Privacy Policy

Last Updated: October 1, 2025

Data Controller:

Zenex Innovations OÜ

Registry Code: 16721227

Tallinn, Estonia

1. Introduction

Zenex Innovations OÜ ("we," "us," "our," or "10XSwipe") respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, store, share, and protect your personal information when you use our website and services (collectively, the "Service").

This Privacy Policy applies to all users of 10XSwipe and should be read in conjunction with our Terms of Service.

By using our Service, you acknowledge that you have read, understood, and agree to this Privacy Policy and our data practices.

1.1 Age Requirement

Our Service is intended for individuals aged 18 years and older. We do not knowingly collect or process personal data from anyone under the age of 18. If we become aware that we have collected personal data from someone under 18, we will take steps to delete that information immediately. If you believe we have collected information from a minor, please contact us at info@zenexinnovations.com.

1.2 GDPR Compliance

As a company operating in Estonia (European Union), we comply with the General Data Protection Regulation (GDPR) and Estonian data protection laws. This Privacy Policy outlines your rights under GDPR and how we fulfill our obligations as a data controller.

2. Information We Collect

2.1 Account Information

When you create an account, we collect:

Email address
Username
Password (stored in encrypted form)
Subscription plan information
Payment information (processed through Stripe - see Section 4.3)

Legal Basis: Contract performance and legitimate business interests

2.2 Dating Profile Data

To provide our AI analysis service, you voluntarily submit:

Dating app profile photographs
Dating app bios and profile text
Screenshots of dating app profiles
Screenshots of dating app conversations and chats
Information about your dating preferences and targets
Any other content you choose to upload for analysis

Legal Basis: Your explicit consent and contract performance

IMPORTANT: By uploading this content, you represent that:

You have the right to share these images and content
You are not uploading images of minors
You are not uploading illegal, fraudulent, or stolen content
You consent to our processing of this sensitive personal data

2.3 Usage Data

We automatically collect information about how you interact with our Service:

Pages visited and features used
Time spent on the Service
Click patterns and navigation paths
Frequency of use and session duration
Feedback reports generated
Refund requests and associated documentation

Legal Basis: Legitimate business interests (service improvement, fraud prevention)

2.4 Technical Data

We automatically collect technical information about your device and connection:

IP address
Browser type and version
Device type and operating system
Time zone settings and location (country/city level)
Referring website URLs
Crash reports and error logs

Legal Basis: Legitimate business interests (security, service optimization)

2.5 Communications Data

If you contact us, we collect:

Email correspondence
Support ticket information
Feedback and survey responses
Any information you choose to provide

Legal Basis: Legitimate business interests (customer support) and contract performance

2.6 Cookies and Tracking Technologies

We use cookies and similar tracking technologies to:

Keep you logged in
Remember your preferences
Analyze website traffic and usage patterns
Improve user experience

Types of cookies we use:

Essential cookies: Required for the Service to function (cannot be disabled)
Performance cookies: Help us understand how visitors use our Service
Functional cookies: Remember your preferences and settings

You can control cookies through your browser settings. Note that disabling essential cookies may prevent you from using certain features of the Service.

Legal Basis: Your consent (for non-essential cookies) and legitimate interests

3. How We Use Your Data

3.1 Primary Service Provision

We process your data to:

Generate AI-powered feedback on your dating profiles
Analyze your photos, bios, and compatibility with targets
Provide personalized recommendations
Deliver the Service according to our Terms of Service
Process your subscription payments
Send you service-related communications

3.2 Service Improvement and AI Training

We may use your uploaded content and usage data to:

Improve our AI models and algorithms
Enhance the accuracy and quality of our analysis
Develop new features and services
Conduct internal research and analytics
Create anonymized datasets for testing and development

Your content may be used to train and improve our AI systems. However, we implement measures to protect your identity in these processes.

3.3 Fraud Prevention and Security

We process your data to:

Prevent fraudulent refund requests
Detect and prevent abuse of our Service
Verify compliance with our Terms of Service
Protect against security threats
Investigate violations of our policies
Maintain the integrity of our platform

This includes retaining data for extended periods when necessary for fraud investigation or legal compliance.

3.4 Legal Compliance

We process your data to:

Comply with legal obligations
Respond to legal requests from authorities
Enforce our Terms of Service
Protect our legal rights and interests
Resolve disputes and pursue legal remedies

3.5 Marketing Communications (Optional)

With your explicit consent, we may send you:

Product updates and new feature announcements
Promotional offers and discounts
Tips for improving your dating profile
Newsletter and blog content

You can opt out of marketing communications at any time by clicking the "unsubscribe" link in any marketing email or contacting us at info@zenexinnovations.com. Note that you cannot opt out of essential service-related communications.

4. How We Share Your Data

We do not sell your personal data to third parties.

4.1 Third-Party Service Providers

We share your data with trusted third-party service providers who assist us in operating our Service:

OpenAI (United States)

Purpose: AI analysis and feedback generation
Data Shared: Dating profile photos, bios, text content you submit for analysis
Legal Basis: Contract performance and legitimate interests
Note: Your submitted content is processed through OpenAI's API to generate feedback. OpenAI's data processing is governed by their Data Processing Agreement and Terms of Service. OpenAI has committed to GDPR compliance for EU customers.

Stripe (United States/Ireland)

Purpose: Payment processing
Data Shared: Payment information, billing details, transaction data
Legal Basis: Contract performance
Note: We do not store your full payment card details. Stripe is PCI-DSS compliant and GDPR compliant.

Hosting and Infrastructure Providers

Purpose: Website hosting, data storage, cloud services
Data Shared: All data necessary to operate the Service
Legal Basis: Contract performance and legitimate interests

All third-party service providers are contractually required to protect your data and use it only for the purposes we specify.

4.2 International Data Transfers

Some of our service providers (including OpenAI and Stripe) are based outside the European Economic Area (EEA), primarily in the United States. When we transfer your data outside the EEA, we ensure appropriate safeguards are in place:

Standard Contractual Clauses (SCCs): We use EU-approved Standard Contractual Clauses with our US-based providers
Adequacy Decisions: We rely on EU adequacy decisions where applicable
Data Processing Agreements: All providers sign agreements requiring GDPR-compliant data handling

By using our Service, you acknowledge and consent to the transfer of your data to countries outside the EEA, including the United States, under these safeguards.

4.3 Legal Requirements

We may disclose your personal data if required to do so by law or in response to:

Valid legal requests from government authorities
Court orders, subpoenas, or legal processes
Requests to comply with Estonian or EU law
Protection of our legal rights or defense of legal claims
Prevention of fraud, security threats, or illegal activity
Protection of the safety of any person

4.4 Business Transfers

If we undergo a merger, acquisition, reorganization, bankruptcy, or sale of assets, your personal data may be transferred to the successor entity. We will notify you via email and/or prominent notice on our website before your data is transferred and becomes subject to a different privacy policy.

4.5 Anonymized and Aggregated Data

We may share anonymized, aggregated, or de-identified data that cannot reasonably be used to identify you with:

Researchers and academics
Business partners
The public (for marketing, case studies, or insights)

This data does not constitute personal data under GDPR.

5. Data Retention

5.1 General Retention Principles

We retain your personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

5.2 Specific Retention Periods

Account Data:

Retained for the duration of your active subscription
Retained for 12 months after account cancellation or termination for legal compliance and potential reactivation
Deleted after 12 months unless required for legal purposes

Uploaded Content (Photos, Bios, Screenshots):

Active Users: Retained while your account is active and for 90 days after your last login
Fraud Prevention: If we suspect fraudulent activity, content may be retained indefinitely for investigation and legal purposes
AI Training: Anonymized versions may be retained indefinitely for AI model improvement
Refund Requests: Content submitted with refund requests is retained for 24 months for fraud prevention and dispute resolution

Generated Feedback Reports:

Retained while your account is active
Retained for 12 months after account closure
You may request deletion at any time (see Section 7)

Payment and Transaction Data:

Retained for 7 years to comply with Estonian accounting and tax requirements
Credit card information is not stored by us (handled by Stripe)

Usage and Technical Data:

Retained for 24 months for analytics and service improvement
Anonymized versions may be retained indefinitely

Marketing Communications Data:

Retained until you withdraw consent or for 3 years after last interaction, whichever comes first

Legal and Compliance Data:

Retained as long as necessary to comply with legal obligations, resolve disputes, and enforce our agreements

5.3 Data Deletion

After the applicable retention period, we securely delete or anonymize your personal data. Deletion methods include:

Permanent deletion from active databases
Secure erasure from backup systems within 90 days
Anonymization rendering data no longer personally identifiable

Note: We may retain certain data in anonymized form for historical, statistical, or research purposes, as this no longer constitutes personal data under GDPR.

6. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction.

6.1 Security Measures

Encryption: Data is encrypted in transit (TLS/SSL) and at rest
Access Controls: Strict access controls limit who can access personal data
Authentication: Multi-factor authentication for administrative access
Regular Security Audits: Periodic security assessments and vulnerability testing
Employee Training: Staff are trained on data protection and security best practices
Secure Infrastructure: We use reputable, secure hosting and cloud providers

6.2 Data Breach Notification

In the event of a data breach that poses a risk to your rights and freedoms, we will:

Notify the relevant supervisory authority within 72 hours (as required by GDPR)
Notify affected users without undue delay if the breach poses a high risk
Provide information about the nature of the breach and steps being taken
Offer guidance on protective measures you can take

6.3 Your Responsibility

You are responsible for:

Maintaining the confidentiality of your account credentials
Using a strong, unique password
Not sharing your account with others
Notifying us immediately of any unauthorized access

We are not liable for security breaches resulting from your failure to protect your account credentials.

7. Your Rights Under GDPR

As a data subject in the European Union, you have the following rights regarding your personal data:

7.1 Right of Access

You have the right to request a copy of the personal data we hold about you. You can request:

Confirmation that we are processing your personal data
Access to your personal data
Information about how we use and share your data

How to exercise: Email info@zenexinnovations.com with "Data Access Request" in the subject line

7.2 Right to Rectification

You have the right to request correction of inaccurate or incomplete personal data.

How to exercise: Update your information in your account settings or email info@zenexinnovations.com

7.3 Right to Erasure ("Right to be Forgotten")

You have the right to request deletion of your personal data in certain circumstances:

The data is no longer necessary for the purposes it was collected
You withdraw consent (where consent is the legal basis)
You object to processing and there are no overriding legitimate grounds
The data was unlawfully processed
Deletion is required to comply with a legal obligation

Limitations: We may refuse deletion if the data is necessary for:

Compliance with legal obligations
Establishment, exercise, or defense of legal claims
Fraud prevention or security purposes

How to exercise: Email info@zenexinnovations.com with "Deletion Request" in the subject line

7.4 Right to Restrict Processing

You have the right to request that we limit how we use your data in certain circumstances:

You contest the accuracy of the data
Processing is unlawful but you don't want deletion
We no longer need the data but you need it for legal claims
You have objected to processing pending verification of legitimate grounds

How to exercise: Email info@zenexinnovations.com with "Restrict Processing Request" in the subject line

7.5 Right to Data Portability

You have the right to receive your personal data in a structured, commonly used, machine-readable format and transmit it to another controller, where:

Processing is based on your consent or contract performance
Processing is carried out by automated means

How to exercise: Email info@zenexinnovations.com with "Data Portability Request" in the subject line

7.6 Right to Object

You have the right to object to processing based on legitimate interests or for direct marketing purposes.

For Direct Marketing: You can opt out at any time by clicking "unsubscribe" in marketing emails

For Legitimate Interests: You can object by emailing info@zenexinnovations.com. We will stop processing unless we have compelling legitimate grounds that override your interests.

How to exercise: Email info@zenexinnovations.com with "Objection to Processing" in the subject line

7.7 Right to Withdraw Consent

Where we process your data based on consent, you have the right to withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing before withdrawal.

How to exercise: Email info@zenexinnovations.com or adjust your account settings

7.8 Right to Lodge a Complaint

You have the right to lodge a complaint with a supervisory authority if you believe we have violated your data protection rights.

Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon)

Website: https://www.aki.ee

Email: info@aki.ee

You may also lodge a complaint with the supervisory authority in your country of residence.

7.9 Response Timeline

We will respond to all rights requests within one (1) month of receipt. In complex cases, we may extend this by two additional months and will notify you of the extension and reasons.

7.10 Verification

To protect your privacy, we may need to verify your identity before fulfilling rights requests. We may request additional information to confirm you are the account holder.

7.11 No Fee

We will not charge a fee for processing rights requests unless the request is clearly unfounded, excessive, or repetitive. In such cases, we may charge a reasonable administrative fee or refuse the request.

8. Third-Party Links

Our Service may contain links to third-party websites, applications, or services that are not operated by us. This Privacy Policy does not apply to third-party sites.

We are not responsible for the privacy practices of third parties. We encourage you to review the privacy policies of any third-party sites you visit.

Notable Third Parties:

Dating apps (Tinder, Bumble, Hinge, etc.)
Social media platforms
Payment processors (Stripe)
AI providers (OpenAI)

9. Updates to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors.

9.1 Notification of Changes

We will notify you of material changes by:

Updating the "Last Updated" date at the top of this policy
Posting a prominent notice on our website
Sending an email notification to your registered email address (for significant changes)

9.2 Your Acceptance

Your continued use of the Service after changes become effective constitutes your acceptance of the updated Privacy Policy. If you do not agree to the changes, you must stop using the Service and may request deletion of your account.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your data.

10. Children's Privacy

Our Service is not intended for individuals under the age of 18. We do not knowingly collect, use, or disclose personal information from children under 18.

If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately at info@zenexinnovations.com. We will take steps to delete such information from our systems.

If we become aware that we have collected personal data from someone under 18 without parental consent, we will delete that information as quickly as possible.

11. California Privacy Rights (CCPA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA):

11.1 Right to Know

You have the right to request information about:

Categories of personal information collected
Sources of personal information
Business or commercial purpose for collecting personal information
Categories of third parties with whom we share personal information
Specific pieces of personal information collected about you

11.2 Right to Delete

You have the right to request deletion of your personal information, subject to certain exceptions.

11.3 Right to Opt-Out of Sale

We do not sell personal information. You do not need to opt out of any sale.

11.4 Right to Non-Discrimination

You have the right not to receive discriminatory treatment for exercising your CCPA rights.

11.5 How to Exercise CCPA Rights

Email info@zenexinnovations.com with "CCPA Request" in the subject line or call us at [phone number if you have one].

We will verify your identity before processing your request and respond within 45 days.

12. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

Zenex Innovations OÜ

Registry Code: 16721227

Email: info@zenexinnovations.com

Website: [Your website URL]

Data Protection Officer: info@zenexinnovations.com

For GDPR-related inquiries or to exercise your rights, please email info@zenexinnovations.com with a clear description of your request.

By using 10XSwipe, you acknowledge that you have read, understood, and agree to this Privacy Policy and our data processing practices.