This is a translation provided for information. The Russian text prevails; in case of any discrepancy the Russian version applies.
1. General provisions
1.1. This Policy sets out how the personal data ("PD") of users of the dating application "КьюПи" (KyuPi) (the "Application") is processed and protected, and applies to all information the Operator may obtain about a user.
1.2. Operator: Egor Andreevich Lebedev — a natural person (art. 3 of Federal Law No. 152-FZ), Kaliningrad, Russian Federation. The Operator's full postal address is provided on request at noreply@qp.com.ru. The Operator is located within the Russian Federation and processing is carried out in compliance with 152-FZ; engaging a separate representative or processor in Russia is not required.
1.3. Use of the Application means the user agrees to this Policy. Certain kinds of processing (special categories of PD, cross-border transfer) require separate consent (section 7).
1.4. The Application is intended only for persons over 18. Personal data of minors is not processed; such accounts are deleted when found.
1.5. Sign-in methods. For users in Russia, authentication is by phone number (in accordance with Federal Law No. 406-FZ, which restricts the use of foreign authentication services). Sign-in via Apple ID / Google is available in other jurisdictions. A phone number is required at registration in all cases.
2. Categories of data subjects and personal data
2.1. Categories of subjects: registered users of the Application.
2.2. Personal data processed:
- Identification — name, year of birth, gender. Source: the user.
- Contact — phone number, email address. Source: the user at code sign-in.
- Account (OAuth) — Apple/Google identifier and email. Source: the sign-in provider.
- Geolocation — city, country, coordinates (for nearby matching). Source: the user or their device.
- Media — photos, audio and video profile presentation. Source: the user.
- Behavioural — likes, views, "interested" marks. Source: actions in the Application.
- Communications — chat messages, participation in events. Source: the user.
- Technical — device tokens for push notifications, sessions, masked IP address and User-Agent for security. Source: the device.
2.3. Special categories of PD. Given the purpose of the Application (dating), correspondence, likes and the fact of a mutual match may reveal information about intimate life and personal relationships. Such data is processed only with the user's separate explicit consent (section 7) and with enhanced protection measures (section 9).
2.4. Biometric PD. Since 24.08.2026 the Application processes biometric personal data (art. 11 of 152-FZ) — a video recording of the face made by the user in the "Confirm it's you" feature. Processing is carried out only with separate explicit consent (section 7) and for a single purpose: to confirm that the photos in the profile belong to that person.
Material limitations adopted by the Operator:
- no persistent biometric template is created or stored — neither a face vector nor an embedding. Only a mark that the check was passed and its date remain in the profile;
- the recording is stored within the Russian Federation, is not transferred outside it, and is deleted when the retention period expires (30 days by default), when consent is withdrawn, or when the account is deleted — whichever comes first;
- the decision is made by a staff member, not an algorithm. Automated biometric identification is not used; decisions producing legal effects are not taken on the basis of solely automated processing (art. 16(1) of 152-FZ);
- without this consent the feature is unavailable; the rest of the service works in full.
3. Purposes of processing
- registration and authentication of the user (including OTP and Apple/Google sign-in);
- providing the core feature — matching and showing profiles, likes, mutual matches;
- exchanging messages and taking part in events (meet-ups);
- personalising recommendations (compatibility matching);
- push notifications;
- security, fraud prevention, moderation and handling of complaints;
- compliance with legal requirements.
4. Legal bases
- consent of the data subject (art. 6(1)(1) of 152-FZ) — the principal basis;
- separate consent for the processing of special categories (art. 10 of 152-FZ);
- separate consent for cross-border transfer (art. 12 of 152-FZ);
- performance of a contract (the Terms of Service) to which the subject is a party;
- performance of obligations imposed on the Operator by law.
5. Place and periods of storage; localisation (152-FZ)
5.1. Localisation. The initial recording, systematisation, accumulation and storage of the PD of citizens of the Russian Federation are carried out using databases located within the Russian Federation (art. 18(5) of 152-FZ). Hosting: Selectel LLC, Russian Federation.
5.2. Geography of the service. As of this revision the Application operates only in the Russian Federation and all PD is stored within Russia. The technical ability to store data by country is provided for the future; if it is used, this Policy will be supplemented by a new revision before such processing begins.
5.3. Periods. PD is processed until the purposes are achieved or until consent is withdrawn / the account is deleted. Account deletion is performed immediately at the user's request: profile data, media files, correspondence, likes and event participation are erased from the working databases at the moment of the request. Backups are kept for 7 days, after which deleted data disappears from them as well. The exception is data the Operator is required by law to retain (including the consent log).
6. Transfer to third parties (sub-processors)
6.1. The Operator engages processors for certain operations. As of this revision:
- Selectel LLC, Russian Federation — hosting of databases and files.
- Timeweb JSC, Russian Federation — delivery of sign-in code emails.
- Sole trader S. V. Shchuchkin (SMSPILOT), Russian Federation — delivery of sign-in code SMS.
- Google LLC (Firebase Cloud Messaging), United States — delivery of push notifications.
6.2. Transfer to sub-processors outside Russia is a cross-border transfer (section 7.3). Push notifications do not include special categories of PD or the content of correspondence.
6.3. Certain technical requests are made by the Operator from its own server and carry no personal data. When coordinates are resolved from a city name, when city suggestions are offered while typing, or when an event venue is resolved from its address, only the place name, the typed string or the venue address leaves the Operator's perimeter — without the User's identifiers, coordinates or IP address. The recipient cannot relate such a request to a particular person, which is why these services are not listed above.
7. Consents (obtained separately)
7.1. General consent to the processing of PD — at registration.
7.2. Separate consent for special categories — for the dating features (correspondence, matches). Without it, only the features that do not require such data are provided.
7.3. Separate consent for cross-border transfer — for transferring data to recipients outside the Russian Federation (push notifications via Firebase).
7.4. Withdrawal of consent — at any time in the Application settings or by writing to noreply@qp.com.ru. Withdrawal terminates processing and deletes the account unless the law provides otherwise.
7.5. Record of consents. The Operator keeps a consent log: the type of consent, the version of the text the user agreed to, the date of acceptance and the date of withdrawal. Records are not altered retroactively — re-confirmation and withdrawal add new entries, so the basis for processing can be reconstructed for any past period. The text of each version of a consent is retained and provided on request.
7.6. Consent log after account deletion. When an account is deleted, the consent log is not destroyed together with the rest of the data but is moved to an archive limited to: the type of consent, the text version, the dates of acceptance and withdrawal, the date of account deletion, the identifier of the deleted account and irreversible hashes of the phone number and email address. The name, contacts in clear text, photos, correspondence and any other data do not enter the archive; a record can only be found upon a request from the user themselves with their number or address. The purpose of retention is to fulfil the Operator's obligation to prove that consent was obtained (art. 9(3) of 152-FZ) and to protect rights in a dispute; the legal basis is art. 6(1)(2) of 152-FZ. The period is 3 years from the date of account deletion (the general limitation period, art. 196 of the Civil Code of the Russian Federation), after which archived records are destroyed automatically.
8. Rights of the data subject
The user has the right to: receive information about the processing; demand that PD be corrected, blocked or destroyed; withdraw consent; delete their account and all associated data through the Application; export their data; appeal against the Operator's actions to Roskomnadzor or a court.
Requests are sent to noreply@qp.com.ru; the response time is within the limits set by law.
9. Protection measures
- separation of PD storage by jurisdiction (residency zones);
- encryption of correspondence content at rest;
- hashing of session tokens; masking of IP addresses and identifiers in logs;
- restriction of staff access on the least-privilege principle;
- backups within the same jurisdiction, encryption of exports;
- organisational measures: an incident response procedure, notification of Roskomnadzor about breaches within the established time limit.
10. Changes to the Policy
The Operator may amend this Policy. The current revision is published in the Application and on the website, stating the date it takes effect.
Revision of: 31.08.2026 · Contact for personal data matters: noreply@qp.com.ru