This Privacy Policy explains how RELATECH LABS LTD ("we", "us", "our") collects, uses, shares, and protects information when you access or use FlirtyLabs and related websites, apps, and services (the "Services"). By using the Services, you acknowledge this Policy.

1. Who we are and how to contact us

1.1. Controller. RELATECH LABS LTD is the operator of the Services and acts as the data controller for the personal data processed through the Services (unless stated otherwise).

1.2. Contact details:

• Address: Unit 3, Office A , 1st Floor, 6-7 St Mary At Hill, London, England, EC3R 8EE
• Email: [email protected]

1.3. Law enforcement enquiries. Authorities may contact [email protected] with the subject line “Law Enforcement Request”. Requests should identify the requesting authority and officer, provide independently verifiable official contact details, state the legal basis and purpose, and specify the relevant account identifiers, information sought, and time period. Any urgency and applicable legal deadline should be explained. Submitting a request does not guarantee disclosure.

2. Key definitions

2.1. Personal Data means information that identifies you directly or indirectly (e.g., email, phone, IP address, user ID).

2.2. Special Category Data (sometimes called "sensitive data") may include information revealing racial or ethnic origin, religion, sexual orientation, or other sensitive traits, where permitted by law and provided by you.

2.3. Anonymous/aggregated data is information that does not identify you (or has been de-identified) and is used for analytics and improvement.

3. Age limits and children

3.1. The Services are for adults only. We do not knowingly collect information from anyone under 18.

3.2. If we learn that a user is under 18, we may suspend the account and delete related data as required by law.

3.3. If you believe a minor has provided us data, contact [email protected] (see Section 1).

4. Information we collect

We collect information in several ways, including what you provide, what we collect automatically, and what we receive from integrations.

4.1. Information you provide directly

(a) Account and profile information: screen name, email address, date of birth, profile details, photos, preferences, and any other information you choose to add.

(b) Optional sensitive profile details: you may choose to provide information such as race, religion, and sexual orientation (where permitted).

(c) Support and communications: messages to support, complaints, feedback, survey responses, and related correspondence.

(d) Invites and referrals: if you invite contacts, you may provide their name, email, or phone number (see Section 9.6).

(e) Verification data: when required, we may collect age/identity verification information (see Section 6).

4.2. Information generated through your use of the Services

(a) Activity and interactions: searches, likes/winks, blocks, reports, profile views, matches, and other behavioral signals.

(b) Messages: content you send and receive through in-service messaging (including attachments/media where available).

(c) Transactions: records of token purchases and pay-as-you-go feature use, payment confirmations, chargeback/dispute information (payment card data is typically handled by payment processors; see Section 9.2).

4.3. Information collected automatically

(a) Device and technical data: device type, operating system, app version, browser type, language, time zone, and identifiers.

(b) Log and usage data: IP address, access times, pages viewed, clicks, error logs, and performance diagnostics.

(c) Cookies and similar technologies: used for sign-in, preferences, analytics, and security (see Section 12).

4.4. Location information

(a) Approximate location may be inferred from IP address.

(b) If you enable location on your mobile device, we may process GPS-based location (accuracy depends on device settings, typically within tens to hundreds of meters).

(c) Location may be used for local matching and safety/anti-fraud measures (see Sections 7 and 8).

(d) If you disable precise location, we may display a generalized or randomized location within the area you provide (e.g., postal code area) to support localized features.

4.5. Data from social networks and integrations (if offered)

(a) If you choose to connect a social account, we may receive basic account data depending on your settings and what the third party makes available (e.g., name, profile photo, user ID, email).

(b) If you allow posting or sharing, you understand content may be posted via that third party under your control.

(c) You can usually disconnect integrations in your account settings; the third party may still retain data under their own policies.

5. Why we use your information

We process personal data for these purposes:

5.1. To provide and operate the Services: create accounts, show profiles, enable matching, messaging, and user features.

5.2. To personalize your experience: recommend profiles, optimize matches, and tailor content based on preferences and activity.

5.3. To communicate with you: service updates, security notices, account alerts, support responses, and important policy changes.

5.4. To maintain safety and integrity: moderation, enforcing rules, preventing fraud, detecting spam/bots, investigating reports, and protecting users (see Section 8).

5.5. To process pay-as-you-go transactions: confirm purchases, deliver paid features, handle refunds/disputes where applicable.

5.6. To improve and develop: analytics, research, testing, debugging, and product improvements.

5.7. To market (where allowed): send offers, tips, and promotions if you consent or where lawful; you can opt out (see Section 10).

5.8. To comply with legal obligations: responding to lawful requests, tax/accounting, and regulatory compliance.

6. Legal bases for processing

Depending on your location, we rely on one or more of the following legal bases:

6.1. Contract necessity: to provide the Services you request (account, matching, messaging, paid features).

6.2. Legitimate interests: to keep the platform safe, prevent fraud, improve Services, and maintain performance—balanced against your rights.

6.3. Consent: for certain optional profile fields, precise location (where required), certain marketing communications, and some cookie categories.

6.4. Legal obligation: where laws require verification, retention, or disclosures.

7. Age Verification and Identity Verification

7.1. To ensure compliance with applicable laws and to prevent access to the Service by individuals who are under the required age, we require users to complete an age verification process.

7.2. Age verification is performed by our third-party verification provider, Didit.

7.3. During the verification process, certain personal data may be collected and processed by the verification provider. This may include identification documents, facial images, date of birth, and other information required to confirm that a user meets the minimum age requirement.

7.4. We do not store or retain identification documents submitted during the verification process unless otherwise stated. We typically receive only the verification result (for example, confirmation that the user meets the required age threshold).

7.5. The processing of personal data for age verification purposes is based on our legitimate interest in preventing access to age-restricted services by minors and ensuring compliance with applicable legal requirements.

7.6. For more information about how personal data is processed during the verification process, please refer to the privacy policy of Didit.

8. Dating-specific safety processing and moderation

8.1. Reports and complaints: if you report a user, we process report content, message excerpts, and related metadata to investigate and take action.

8.2. Content review: we may use a combination of human moderators and automated tools to detect scams, harassment, abusive content, CSAM, impersonation, or other policy violations.

8.3. Risk signals: we may analyze behavior patterns (e.g., spam-like messaging, unusual login patterns, VPN/proxy signals) to prevent fraud and protect users.

8.4. We cooperate with competent law enforcement authorities in accordance with applicable law, including by assessing and responding to lawful requests concerning suspected fraud, exploitation, threats, and other criminal activity connected with the Services. Any disclosure of personal data is subject to the safeguards described in Section 9.4.

9. How we share information

We do not sell your personal data as a business model. We share information only as described below.

9.1. With other users

(a) Your profile information is visible to other users according to your settings and the product design (e.g., screen name, photos, profile fields).

(b) Your messages are shared with recipients through the internal messaging system.

(c) If you enable location features, approximate location may be displayed to other users—use caution.

9.2. With service providers (processors)

We use vendors to help operate the Services (hosting, analytics, customer support tools, payment processing, moderation tooling, email/SMS, security). They may access personal data only to perform services for us and under contractual safeguards.

9.3. With affiliates and partners

We may share limited data with affiliated entities and trusted partners to operate or improve the Services, subject to appropriate safeguards and this Policy.

9.4. For legal and safety reasons

We may disclose relevant personal data to competent law enforcement authorities, courts, regulators, or other authorised recipients where we have a lawful basis to do so and disclosure is necessary and proportionate to:

(a) comply with applicable law, a binding court order, or another enforceable legal requirement;

(b) prevent, detect, or investigate suspected fraud or other unlawful activity;

(c) protect a person’s life or safety; or

(d) establish, exercise, or defend legal claims.

Before responding to a request, we take reasonable steps to verify the requesting authority’s identity and powers and assess the legal basis and scope of the request. We may seek clarification or challenge requests that are insufficiently supported or excessively broad.

We limit disclosures to information relevant and necessary for the applicable purpose and use appropriate security measures when transferring it. Where special category data or data relating to criminal allegations or offences is involved, we also assess the additional legal conditions applicable to that information. Requests from authorities outside the United Kingdom are assessed against applicable jurisdictional and international data-transfer requirements. Receipt of a request does not, by itself, authorise disclosure.

9.5. Business transfers

If RELATECH LABS LTD is involved in a merger, acquisition, reorganization, or sale of assets, personal data may be transferred as part of that transaction, subject to notice where required.

9.6. Invitations to contacts

If you invite contacts, we use the provided details only to send your invitation and track delivery/abuse prevention. You represent you have permission to send invitations to those people.

10. Marketing and your choices

10.1. Email/SMS marketing: where required, we ask for consent. You can opt out at any time via the unsubscribe link or by contacting support (Section 1).

10.2. Service messages: even if you opt out of marketing, we may still send non-promotional messages (security alerts, legal notices, transaction confirmations).

10.3. In-app notifications: you can control notifications in device settings and/or account settings.

11. Your rights: access, correction, deletion, portability, objection

11.1. Depending on your location, you may have rights to:

• access your data;
• correct inaccurate data;
• delete data;
• restrict processing;
• object to processing (including marketing);
• receive a portable copy of certain data;
• withdraw consent (where processing is based on consent).

11.2. Access requests (DSAR): you can submit a request to [email protected] or by mail to Unit 3, Office A , 1st Floor, 6-7 St Mary At Hill, London, England, EC3R 8EE.

11.3. Identity verification: to protect users, we may request reasonable proof of identity before fulfilling a request.

11.4. Response time: we respond within legally required timeframes (which vary by jurisdiction).

11.5. Opting out impact: limiting certain processing may reduce functionality or disable some features.

12. Cookies and similar technologies

12.1. We use cookies, SDKs, pixels, and similar tech for:

(a) essential functionality (login/session security);

(b) preferences;

(c) analytics/performance;

(d) advertising/retargeting where enabled and lawful.

12.2. You can control cookies through browser settings and, where available, our cookie banner/preferences tool. Disabling some cookies may break features.

13. Data security

13.1. We use technical and organizational measures designed to protect data (access controls, encryption in transit where feasible, monitoring, and internal policies).

13.2. No system is 100% secure. You are responsible for keeping your login credentials confidential and for safe dating practices.

14. Data retention

14.1. We retain personal data only as long as needed for the purposes described in this Policy, including compliance, dispute resolution, and platform safety.

14.2. Typical retention factors include:

• whether your account is active;
• whether data is needed for fraud prevention;
• legal/regulatory retention obligations;
• unresolved disputes or enforcement actions.

14.3. When retention is no longer needed, data is deleted or anonymized where feasible.

14.4. Preservation for legal and safety matters. Where required or otherwise lawfully justified, we may preserve specific records relevant to an investigation, legal claim, or serious safety incident beyond their usual retention period, including after account closure. Such preservation is limited to the relevant information and reviewed for continued necessity. Access is restricted to authorised personnel, and the records are deleted or anonymised when the applicable grounds for retention no longer apply.

15. International transfers

15.1. Your data may be processed in countries other than your own. Where required, we use safeguards such as standard contractual clauses or equivalent mechanisms to protect cross-border transfers.

16. Third-party links and external websites

16.1. The Services may include links to third-party websites, advertisers, or affiliates. Their privacy practices are governed by their own policies. We are not responsible for third-party privacy practices.

17. Changes to this Privacy Policy

17.1. We may update this Policy from time to time. If changes are material, we may provide additional notice (e.g., email or in-app alert).

17.2. The updated version becomes effective once published with an updated "Effective date".

18. How to contact us

18.1. Questions, complaints, or requests:

• Email: [email protected]
• Address: Unit 3, Office A , 1st Floor, 6-7 St Mary At Hill, London, England, EC3R 8EE