Amavi – to the home page

Privacy Policy

This is a convenience translation; only the German version is legally binding. In the event of any discrepancy between this translation and the German version, the German version prevails.

1. The key points in brief

  • All profiles in this app are fictional profiles operated by us. They are not real people. You never chat with other users. Real meetings are not part of the service.
  • Your chat messages are transmitted to technical service providers so that the replies of the profiles can be created. The app does not work without this transmission.
  • Erotic conversations: If a conversation becomes erotic, the replies are created by a service provider in the EU; the requests pass through a routing service in the USA. Whether a conversation has become erotic is classified automatically by the system (section 5).
  • Chat content on a flirting platform can be very personal. We treat it as a special category of personal data (Art. 9 GDPR). That is why we expressly ask for your consent when you set up your profile.
  • Your data is stored with Supabase in Frankfurt am Main (EU), your photos with Cloudflare R2 in a storage area that is bound to the EU.
  • You can withdraw your consent at any time and have your account deleted.
  • Other users do not see your profile and your pictures. There is no public area in the app.
  • Advertising measurement with Adjust only if you allow it. In the app for Android and iOS and in the web app we ask you whether we may measure which advertisement brought you to us. Without your consent this does not take place, and you can withdraw it at any time in the settings.

2. Who is responsible for the processing

The controller within the meaning of the GDPR is:

mobile TREND GmbH
Zirkusweg 1–3, 20359 Hamburg
represented by Christoph Matthiesen, Jannis Kiesow (Managing Directors)
Email: info@mobiletrend.de

For questions about data protection and to exercise your rights: info@mobiletrend.de

Our data protection officer:
Sven Weschler (iqanta), email kontakt@iqanta.com

3. Which data we store

The following list corresponds to what the system actually creates. It is deliberately complete so that you do not have to search for anything.

Account and sign-in

Email address, password — stored only as a cryptographic hash —, time of registration and of the last sign-in. This information comes from you.

If you sign in with a Google, Apple or Facebook account, we do not store a password. Instead we receive from the respective provider:

  • Google: your email address, your name, the identifier of your Google account and, if available, the address of your Google profile picture.
  • Apple: your email address and the identifier of your Apple Account, the first time also your name, provided you share it. If you choose “Hide My Email” at Apple, we receive a forwarding address from Apple instead of your address.
  • Facebook: your email address and your public profile, i.e. your name, the identifier of your Facebook account and the address of your profile picture. We do not access your friends list, your posts or other information from Facebook.

If you accept an offer in the app to purchase in the web app (see below), we generate a one-time sign-in link with which the web app signs you in without you having to enter your credentials again. It is valid only once and only for a short time; we do not write it to any log.

If you allow notifications, we store the device token for push notifications, the platform of your device and the version of the app.

We also record when the app was last in the foreground and, for each platform (web, Android, iOS), when you last used it there. The app reports this on start, when it returns to the foreground and every five minutes; we only store the latest time, no history. Other users never see this information, not even in your profile.

Consents

What you consented to, when and to which text: consent to these terms, acknowledgement of the privacy policy, confirmation of the minimum age, consent to the processing of your chat content, and the declaration regarding the right of withdrawal before a star purchase. For the terms and the privacy policy we store the version and a checksum of the text you saw; we keep the text itself in every version. Art. 7(1) GDPR requires that consent can be demonstrated. Entries are never changed; a withdrawal is a new entry.

We likewise record whether you consented to or declined advertising measurement with Adjust, and every later change in the settings.

Profile information

  • Name or display name, date of birth, gender. The age is calculated from the date of birth and not stored separately.
  • Location and, if provided, geographic coordinates. They are used to display the distance in the deck.
  • If you change your place of residence after registering, we store the old and the new place, the distance, the stars booked for it and the time. We use this for billing and to evaluate how many profiles near you are new after a move. The data is deleted together with your account.
  • The place nearest to your coordinates, including its country, determined by us. This lets a profile know the weather where you are. Our server requests the weather from the Bright Sky service (data of the German Weather Service, Deutscher Wetterdienst) using only the coordinates of the place, without any link to you.
  • Free text about you, hobbies, “looking for”, relationship status — voluntary.
  • Height, build, hair colour, eye colour, smoking, drinking, tattoos and piercings — voluntary.
  • Verification mark and account status, set by us.
  • A flag indicating whether your profile text was rejected in moderation.

Pictures

Pictures you upload, their order, which one is the profile picture, the chosen visibility and, if you set one, the price for unlocking. The picture files are stored in the object storage Cloudflare R2, in a storage area with EU jurisdiction; the database only contains the reference to them. A reduced-size version is stored, not the uploaded original.

Your pictures are stored in a closed storage area. They are delivered via our picture service (assets.amavi.dating), which checks your sign-in on every request: only you get to see your own pictures, and nothing can be accessed without signing in. Anyone who passes on the address of a picture passes on nothing that works without your sign-in (Art. 32 GDPR).

Checking uploaded pictures

Uploaded photos are checked automatically before they appear in the app: for depictions of child sexual abuse and, by automated moderation, for prohibited content such as depictions of violence. For this moderation a reduced-size version of the picture is sent to a service provider in the USA. If the check cannot take place at the moment, the picture is not published.

  • A picture with a violation is rejected and deleted. The check record is retained: time, result, category of the violation and the storage location where the picture was held.
  • If depiction of child sexual abuse is suspected, the picture is not deleted but secured as evidence in a closed area from which nothing is delivered. The account is blocked immediately; a human being reviews the case and reports a well-founded suspicion to the law enforcement authorities. Further details can be found in our child safety standards.

Use of the app

  • Your swipe decisions with time — always relating to a profile.
  • Matches that came about. We decide whether a match comes about.
  • Conversations: favourite flag, whether the free message has been used, time of the last message.
  • Messages: the content itself, the type — text, picture, nudge, gift —, the direction, the star price, whether it was free, and the time it was read. The messages of the profile are stored as well.
  • Unlocked pictures and the price paid for them.
  • For pictures you send to a profile: the price you set, whether the profile opened the picture or not, when this was decided, and the amount of the star credit.
  • Friend requests to profiles with status and price paid.
  • Blocked profiles.
  • For each conversation a memory: summary, facts about you and about the profile. For every reply of the profile, via which service it was created, and a log of failed calls without content. For pictures you send in the chat, their description.
  • For erotic conversations: which mode a conversation is currently in (normal or erotic) and since when, for every message of the profile whether it was written in erotic mode, every switch between the services, every change of the intensity level and any exclusion of your account from this feature. Details are in section 5.
  • For every reply of the profile, which example texts served as a template for it and whether you replied to it within 24 hours.
  • Short notes on what a profile told you in the conversation about its day.
  • Indications of a crisis: the automatic report, the message from the Amavi Team and when it was due and delivered. Details are in section 5 under “Indications of a crisis”.

Usage analysis

So that we can see where the app is not working well — for example at which point of the setup or of a purchase people give up —, we record which screens you open and which steps you take. This includes, for example, “onboarding step birthday reached” or “purchase cancelled”, the app version, the platform and a random identifier of this installation. The content of your messages, texts you enter and your email address are not included. If you come to us via a website, we additionally record the campaign parameters (utm_…) of the link through which you come and the address of the referring page.

The data is stored on our servers in the EU (Supabase, see §8) and is not passed on to any third parties for their own purposes. The legal basis is our legitimate interest in a functioning app (Art. 6(1)(f) GDPR). We delete the entries after 13 months; if you delete your account, we immediately remove every link to you.

You can object at any time: in the app (also in the web app) under Settings → “Usage analysis” or by email to info@mobiletrend.de. After that we no longer record anything.

Experiments

To improve the app, we sometimes try out variants — for example a different order of the setup, a different design or, on the web, a different price for a star package. For this purpose the server randomly assigns your account or your installation to a variant and remembers this assignment so that you do not keep seeing different versions. We evaluate which variant works better; the data stays with us and is not passed on to any third parties. The legal basis is the same legitimate interest as for usage analysis. If you have objected to usage analysis, you do not take part in any experiment and always see the usual version. The price you see in the shop is the price you pay. We delete the assignments after 13 months; if you delete your account, we remove the link to you immediately.

Advertising measurement with Adjust

We also advertise Amavi with ads. If you allow it, we measure in the app for Android and iOS and in the web app (app.amavi.dating) which ad brought you to us and whether a registration, the setup of your profile or a purchase follows. This way we see which advertising works and can align our campaigns accordingly. For this we use the Adjust service of Adjust GmbH, Saarbrücker Str. 37a, 10405 Berlin, Germany, which belongs to the AppLovin group.

Only with your consent. Without it, Adjust does not start either in the app or in the web app, and we do not send any data to Adjust. Independently of this, iOS itself may send anonymised reports to Adjust under Apple's SKAdNetwork procedure; they do not contain any identifier that allows conclusions to be drawn about you or your device. The app and the web app ask you once, after you have set up your profile; “Allow” and “Don't allow” are placed next to each other with equal weight, nothing is preselected. On the iPhone, Apple then additionally asks whether the app may recognise your device for advertising purposes (App Tracking Transparency). If you decline there, Adjust does not receive the advertising ID of your iPhone; measurement then only runs with the other identifiers listed below.

In the web app, measurement runs via Adjust's web SDK, a script that the web app only loads after your consent. It stores an identifier in your browser's storage (localStorage) by which Adjust recognises your browser on your next visit. There is no advertising ID in the browser; the web app does not set any cookies for this. If you delete your browser data for app.amavi.dating, this identifier is gone as well.

On our website amavi.dating, the links to the app stores may lead via Adjust: if you tap one of them, Adjust learns your IP address, your browser and the campaign of the link during the redirect, so that a later installation can be attributed to this campaign. The website itself does not set any cookies for this, stores nothing in your browser and does not load any script from Adjust.

Which data:

  • in the app, the advertising ID of your device: on Android Google's advertising ID, on the iPhone the IDFA, the latter only if you release it to Apple;
  • on the iPhone, the identifier that Apple gives the app for us as the provider (IDFV);
  • in the web app, the identifier that Adjust's web SDK stores in your browser's storage;
  • the identifier that Adjust assigns to your device or browser (ADID);
  • the IP address of your device when the app or the web app connects to Adjust, and technical information such as operating system, device type, browser and app version;
  • the attribution that Adjust reports back to us: the ad network, the campaign, the ad group and the ad through which you came;
  • the events registration, completed profile setup, purchase with amount and currency and your first purchase, each with time.

Our server reports the events to Adjust, linked only to the ADID of your installation, i.e. the app on your device or the web app in your browser. If you gave consent in the app, this also applies to a purchase you complete in the web app. If you only give consent some time after registration, we also report the events of the seven days before, but not older ones. Adjust does not receive your name, your email address, your profile information or the content of your messages, nor the random installation identifier from the usage analysis; we deliberately do not give that to Adjust.

From Adjust we receive the ADID and the attribution (ad network, campaign, ad group, ad) and store both with your installation, so that we can break down our analysis by campaign and attribute the events of your account to the correct installation.

Adjust attributes the installation to the ad through which you came. For this purpose Adjust may inform the ad network that delivered the ad that the installation and the events mentioned go back to this ad. The ad network is itself responsible for what it does with this.

The legal basis is your consent: for the processing Art. 6(1)(a) GDPR, for reading the advertising ID and the other identifiers on your device and for storing and reading the identifier in your browser's storage Section 25(1) of the German Telecommunications Digital Services Data Protection Act (TDDDG). Adjust processes the data on our behalf (see section 8). Whether data reaches the USA in the process is set out in section 9, how long we store it in section 10.

Withdrawal. You can withdraw your consent at any time: in the app and in the web app under Settings → “Advertising measurement” or by email to info@mobiletrend.de. The app or the web app then switches Adjust off and informs Adjust that no more data is to go to third parties; our server no longer reports anything, and reports that had not yet been sent are discarded. The lawfulness of the processing until the withdrawal remains unaffected. If you delete your account in the app or in the web app while advertising measurement is switched on there, it first asks Adjust to delete the data relating to your device or browser. If you switched it off beforehand or delete your account in another way, you can contact us about this. With the withdrawal we also delete the advertising identifier and the campaign information we had stored for your installation.

Stars, diamonds and purchases

  • Balance of stars and diamonds.
  • The ledger: every booking with amount, reason, reference and time, including star credits for your pictures. Bookings are never changed; corrections are counter-bookings.
  • Purchase receipts from the app store: purchase identifier, product identifier, number of stars credited, price, time of verification. We do not receive payment data such as card numbers from the store.
  • Purchases in the web app via PayPal: the order number (PayPal order ID) and the identifier of the payment at PayPal (capture ID), package, number of stars credited, amount paid and currency, purchase channel, the status of the payment (for example pending, paid, refunded, reversed) and PayPal's response regarding the payment. It also contains the information PayPal sends about the paying person: name, email address and identifier of the PayPal account (payer ID) as well as the country. We do not receive bank or card details from PayPal.
  • Messages from PayPal about a payment — payment captured, refunded, reversed, dispute opened —, as PayPal sends them. In the case of a dispute they may also contain the reason and information about the paying person.
  • Offers for purchases in the web app: when an offer was created, from which app it came, until when it is valid and whether it was redeemed. If you accept an offer, the reference to it is also stored with the purchase. If our team excludes you from these offers, we store a note with the reason and the person who decided.
  • Daily bonus with date and streak length.
  • The contract confirmations we send you after a purchase.

Reports

If you report a profile or a conversation, we store the category, your description, whether the conversation history is to be sent along, the processing status, the decision including the reasons and the notification to you, as well as any complaint and its outcome.

Some reports are created by the system itself, under your account: for indications that a user is a minor and for indications of a crisis (section 5). They contain the category, the profile, the conversation, the note “detected automatically” with the type of indication and, in the case of a crisis, the message in which it was noticed.

Access by staff

Via an internal administration area, authorised staff can view your profile, your conversations and the pictures sent in them — to handle reports, investigate abuse and fix errors — and write in the name of a profile. Access and changes are logged: acting person, time, action, values before and after the change. For a conversation they also see its memory (summary and facts) and via which service a reply was created.

4. What we process it for and on what legal basis

  • Creating and operating the account, displaying the profile, serving the deck, delivering messages — performance of the user agreement, Art. 6(1)(b) GDPR.
  • Adapting the timing of the profiles' messages to your use and determining for each platform which pictures the profiles send (time of last use, section 3) — performance of the user agreement, Art. 6(1)(b) GDPR.
  • Sign-in with Google, Apple or Facebook — performance of the user agreement, Art. 6(1)(b) GDPR. You choose this route yourself; signing in with email and password is equally open to you.
  • Processing chat content and transmitting it to our service providers — explicit consent, Art. 9(2)(a) in conjunction with Art. 6(1)(a) GDPR. This includes the automatic classification of the latest messages of a conversation as to whether they have sexual content, the description of pictures you send in the chat, and the conversation memory (section 5).
  • Recording via which service a reply was created, and logging failed calls — legitimate interest in operation and troubleshooting, Art. 6(1)(f) GDPR.
  • Detecting indications of a crisis, notifying the moderation team and sending you support services (section 5) — your explicit consent to the processing of your chat content, which also covers this protection, Art. 9(2)(a) in conjunction with Art. 6(1)(a) GDPR; in the alternative, where there is no valid consent in an individual case or where information about other people is concerned, the protection of vital interests, Art. 9(2)(c) in conjunction with Art. 6(1)(d) GDPR; for information about other people additionally our legitimate interest in protecting our users, Art. 6(1)(f) GDPR.
  • Recording which example texts served as a template for a reply and whether you replied to it — legitimate interest in replies that are well received, Art. 6(1)(f) GDPR.
  • Analysis of colloquial language (only counts per term and age group, from 20 persons) — legitimate interest in naturally writing profiles, Art. 6(1)(f) GDPR; you can object at any time.
  • Erotic conversations via the service provider in the EU — the explicit consent to the processing of your chat content that you give when setting up your profile, Art. 9(2)(a) in conjunction with Art. 6(1)(a) GDPR. We obtain no separate consent for erotic conversations.
  • Recording the switches between the services, to evaluate how often and when conversations switch and to control the costs of the service provider for erotic conversations — the same consent as for the erotic conversations and our legitimate interest in running the service economically, Art. 6(1)(f) GDPR.
  • Excluding individual accounts from erotic conversations — legitimate interest in a safe service, in particular in protecting minors, Art. 6(1)(f) GDPR.
  • Prices for your pictures and star credit — performance of the user agreement, Art. 6(1)(b) GDPR. Whether a profile opens a picture with a price is determined automatically from the price, a random value and from how many pictures you have sent, how many the profile has offered you and how many you have unlocked in this conversation. This decision has no legal or similarly significant effect on you within the meaning of Art. 22 GDPR; it concerns only a bonus within the app.
  • Selling and booking stars and verifying purchases; retention under tax and commercial law — contract (point (b)) and legal obligation (point (c)). This applies to purchases in the app store as well as to purchases in the web app via PayPal, including the redirect to PayPal and the processing of its messages about the payment.
  • Booking and recording a change of residence for stars (section 3, profile information) — contract (point (b)); evaluating how many profiles are new after a move, legitimate interest in running the service economically and in a suitably set price (point (f)).
  • Booking refunds and reversals — contract (point (b)) and legitimate interest in not leaving stars in place for payments that have been reclaimed (point (f)).
  • Offer for purchases in the web app — legitimate interest, Art. 6(1)(f) GDPR: whether the app shows you a cheaper offer for the web app depends on whether you have reached a minimum number of purchases in the app store, whether your account has a minimum age, whether an earlier purchase was refunded or reversed, whether your account is blocked and whether our team has excluded you from the offers. We read reversals and blocks from the status of your purchases and your account; we do not create a separate entry for this. This way customers who have already purchased receive the price advantage, and we keep the risk of payment defaults low. This has no legal or similarly significant effect; you can always buy via the app store as usual. Signing in to the web app via the one-time link serves the performance of the contract (point (b)).
  • Moderation, abuse prevention, handling of reports, blocking — legal obligation under the Digital Services Act (point (c)) and legitimate interest in a safe service (point (f)).
  • Operation, troubleshooting, protection against attacks and multiple accounts — legitimate interest, Art. 6(1)(f) GDPR.
  • Usage analysis (identifying drop-off points in setup and purchase) — legitimate interest, Art. 6(1)(f) GDPR; objection in the settings.
  • Checking the minimum age — legal obligation and legitimate interest.
  • Advertising measurement with Adjust (measuring origin from campaigns, registration, profile setup and purchases) — consent, Art. 6(1)(a) GDPR; for reading the identifiers on your device and storing the identifier in your browser's storage Section 25(1) TDDDG. Withdrawal at any time in the settings under “Advertising measurement”.

5. Chat content and the replies of the profiles

All profiles you talk to in the app are fictional profiles operated by us; they are not real people. So that a profile can reply, the content of your message and the previous history of the respective conversation are transmitted to a technical service provider in the USA that creates the replies for us. We may also use further service providers for this, which we access via a routing service in the USA; details are set out in section 8. In erotic conversations the replies are created by a service provider in the EU (see below). The reply comes back, is stored and displayed to you.

The conversation history and the personality description of the respective profile are transmitted, plus, where applicable, the name of your place and the weather there (section 3, “Profile information”). Your email address and your payment data are not transmitted.

Photos that you upload to your profile are also sent to this service provider. It puts them into words in a short description so that the replies can refer to them. This description is stored with the photo.

Pictures that you send to a profile in the chat are first checked automatically (moderation by our service provider in the USA, see section 3). They are then described by the service provider in the EU, which we access via the routing service in the USA, without storage after the reply and without use for the service providers' own purposes. This also applies to nude pictures: they are described factually so that the profile can react appropriately, and they allow conclusions to be drawn about your sex life (Art. 9 GDPR). The description is stored with the message. If the description indicates that a person shown might be a minor, the picture is not described, not passed on and not added to the conversation, but secured and reviewed by a human being. If you have set a price for a picture, the profile receives the description only once it opens the picture.

Conversation memory. So that a profile remembers earlier parts of a conversation, we keep a summary for each conversation, plus facts about you that you mentioned in the conversation — including preferences, which may be intimate — and facts the profile told about itself. The memory is created by our service providers (as a rule in the USA, in erotic conversations by the service provider in the EU via the routing service) and updated with each reply. It is deleted with the conversation. Authorised staff can view it in the administration area to handle reports and fix errors (section 3).

What a profile tells you about its day. If a profile tells you what it did today, we then record this in a short note at our service providers, so that the profile does not later tell you anything contradictory. For this your last message and the profile's reply are sent to the service provider once more; until the note is written, both are kept for at most 14 days in a work queue. The note applies only to the conversation with you and does not flow into any other conversation.

Via which service a reply was created. For every reply of a profile we record internally via which service it was created. If a call fails and a fallback service steps in, we log the conversation, time, services involved, type of error and a shortened error message from the provider, but no content. This serves operation and troubleshooting; it is shown only in the administration area.

Colloquial language. So that profiles write like people of their age, we periodically count how many users per age group use terms from a list of colloquial words in their messages. The result is only a number per term and age group, and only if at least 20 different persons have used the term. Message texts or links to individual persons are not stored or passed on in the process. The basis is our legitimate interest in naturally writing profiles (Art. 6(1)(f) GDPR); you can object at any time, informally to info@mobiletrend.de.

Chat content on a flirting platform allows conclusions to be drawn about sex life. It is therefore a special category of personal data within the meaning of Art. 9 GDPR. We therefore base the processing on your explicit consent, which we obtain when you set up your profile. Without this consent the app cannot fulfil its purpose.

In addition, we automatically check inputs and outputs for prohibited content in order to prevent abuse — chat messages, your profile text on every change and uploaded pictures (see section 3). In two cases the system blocks an account without prior human review: if depiction of child sexual abuse is suspected in an uploaded picture, and in the case of repeated attempts to exchange contact details if nothing has yet been purchased with the account. If you think such a block is wrong, contact info@mobiletrend.de; a human being will then review the decision. A human being decides on all other blocks.

Indications of a crisis. If you write something to a profile that indicates suicidal thoughts, self-harm or violence against you, the system detects this automatically using fixed word patterns. This detection runs on our own servers; your message is not sent to any service provider for it. If the system detects a crisis, the following happens:

  • The profile does not reply, and the conversation is paused for 24 hours: during that time you cannot write to the profile there; instead of the input field, the app shows a notice and the way to the Amavi Team.
  • Our moderation team automatically receives a report (section 3, “Reports”).
  • About a minute later the “Amavi Team” writes to you in a separate conversation with support services and telephone numbers, at most once in 24 hours. The app shows a banner until you have read the message. The notification on your device only announces an important message with support services and does not name a reason. You can delete the conversation with the Amavi Team.
  • For 24 hours no profile writes to you on its own initiative.

We store the report, the type of indication (suicide or self-harm, violence), in which conversation and in which message it was noticed, the language of the team's message, when it was due and when it was delivered, the message itself and until when the conversation rests. Your message that triggered the indication remains stored in the conversation like any other. Only authorised staff of our moderation team can see this in the administration area, never other users. Such indications allow conclusions about your health and therefore belong to the special categories under Art. 9 GDPR. We process them to point you to help in a possible emergency. The legal basis is your explicit consent to the processing of your chat content, which also covers this protection (Art. 9(2)(a) in conjunction with Art. 6(1)(a) GDPR). Where there is no valid consent in an individual case, we rely in the alternative on the protection of vital interests (Art. 9(2)(c) in conjunction with Art. 6(1)(d) GDPR).

If you tell us about violence by other people, your message may also contain information about these people, including about their health or sex life. The detection only evaluates whether there is an indication. We use such information solely for this protective purpose; we do not create a separate record of these people and do not pass the information on. The legal basis in this respect is the protection of vital interests (Art. 9(2)(c) in conjunction with Art. 6(1)(d) GDPR) and our legitimate interest in protecting our users (Art. 6(1)(f) GDPR). We do not inform these people separately, because we do not know them and doing so would involve a disproportionate effort (Art. 14(5)(b) GDPR).

The classification has no legal or similarly significant effect on you within the meaning of Art. 22 GDPR: you can keep using the app and write to all other profiles; only the conversation concerned is paused for 24 hours, the app tells you until when, and this causes you no costs. A human in our moderation team sees every report. If you think the classification is wrong, you can at any time request at info@mobiletrend.de that a human reviews it, express your point of view and contest the classification. How long we keep the information is set out in section 10.

Erotic conversations

Where and for whom. Erotic conversations with the profiles are possible in the web app (app.amavi.dating) and in the apps for Android and iOS. We switch the feature on or off per platform and set per platform after how many of your messages a conversation can become erotic at the earliest. Depending on our setting, the apps for Android and iOS either show messages from erotic conversations or hide them with a note that you can read them in the web app; in the web app you always see them. The feature is open to adults only. We can switch it off at any time, generally or for individual accounts, for example if there are indications of minority or abuse; for such an exclusion we store a note with the reason and the person who decided.

Legal basis. We obtain no separate consent for erotic conversations. The processing is based on your explicit consent to the processing of your chat content, which you give when setting up your profile (Art. 9(2)(a) GDPR, see above). If you do not want erotic conversations, write to us at info@mobiletrend.de; we will then exclude your account from them.

Automatic switch of the service. So that a profile replies in the right tone, we automatically classify the latest messages of a conversation as to whether they have sexual content. For this purpose these messages are sent to the moderation service of our service provider in the USA. If the course of the conversation is sexual, or if no reply comes about at the main service provider, the replies are created from then on by the service provider in the EU; if the conversation calms down again or rests for a while, it switches back. Some profiles are designed for erotic conversations from the outset and their replies are created there straight away. The switch only affects where the reply is created; it has no legal or similarly significant effect on you.

The service provider for erotic conversations. It processes the requests on servers in the EU (France). At present we do not send the requests to it directly but via a routing service in the USA, which forwards them exclusively to this service provider and to no other. It receives the same as the main service provider otherwise does: the conversation history and the personality description of the profile. Under the settings we specify for this, neither the routing service nor the service provider stores this content after the reply, and neither uses it for its own purposes. None of it goes to China. Because the routing service is based in the USA, this is a transfer to a third country (section 9).

Limits and checks. Hard limits apply in erotic conversations too: no content relating to minors, no incest, no animals, no violence without consent, no real persons. We automatically check every reply in these conversations before it is sent for sexual content relating to minors, likewise via the moderation service in the USA. If the check flags it or cannot take place, the reply is not sent.

Pace of the conversation. In erotic conversations a profile escalates in levels and recognises when a climax has been reached, in order to continue more calmly afterwards. We record every change of level: conversation, profile, your account, time, old and new level, trigger and the number of your messages up to then.

What we store for this. Which mode a conversation is currently in and since when, for every message of the profile whether it was written in erotic mode (this also determines how it is shown in the apps), and for every switch: conversation, profile, your account, time, direction of the switch, trigger, the number of messages up to then and the value of the classification. This shows us how often and after how many messages conversations switch, and lets us keep an eye on the higher costs of the service provider for erotic conversations. We do not store the content of the messages a second time for this.

6. Voice recordings when dictating

If you use the microphone in the chat, the recording is transmitted to a service provider for recognition and converted into text there. The recording is not stored permanently; only the recognised text is stored, and only if you send it. The basis is your consent, which you give by tapping the microphone.

7. Consent and withdrawal

At registration you confirm that you know these terms and have taken note of the privacy policy. When setting up your profile you additionally confirm your minimum age and consent to the processing of your chat content. This consent expressly also covers protection in case of indications of a crisis (section 5).

You can withdraw your consent at any time with effect for the future, informally to info@mobiletrend.de. The withdrawal ends the further processing of your chat content; the lawfulness of the processing until the withdrawal remains unaffected. Since the processing of chat content is necessary for operating the app, a withdrawal is in practice equivalent to ending use.

For erotic conversations we obtain no separate consent; they are covered by your consent to the processing of your chat content. If you do not want erotic conversations, write to us at info@mobiletrend.de; after that, all profiles reply to you via the main service provider.

Consent to advertising measurement with Adjust is separate from this and voluntary; the app works just the same without it. You give it in the app for Android and iOS or in the web app and can withdraw it there at any time under Settings → “Advertising measurement” or give it again, and also by email to info@mobiletrend.de. What a withdrawal does is set out in section 3 under “Advertising measurement with Adjust”.

8. Who data is passed on to

We use the following service providers. For each recipient it is stated what for, where the data is processed and what a transfer outside the EU is based on.

  • Supabase (Supabase Inc., USA) — database and sign-in; containing the account, profile, chat and purchase data. Processing in Frankfurt am Main, Germany (EU, region eu-central-1). Insofar as the provider accesses it from the USA, for example in support: standard contractual clauses.

  • Cloudflare (Cloudflare, Inc., USA) — storage of your photos in the R2 object storage, in a storage area with EU jurisdiction; delivery of the pictures via the picture service assets.amavi.dating; name resolution (DNS) for amavi.dating. The picture service runs in Cloudflare's global network; a request may therefore also be handled outside the EU. Basis: standard contractual clauses and EU-US Data Privacy Framework.

  • Vercel (Vercel Inc., USA) — hosting of the website amavi.dating, the web app app.amavi.dating, our server api.amavi.dating (for example for uploading pictures and deleting accounts) and the internal administration area. The server functions run in Frankfurt am Main (region fra1). Technical connection data such as the IP address is generated in the process. Basis: standard contractual clauses and EU-US Data Privacy Framework.

  • Service provider for text and picture processing (processing in the USA) — creating the replies of the profiles, conversation memory, describing profile photos, recognising voice recordings, checking profile texts, automated moderation of uploaded pictures and of pictures in the chat, classifying the latest chat messages for sexual content and checking the replies in erotic conversations. Basis: data processing agreement with standard contractual clauses.

  • Routing service (USA) — forwarding requests to further service providers: in erotic conversations (replies and conversation memory) and for describing pictures in the chat exclusively to the service provider in the EU (see below); if we use a further service provider for other conversations, to that provider. The conversation history, the personality description of the profile and pictures you send in the chat are transmitted; without storing the content after the reply and without use for its own purposes. Basis: data processing agreement under Art. 28 GDPR with standard contractual clauses.

  • Service provider for erotic conversations (France, EU) — creating the replies of the profiles and the conversation memory in erotic conversations, describing pictures in the chat (see section 5). It currently receives the requests via the routing service. The conversation history, the personality description of the profile and the pictures are transmitted. Processing in the EU, without storing the content after the reply and without use for its own purposes.

  • Google Firebase Cloud Messaging (Google, USA) — delivery of push notifications to your device. The device token and the content of the notification are transmitted. Basis: EU-US Data Privacy Framework and standard contractual clauses.

  • Google (Google Play) — processing and verification of purchases in the app store. For verification we transmit the purchase receipt to Google. Google is independently responsible for the payment itself; its privacy policy applies.

  • PayPal (PayPal (Europe) S.à r.l. et Cie, S.C.A., 22–24 Boulevard Royal, L-2449 Luxembourg) — payment for purchases in the web app. We transmit to PayPal the package, price and currency as well as a random order identifier, no information about your account with us. You sign in to PayPal and authorise the payment there; PayPal then informs us of the status of the payment and of the information mentioned in section 3, as well as of later refunds, reversals and disputes. PayPal is independently responsible for the payment and your PayPal account; its privacy policy applies. PayPal may transfer data to other companies of the PayPal group, including in the USA.

  • Sign-in with Google (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland) — only if you sign in with your Google account. Google confirms the sign-in and transmits the information mentioned in section 3. Google is independently responsible for the sign-in with Google; its privacy policy applies. Google may transfer data to Google LLC in the USA. Basis: EU-US Data Privacy Framework.

  • Sign in with Apple (Apple Distribution International Ltd., Hollyhill Industrial Estate, Hollyhill, Cork, Ireland) — only if you sign in with your Apple Account. Apple confirms the sign-in and transmits the information mentioned in section 3. Apple is independently responsible for the sign-in with Apple; its privacy policy applies. Apple may transfer data to Apple Inc. in the USA. Basis: EU-US Data Privacy Framework.

  • Sign-in with Facebook (Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland) — only if you sign in with your Facebook account. Meta confirms the sign-in and transmits the information mentioned in section 3. Meta is independently responsible for the sign-in with Facebook; its privacy policy applies. Meta may transfer data to Meta Platforms, Inc. in the USA. Basis: EU-US Data Privacy Framework.

    For all three providers, the app opens their sign-in page in the browser; the sign-in runs via Supabase. We do not integrate any software libraries of these providers into the app.

  • Resend (Plus Five Five, Inc., USA) — sending emails: confirmations after a purchase and emails about the account, for example for resetting the password. Sending takes place from Ireland (EU); Resend stores sending logs with the recipient address in the USA. Basis: EU-US Data Privacy Framework.

  • Adjust (Adjust GmbH, Saarbrücker Str. 37a, 10405 Berlin, Germany; part of the AppLovin group, USA) — advertising measurement in the app for Android and iOS and in the web app, only with your consent (see section 3, “Advertising measurement with Adjust”). From the app, the advertising ID of your device, the IDFV, the ADID, the IP address and technical device information are transmitted, from the web app the identifier in your browser's storage, the ADID, the IP address and technical information about the browser, and from our server the events registration, profile setup, purchase with amount and first purchase. Adjust works on our behalf under Art. 28 GDPR. Insofar as companies of the AppLovin group or subcontractors outside the EU, in particular in the USA, are involved: EU-US Data Privacy Framework, otherwise standard contractual clauses. The ad network whose ad brought you to us may receive from Adjust the attribution of the installation and the events to its ad; it is independently responsible for this.

Contracts under Art. 28 GDPR exist with all service providers that process data on our behalf. We only pass on data for advertising purposes within the scope of advertising measurement with Adjust and only with your consent; we do not sell any data.

9. Processing outside the EU

The database and photos are located in the EU. Some service providers have their registered office in the USA or process data there — above all our service provider for text and picture processing (replies, picture description, speech recognition, moderation), Google Firebase Cloud Messaging (push notifications) and Resend (sending logs of emails); if you sign in with Google, Apple or Facebook, their parent companies in the USA may also be involved. Details for each recipient can be found in section 8. We base such transfers on the adequacy decision of the European Commission on the EU-US Data Privacy Framework, insofar as the recipient is certified under it, and otherwise on the standard contractual clauses of the European Commission.

Requests to further service providers, including those for erotic conversations and for describing pictures in the chat, pass through the routing service in the USA. To our knowledge it is not certified under the EU-US Data Privacy Framework; the basis is therefore the standard contractual clauses of the European Commission in the data processing agreement with it. The replies in erotic conversations are created by the service provider on servers in the EU. The classification and checking of these conversations runs via the moderation service of our service provider in the USA.

If you pay in the web app via PayPal, PayPal may transfer data to companies of the PayPal group in the USA. PayPal is itself responsible for this as an independent controller; details can be found in its privacy policy.

If you allow advertising measurement, Adjust processes the data on our behalf. Adjust is based in Berlin but belongs to the AppLovin group, which is based in the USA; processing by group companies or subcontractors in the USA or other countries outside the EU is therefore possible. The bases mentioned above apply: the EU-US Data Privacy Framework insofar as the recipient is certified under it, otherwise the standard contractual clauses. An ad network that receives the attribution from Adjust may also be located outside the EU and is itself responsible for this.

10. How long we store data

  • Account, profile, pictures: as long as your account exists. They are removed when the account is deleted, the picture files immediately, at the latest in the next daily clean-up run.
  • Messages and conversations: as long as your account exists; they are deleted with the account.
  • Time of last use, overall and per platform: only the latest value, as long as your account exists; it is deleted with the account.
  • Erotic conversations: The mode of a conversation is deleted with the conversation, the flag on a message with the message. We delete the record of switches between the services and of level changes after 13 months; if you delete your account, we immediately remove the link to you and to your conversations, and the entries remain without any connection to you until the 13 months have expired. An exclusion from erotic conversations remains in place as long as your account exists. The routing service and the service provider in the EU do not store the content beyond the reply.
  • Conversation memory, picture descriptions, record of the service: with the conversation or the message, i.e. at the latest with your account.
  • Log of failed calls: 90 days; if you delete your account, we immediately remove the link to you and to your conversations.
  • Analysis of colloquial language: we store only the counts per term and age group, no links to persons.
  • Indications of a crisis: We keep the report like other reports (see below). We delete the entry on the indication — type, language, times — automatically 30 days after it was created, at the latest with your account. If you delete the conversation concerned, the link to it is removed. The message from the Amavi Team is deleted with the team conversation, which you can delete at any time; the information until when a conversation rests is deleted with the conversation.
  • Templates for a reply and whether you replied: with the conversation, i.e. at the latest with your account.
  • Notes on what a profile tells you about its day: at most 60 days, the work queue for them at most 14 days; if you delete the conversation or your account, the work queue is removed immediately.
  • Stars, diamonds and the account ledger: as long as your account exists; they are deleted with the account.
  • Purchase receipts: for the retention periods under commercial and tax law (Section 147 of the German Fiscal Code, AO; Section 257 of the German Commercial Code, HGB), up to ten years. This applies to purchases in the app store as well as to purchases in the web app via PayPal. After an account deletion they are retained without any link to your account: transaction number, time, product, quantity, price and status, for purchases in the app store the country of purchase, for PayPal purchases the purchase channel, amount paid and currency. The purchase receipt identifier of the store is replaced by an irreversible check value, as is the identifier of the payment for PayPal purchases; the information about the paying person from PayPal's response is deleted. The order number at PayPal remains in plain text as the transaction number so that the receipt can be reconciled with PayPal's statement (Section 147 AO). The receipts are not used for anything else.
  • Messages from PayPal about payments: as part of the accounting records for the same periods, up to ten years. After an account deletion, only the type, time, status, amount and currency and, in the case of a dispute, its reason remain of each message about your purchases; the identifiers at PayPal remain only as an irreversible check value. Names, email addresses, PayPal identifiers of the paying person and messages in a dispute are deleted. This also applies to messages that only reach us after the deletion; they are stored in this form straight away.
  • Offers for purchases in the web app and a note that we no longer offer you purchases there: as long as your account exists; they are deleted with the account.
  • Contract confirmations by email: as long as your account exists; they are deleted with the account, as is every other email we have sent to your address.
  • Consents: as long as your account exists, as evidence; they are deleted with the account.
  • Reports and moderation decisions: as long as necessary for handling, a complaint and fulfilling the obligations under the Digital Services Act. If you delete your account, your decided reports are deleted with it; a report whose procedure is still ongoing is retained without any link to your account.
  • Check records for pictures: as long as your account exists. If depiction of child sexual abuse is suspected, the secured picture and the check record are retained as evidence even after an account deletion, together with the identifier, email address and creation and deletion time of the account — the information required for a report to the law enforcement authorities.
  • Logs of the administration area: for traceability of interventions. After an account deletion only the action remains (who did what at our end and when); the reference to your account and the changed values are removed.
  • Usage analysis: 13 months, then deleted. If you delete your account, the link to you is removed immediately; the entries remain without any link to you until the 13 months have expired.
  • Advertising measurement with Adjust: We store the ADID and the campaign attribution with the installation until 13 months after its last use; if you delete your account, they are removed immediately. We delete our record of the reports to Adjust (type, time, amount, sending status) 30 days after sending; reports that we discarded after your withdrawal also after 30 days, reports whose sending failed after 90 days. If you delete your account, they are deleted immediately. At Adjust the data is stored for as long as the contract with Adjust specifies; if you delete your account in the app or in the web app while advertising measurement is switched on there, it first asks Adjust to delete the data relating to your device or browser. The identifier in your browser's storage remains there until you withdraw your consent or delete your browser data for app.amavi.dating.

11. Moderation, reporting and blocking

A human being reviews reports. You receive a notification with a statement of reasons and can lodge a complaint against it; the complaint is reviewed by a different person. Further details can be found in the terms and conditions.

12. Your rights

You have the right of access (Art. 15), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18), data portability (Art. 20) and objection (Art. 21). You can withdraw a consent you have given at any time with effect for the future.

Contact info@mobiletrend.de for this. You can also delete your account including profile, pictures and conversations directly in the app (Profile → Delete account). What is deleted and what is retained is set out in section 10 and on our page “Delete account and data” (amavi.dating/konto-loeschen).

You also have the right to lodge a complaint with a data protection supervisory authority.

13. Security

The connection to the app is encrypted. Passwords are not stored in plain text. Access to data is restricted row by row in the database: each account sees only its own records, and this restriction lies in the database itself, not in the app. Pictures are stored in a closed storage area and are only delivered after the sign-in has been checked.

14. Minimum age

The app can only be used from the age of 18. You enter your date of birth when setting up your profile; a date under eighteen years cannot be selected, and the database checks it a second time.

15. What we do not do

  • We do not sell any data.
  • We do not show third-party advertising that evaluates your behaviour.
  • We do not show your profile and your pictures to any other users.
  • We do not create personality profiles for advertising purposes. Usage analysis (see above) only serves to improve the app.
  • Advertising measurement with Adjust only runs with your consent and serves solely to measure our own advertising. We nevertheless do not show advertising of other providers in the app.
  • Our service providers do not use your chat content for their own purposes.

16. Changes to this policy

We adapt this policy when the processing changes. The version in force at any time can be found in the app and on our website; you will find the version and date at the top. We inform you in advance about significant changes.