Privacy Policy

Cumpli ("we," "us," or "our") is a matchmaking platform for individuals practicing consensual non-monogamy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our platform.

We are committed to protecting your privacy, especially given the sensitive nature of the information you share with us. We understand that information about your relationship style, sexual orientation, and personal preferences requires the highest level of care and protection.

By using the Service, you consent to the data practices described in this policy. If you do not agree with the terms of this Privacy Policy, please do not use the Service.

We collect the following categories of information:

Account Information

• Name, email address, and phone number
• Date of birth (to verify you are 18+)
• Password (stored in hashed form)

Profile Information

• Sexual orientation and gender identity
• Relationship structure and preferences
• Profile photos and biographical information

Survey Data

• Lifestyle survey responses (values, communication style, relationship goals)
• Kink and intimacy preference data (used solely for matchmaking compatibility)

Payment Information

• Payment details are processed by PayPal. We do not store your full credit card number. We retain only the payment metadata needed to reconcile your application payment, such as provider, order, capture, and status information.

Usage Data

• Device information, browser type, and IP address
• Pages visited, features used, and time spent on the platform
• Cookies and similar tracking technologies (see Section 12)

Note: Cumpli implements technical measures to prevent search engine indexing of member profiles and content. Your profile and activity on the platform are not discoverable through external search engines.

We recognize that some of the data we collect is particularly sensitive, including:

• Sexual orientation and gender identity
• Kink and fetish preferences collected through our compatibility surveys
• Relationship structure (e.g., polyamorous, open, swinging)

We handle this sensitive data with additional safeguards:

• Explicit consent: We collect sensitive data only with your explicit, informed consent
• Encryption: Sensitive data is encrypted both at rest and in transit
• Never sold: We will never sell your sensitive personal data to third parties
• Minimal access: Access to sensitive data is restricted to essential staff on a need-to-know basis

We use the information we collect for the following purposes:

• Matchmaking: To provide personalized match recommendations based on your profile, surveys, and preferences
• Account Management: To create, maintain, and secure your account
• Communication: To send you important updates, match notifications, and service-related communications
• Analytics: To understand how our platform is used and to improve our services
• Safety: To detect and prevent fraud, abuse, and violations of our Terms & Conditions

We process your personal information under the following legal bases:

• Consent: Particularly for the collection and processing of sensitive personal data (sexual orientation, kink preferences, relationship structure). You may withdraw consent at any time.
• Contract Performance: Processing necessary to provide you with the matchmaking services you have requested.
• Legitimate Interests: Processing necessary for our legitimate interests, such as improving our services, preventing fraud, and ensuring platform safety, where these interests are not overridden by your rights.

We may share your information with the following categories of third parties:

• PayPal: For payment processing. PayPal receives only the payment information necessary to process your transactions. We do not store your full card number.
• Hosting and Infrastructure: Cloud service providers that host our platform and databases, subject to strict data processing agreements.
• Legal Requirements: We may disclose your information if required by law, subpoena, or court order.
• Legal Claims and Rights Protection: We may disclose information where reasonably necessary to establish, exercise, or defend legal claims, enforce our agreements, investigate wrongdoing, or protect the rights, property, or safety of Cumpli, our members, or others.
• Safety and Fraud Prevention: We may share information to investigate, prevent, or respond to fraud, abuse, security incidents, or violations of our Terms & Conditions or Consent & Community Guidelines.
• Corporate Transactions: If Cumpli is involved in a merger, acquisition, financing, restructuring, sale of assets, bankruptcy, or similar transaction, your information may be disclosed or transferred as part of that process, subject to applicable confidentiality and legal requirements.

We do not sell your personal data. We will never sell, rent, or trade your personal information to third parties for marketing or advertising purposes.

What Other Members Can See

Other members may see your profile information, including your name, photos, and general preferences. Specific survey responses (such as detailed kink preferences) are used for matchmaking algorithms only and are not displayed to other members unless you choose to share them.

Profile data is accessible only to authenticated members and is not publicly accessible or indexed by search engines. Members are strictly prohibited from sharing, screenshotting, or redistributing other members' profile information, messages, or any other content outside the platform. Violations of this policy may result in immediate account termination, as outlined in our Terms & Conditions and Consent & Community Guidelines.

We retain your personal information for as long as your account is active or as needed to provide you with the Service. Specifically:

• Active accounts: Data is retained for the duration of your membership
• Account deletion: Upon account closure, we will delete your personal data within 30 days, except where retention is required by law
• Legal holds: We may retain information longer if required for legal proceedings, regulatory compliance, or dispute resolution
• Safety and Fraud Controls: Limited records may be retained for backups, fraud prevention, safety enforcement, and to help prevent banned or abusive users from re-registering.

In some cases, residual data may remain in secure backups for a limited period before it is overwritten or deleted as part of our normal retention cycle.

You have the following rights regarding your personal data:

• Access: Request a copy of the personal data we hold about you
• Correction: Request correction of inaccurate or incomplete personal data
• Deletion: Request deletion of your personal data, subject to legal retention requirements
• Portability: Request a portable copy of your data in a structured, machine-readable format
• Objection: Object to processing of your personal data based on legitimate interests
• Withdrawal of Consent: Withdraw your consent for processing of sensitive personal data at any time

To exercise any of these rights, please contact us at [email protected]. We will respond to your request within 30 days.

For your protection and the protection of other members, we may request information needed to verify your identity before fulfilling an access, correction, portability, or deletion request.

We may limit or deny a request where compliance would conflict with applicable law, compromise another person's privacy, expose trade secrets or security controls, or prevent us from providing essential aspects of the Service.

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

• Right to Know: You may request information about the categories and specific pieces of personal data we have collected, the sources of that data, our purposes for collecting it, and the third parties with whom we share it.
• Right to Delete: You may request that we delete the personal information we have collected from you, subject to certain exceptions.
• Right to Opt-Out: You have the right to opt out of the sale of your personal information. As stated above, we do not sell your personal data.
• Non-Discrimination: We will not discriminate against you for exercising any of your CCPA rights.

If you are located in the European Economic Area (EEA), you have additional rights under the General Data Protection Regulation (GDPR), including:

• The right to lodge a complaint with your local data protection authority
• The right to restrict processing of your personal data
• The right to object to automated decision-making, including profiling, where it produces legal or significant effects

If we transfer your data outside of the EEA, we will ensure appropriate safeguards are in place, such as Standard Contractual Clauses approved by the European Commission.

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

• Encryption: All data is encrypted in transit (TLS/SSL) and at rest
• Access Controls: Strict role-based access controls limit who can access your data
• Breach Notification: In the event of a data breach affecting your personal information, we will notify you and relevant authorities as required by applicable law
• Sensitive Data Protections: Additional security measures are applied to sensitive data categories (sexual orientation, kink preferences), including enhanced encryption and access restrictions
• Search Engine Blocking: Member profiles and content are protected from search engine indexing through technical measures (noindex directives and authentication walls), ensuring your presence on Cumpli is not discoverable through external searches

While we strive to protect your personal data, no method of transmission or storage is 100% secure. We cannot guarantee absolute security.

We use cookies and similar tracking technologies for the following purposes:

• Essential Cookies: Required for the Service to function (e.g., authentication, session management)
• Analytics Cookies: Help us understand how visitors interact with the platform so we can improve the user experience
• Preference Cookies: Remember your settings and preferences for future visits

You can manage cookie preferences through your browser settings. Disabling essential cookies may affect the functionality of the Service.

The Service is intended solely for individuals who are at least 18 years of age. We do not knowingly collect personal information from anyone under 18. If we become aware that we have collected data from a person under 18, we will take steps to delete that information promptly.

If you believe that a minor has provided us with personal information, please contact us immediately at [email protected].

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the updated policy on the Service and updating the "Effective Date" at the top of this page.

We encourage you to review this Privacy Policy periodically. Your continued use of the Service after any changes indicates your acceptance of the updated policy.

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