DZYR Privacy Policy

Last Updated: March 18, 2026 — Version 2.0

This privacy policy explains how DZYR ("we," "our," or "us") collects, uses, shares, and protects your personal data when you use the DZYR dating application and related services. This policy is provided in accordance with the EU General Data Protection Regulation (GDPR) Articles 13 and 14.

1. Who We Are

DZYR is a verified dating application operated by 9th Level Software, 7402 N 56th St, Ste 355-566, Tampa, FL 33617. We act as the data controller for the personal data processed through the DZYR app and the public website at mydzyr.com.

Privacy contact: For any data protection enquiries, data subject access requests, or complaints, contact us at privacy@mydzyr.com.

2. What We Collect

DZYR collects the following categories of personal data to operate the dating service:

2.1 Account Data

Email address, display name, and authentication provider (Apple Sign-In, Google Sign-In, or email/password). This data is collected at registration and is required to create and maintain your account.

2.2 Profile Data

Name, age, gender, biography, interests, and dating intent. You provide this data when building your profile, and it is displayed to other users during discovery.

2.3 Photos

Profile photos and Flare (After Hours) photos you upload. Photos are processed (resized, EXIF metadata stripped for privacy) and stored on Cloudflare R2 object storage. Perceptual hashes are computed for safety moderation purposes.

2.4 Precise GPS Location

Latitude and longitude coordinates, collected when you grant location permission. Location data is used for proximity-based discovery matching. In Flare mode, coordinates are additionally fuzzed (randomized within a small radius) before being used in matching queries. Location data is encrypted at rest.

2.5 Sexual Preference and Orientation

Sexual preference and orientation data you provide. This is GDPR Article 9 special category data and is processed only with your explicit consent. See Section 4 for details on how we handle this sensitive data.

2.6 Messages

Text messages exchanged through the regular chat feature and through Flare (After Hours) mode. Regular messages are retained until account deletion. Flare messages are automatically deleted after 30 days.

2.7 Identity Verification Data

For users who complete ID verification, we process: full name, date of birth, and identity document details. Verification is performed by our processor KYCAID. Verification data is encrypted at rest using AES-256-GCM and stored only as encrypted ciphertext after initial processing. We retain the verification outcome (verified/not verified) and encrypted source data until account deletion.

2.8 Device Information

Device model, platform (iOS/Android), and device identifiers. This data is collected for ban evasion detection and fraud prevention. Device fingerprints are stored with a link to the user account.

2.9 Subscription and Payment Data

Subscription product identifiers, purchase dates, expiry dates, and active status. Payment processing is handled entirely by RevenueCat and the respective app store (Apple App Store or Google Play). We do not receive or store payment card details.

2.10 Usage Data and Diagnostics

Error reports, crash diagnostics, and performance metrics collected via Sentry. All personally identifiable information (PII) is scrubbed from error events before they are transmitted. Request bodies, query strings, cookies, and authorization headers are redacted. Session replay is disabled. We also maintain audit logs of security-relevant actions (login attempts, profile changes, consent changes) for 90 days.

3. Why We Collect It

We process your personal data under the following lawful bases as defined by GDPR Article 6:

3.1 Performance of Contract (Article 6.1.b)

Processing necessary to provide the DZYR dating service you signed up for:

• Account data: To create and maintain your account, authenticate your identity, and provide the service.
• Profile data: To build and display your profile to potential matches.
• Photos: To display your photos to other users in discovery and chat.
• Messages: To deliver messages between matched users.
• Subscriptions: To manage your subscription status and grant access to premium features.

3.2 Consent (Article 6.1.a)

Processing based on your freely given, specific, informed, and unambiguous consent. You may withdraw consent at any time through the in-app Privacy Controls or by contacting privacy@mydzyr.com. Withdrawal does not affect the lawfulness of processing performed before withdrawal.

• Location discovery: Using your GPS coordinates for proximity-based matching.
• Sexual preference: Processing your sexual preference for preference-based matching (Article 9 special category data — see Section 4).
• Marketing: Sending promotional notifications and communications.
• Analytics: Collecting usage analytics for service improvement.
• Flare (After Hours): Processing your data within the Flare timed-matching feature, including fuzzed location sharing.

3.3 Legitimate Interest (Article 6.1.f)

Processing necessary for our legitimate interests, balanced against your rights:

• Device fingerprinting: Detecting and preventing ban evasion, fraud, and platform abuse. Our legitimate interest is maintaining a safe environment for all users.
• Audit logs: Recording security-relevant events (login attempts, consent changes, account modifications) to detect unauthorized access and support incident response. Retained for 90 days.
• Safety moderation: Processing block lists, reports, and photo hashes to detect and remove harmful content and users.

4. Special Category Data

Sexual preference and orientation data constitutes special category data under GDPR Article 9. We process this data under Article 9(2)(a) — explicit consent of the data subject.

How It Works

• When you first provide sexual preference data, you are asked for explicit consent for its processing.
• Consent is recorded with a timestamp, your IP address, consent version, and purpose identifier (sexual_preference).
• Your sexual preference is used in discovery matching to show you profiles that match your stated preferences, and to show your profile to users whose preferences you match.

If You Withdraw Consent

• Your sexual preference data is excluded from the discovery matching algorithm.
• Your profile will still appear in discovery results, but orientation-based filtering will not be applied to or by your profile.
• Users who have explicitly denied sexual preference consent are excluded from orientation-based matching results for all users.
• Your stored preference data is retained (it was collected lawfully) but is no longer actively processed for matching. You may request its erasure separately.

Safeguards

Sexual preference data is stored in the same database as other profile data but is access-controlled. It is included in GDPR data exports only for the data subject themselves. It is never shared with third-party processors except as part of encrypted database backups on our hosting infrastructure.

5. Who We Share With

We share personal data with the following categories of recipients, each acting as a data processor under a Data Processing Agreement (DPA):

5.1 Firebase / Google

Data shared: Authentication tokens, push notification tokens, analytics events (if analytics consent granted).

Purpose: User authentication (Apple/Google Sign-In), push notification delivery, and optional analytics.

DPA: Firebase Data Processing Terms

5.2 Sentry

Data shared: Error events and performance traces with all PII scrubbed (request bodies, query strings, cookies, authorization headers, and user email/IP are redacted before transmission). sendDefaultPii is explicitly set to false.

Purpose: Error monitoring and crash reporting for service reliability.

DPA: Sentry DPA

5.3 RevenueCat

Data shared: Anonymous user identifiers and subscription purchase/expiry events.

Purpose: Subscription management, entitlement tracking, and purchase validation.

DPA: RevenueCat DPA

5.4 KYCAID

Data shared: Name, date of birth, and identity document images (transmitted over TLS, encrypted at rest).

Purpose: Identity verification to confirm users are real adults.

DPA: Contact KYCAID directly. See KYCAID Privacy Policy.

5.5 Cloudflare / R2

Data shared: Profile photos and Flare photos (stored as objects in R2 buckets).

Purpose: Photo storage and content delivery.

DPA: Cloudflare Customer DPA

5.6 Railway

Data shared: All data processed by the application passes through Railway infrastructure (compute and managed PostgreSQL database).

Purpose: Cloud hosting for backend microservices and database.

DPA: Railway DPA

6. International Transfers

Your personal data is processed on infrastructure located in the United States. Where data is transferred outside the European Economic Area (EEA), we rely on the following safeguards:

• Standard Contractual Clauses (SCCs): Our processor agreements with US-based providers incorporate the European Commission's Standard Contractual Clauses as the transfer mechanism under GDPR Article 46(2)(c).
• EU-US Data Privacy Framework: Where applicable, our processors are certified under the EU-US Data Privacy Framework.
• Supplementary measures: Data is encrypted in transit (TLS 1.2+) and at rest (AES-256-GCM for sensitive fields). Access to production infrastructure is restricted to authorized personnel.

7. How Long We Keep It

We retain personal data only as long as necessary for the purposes described in this policy:

Data Category	Retention Period
Account and profile data	Until account deletion
Photos	Until account deletion (R2 objects deleted on account removal)
Regular messages	Until account deletion
Flare (After Hours) messages	30 days (automatically deleted by scheduled cleanup)
Flare sessions	30 days (included in data export for this window)
Audit logs	90 days
KYC verification data	Until account deletion (encrypted at rest with AES-256-GCM)
Device fingerprints	Until account deletion
Consent records	Until account deletion (retained for audit trail even after withdrawal)
Login attempt logs	90 days

When you delete your account, all associated data is removed immediately. Account deletion cascades to all related records (profile, matches, messages, consents, subscriptions, device fingerprints, photos). Safety records (blocks, reports) may be retained longer where required to prevent abuse.

8. Your Rights

Under the GDPR, you have the following rights regarding your personal data:

8.1 Right of Access (Article 15)

You can request a copy of all personal data we hold about you. Use the in-app data export feature (available in Privacy Controls) or send a request to privacy@mydzyr.com. The export is provided as a structured JSON file. The API endpoint is GET /auth/data-export.

8.2 Right to Rectification (Article 16)

You can correct inaccurate personal data at any time by editing your profile in the app. For data that cannot be edited directly (e.g., email address associated with a third-party sign-in provider), contact privacy@mydzyr.com.

8.3 Right to Erasure (Article 17)

You can delete your account and all associated data through the app's account deletion feature or by following the instructions at mydzyr.com/delete-account. Deletion is immediate and cascades to all personal data categories listed in Section 2.

8.4 Right to Data Portability (Article 20)

You can export your data in a structured, commonly used, machine-readable format (JSON). Use the in-app export feature or the GET /auth/data-export API endpoint.

8.5 Right to Restrict Processing (Article 18)

You can request that we restrict the processing of your personal data. When processing is restricted:

• Your profile is hidden from discovery results.
• Your data is stored but not actively processed for matching or recommendations.
• Existing matches and messages are preserved but no new processing occurs.

To restrict processing, use the in-app Privacy Controls or contact privacy@mydzyr.com. The API endpoint is POST /auth/restrict-processing. You can lift the restriction at any time via DELETE /auth/restrict-processing.

8.6 Right to Object (Article 21)

You can object to processing based on legitimate interest (Section 3.3). We will cease processing unless we demonstrate compelling legitimate grounds that override your interests. Contact privacy@mydzyr.com to exercise this right.

8.7 Right to Withdraw Consent (Article 7.3)

Where processing is based on consent (Section 3.2), you can withdraw consent at any time through:

• The in-app Privacy Controls (per-purpose consent toggles).
• The API endpoint DELETE /auth/consents/:purpose.
• Email to privacy@mydzyr.com.

Withdrawal is effective immediately. It does not affect the lawfulness of processing performed before withdrawal.

8.8 Right to Lodge a Complaint

If you believe we have not handled your data in accordance with the GDPR, you have the right to lodge a complaint with a supervisory authority. You may contact the supervisory authority in the EU Member State of your habitual residence, place of work, or place of the alleged infringement.

9. Security Measures

We implement appropriate technical and organizational measures to protect your personal data:

• Encryption at rest: Identity verification (KYC) data is encrypted with AES-256-GCM. Location coordinates are encrypted before storage. Database connections use TLS.
• Encryption in transit: All API communication uses TLS 1.2 or higher. The mobile application implements certificate pinning to prevent man-in-the-middle attacks.
• Authentication: JWT-based authentication with token rotation. Refresh tokens are securely stored. Rate limiting is applied to all endpoints.
• Access control: Backend microservices use internal service authentication (HMAC-based). Database access is restricted to application service accounts.
• Audit logging: Security-relevant actions are logged with correlation IDs for incident investigation. Logs are retained for 90 days.
• PII scrubbing: Error monitoring (Sentry) has PII scrubbing enabled. Request bodies, tokens, cookies, and authorization headers are redacted before transmission. sendDefaultPii is explicitly disabled. Session replay is disabled.
• Photo processing: EXIF metadata is stripped from all uploaded photos to prevent location and device leakage.

10. Changes to This Policy

This privacy policy is versioned. The current version is 2.0, effective March 18, 2026.

When we make material changes to this policy, we will:

• Update the version number and "Last Updated" date at the top of this page.
• Bump the internal consent version, which triggers a consent renewal prompt for all existing users on their next app session.
• Where changes affect consent-based processing, request re-consent before continuing that processing.

We encourage you to review this policy periodically. The canonical URL for this policy is https://mydzyr.com/privacy.

Child Safety

DZYR is an adults-only service. We do not knowingly collect data from anyone under the age of 18. If a report involves a minor or child safety risk, refer to our Child Safety Standards for escalation procedures.

Contact

• Privacy enquiries: privacy@mydzyr.com
• Privacy policy: https://mydzyr.com/privacy
• Support: https://mydzyr.com/support
• Account deletion: https://mydzyr.com/delete-account