI Advisor is clearly designated as AI);

• obtain information about the logic of AI systems;

• contest the results of automated processing (see Section 12.8);

• opt out of using AI features (AI Advisor, AI Care) without losing access to the basic functions of the Service.

14. Policy Amendments and Contact Information

14.1. Procedure for Amendments

The Controller reserves the right to amend this Policy. Grounds for amendments include:

• changes in EU/EEA legislation on personal data protection;

• introduction of new Service features related to personal data processing;

• changes in the categories of data being processed;

• changes in the list of third parties to whom data is disclosed;

• changes in security measures;

• decisions of supervisory authorities or courts.

14.2. Notification of Changes

The Controller shall notify Users of material changes to the Policy by one or more of the following means:

• publication of the updated version of the Policy on the Website;

• push notification within the Service;

• email to the address provided during registration;

• notification in the Service interface upon the next login.

In the event of material changes affecting the legal bases for processing or the scope of data being processed, the Controller will request renewed consent from the User where processing is based on consent.

14.3. Effective Date of Changes

Changes to the Policy take effect from the date of their publication on the Website, unless otherwise specified in the text of the changes. Continued use of the Service after publication of the updated Policy constitutes the User's acceptance of the changes.

In the event of disagreement with the changes, the User must discontinue use of the Service and may request the deletion of their personal data in the manner described in Section 12.

14.4. Version Archive

All previous versions of the Policy are retained by the Controller and are available upon request. The current version of the Policy is available at:

• https://ai2.dating/legal/privacy-policy

14.5. Contact Information

For all matters related to the processing and protection of personal data, You may contact:

Controller:

Private Company "New Reality"

• Registered address: Republic of Kazakhstan, Astana, Zhenis Avenue, building 1, office 29

• Email: support@ai2.dating, support@ai2dating.kz

• Phone: +7 (747) 029-43-05

Data Protection Officer (DPO):

• Email: gdpr@ai2.dating

• Postal address: Republic of Kazakhstan, Astana, Zhenis Avenue, building 1, office 29 — marked "Data Protection Officer"

When submitting a request, please include:

• Your full name;

• the email address provided during registration in the Service;

• the nature of the request;

• Your preferred method of communication for receiving a response.

The Controller undertakes to review the request and provide a response within one month from the date of receipt (Article 12(3) GDPR).

Additional Provisions

Age Restriction. The AI² Dating Service is intended exclusively for individuals who are at least 18 years of age. The Controller does not intentionally collect personal data from minors. If it is discovered that a minor has registered, their account and all personal data will be deleted immediately.

De-identification and Anonymization of Data. The Controller may anonymize personal data for statistical and research purposes. Anonymized data does not allow the identification of the information's attribution to a specific individual and is not subject to the GDPR (Recital 26).

Non-Discrimination. The Service does not permit discrimination based on racial or ethnic origin, political opinions, religious beliefs, sexual orientation, gender identity, or other protected grounds. On international domains (ai2.dating, ai2.date), there are no restrictions whatsoever with respect to LGBTQ+ users.