Privacy Policy
How we collect, use, and protect your personal information
GDPR Compliant: This Privacy Policy complies with the EU General Data Protection Regulation (GDPR) and Belgian data protection laws.
Last updated: August 6, 2025
1. Data Controller
Controller: Vicinex
Contact person: Jolan Orounbaev
Registered address: Wielewaallaan 13,2950 Kapellen (i'm too broke for a P.O box :/)
Email: vicinexofficial@gmail.com
Phone: +32 486622390
Data Protection Officer (if appointed): No DPO appointed (not required under GDPR Article 37)
2. Legal Basis for Processing
We process your personal data based on:
Right to object: When we rely on legitimate interests, you can object to processing at any time based on your particular situation. We will stop unless we have compelling legitimate grounds or the processing is for legal claims.
2.1 Purpose-to-Legal-Basis Map
3. Personal Data We Collect
3.1 Account Information
- Identity data: Name, email address, date of birth, gender, pronouns
- Contact data: Phone number (optional)
- Profile data: Bio, interests, descriptions, profile pictures
3.2 Location Data (Sensitive Data)
- GPS coordinates - Only with your explicit consent
- Places visited - Added voluntarily by you
3.3 Usage and Behavioral Data
- Search preferences and filters
- Online status and last seen timestamps
- Chat messages and moments
- Event participation
- Friend connections and interactions
3.4 Data Sources
- Data you provide directly (account details, profile, posts, messages)
- Device/location data with your consent (GPS, approximate location)
- Automatically collected technical data (logs, diagnostics, security signals)
- Cookies and similar technologies for preferences and, where consented, analytics
- Third-party processors that act on our behalf (hosting, email, analytics)
4. How We Use Your Data
- Service provision: Create and manage your account, enable friend discovery
- Location-based features: Find nearby users and events (with consent)
- Communication: Enable messaging, notifications, and social features
- Personalization: Customize your experience based on interests
- Safety: Prevent abuse, spam, and maintain community standards
- Analytics: Improve our services and user experience
5. Data Sharing and Recipients
We do not sell your personal data. We may share data with:
- Other users: Profile information you choose to make visible
- Service providers: Cloud hosting, analytics (with data processing agreements)
- Legal authorities: When required by law or to protect rights and safety
5.1 Processors and Recipients (Overview)
- Infrastructure hosting and storage — None
- Email delivery/communication — None
- Analytics/monitoring (non-essential, consent-based) — None
- Customer support/helpdesk (if used) — None
6. International Data Transfers
Your data is primarily stored within the EU. If data is transferred outside the EEA, we use safeguards such as the EU Standard Contractual Clauses, adequacy decisions, or participation in an approved framework where applicable.
We do not currently transfer your personal data outside the European Economic Area (EEA).
7. Data Retention
- Active accounts: Retained while your account is active and as needed to provide the service.
- Deleted accounts: Core account data deleted immediately when you delete your account.
- Chat content: Deleted by the user at any time; otherwise removed when the account is deleted.
- Event participation data: Deleted when the event ends or when the account is deleted.
- Logs and security data: Retained for up to 30 days for security and troubleshooting purposes.
- Backups: Deleted automatically on a rolling basis within 90 days.
- Legal retention: Certain data may be kept longer if required to comply with laws or defend legal claims.
8. Your Rights Under GDPR
As an EU resident, you have the right to:
8.1 Right of Access
Request a copy of your personal data we hold
8.2 Right to Rectification
Correct inaccurate or incomplete personal data
8.3 Right to Erasure ("Right to be Forgotten")
Request deletion of your personal data in certain circumstances
8.4 Right to Restrict Processing
Limit how we process your data in certain situations
8.5 Right to Data Portability
Receive your data in a machine-readable format or transfer to another service
8.6 Right to Object
Object to processing based on legitimate interests or direct marketing
8.7 Right to Withdraw Consent
Withdraw consent for location tracking or marketing at any time
How to exercise your rights: Contact us at vicinexofficial@gmail.com. We may request information to verify your identity before acting on your request and will respond within 1 month as required by GDPR.
9. Consent Management
You can manage your privacy settings in your account:
- Location sharing preferences
- Profile visibility settings
- Communication preferences
- Data deletion options
For cookies and similar technologies, visit Cookie Policy or open “Cookie Settings” to manage your preferences. (If Cookie Settings are implemented)
10. Data Security
We implement appropriate technical and organizational measures, including:
- Encryption in transit and, where applicable, at rest
- Role-based access control and authentication
- Regular updates, vulnerability management, and security logging
- Backups and disaster recovery procedures
- Incident response processes
- Staff training on data protection
11. Children's Privacy
Our service is not intended for users under 16. We do not knowingly collect personal data from children under 16 without appropriate consent under applicable law.
Our service is only available to individuals who are at least 18 years old. We do not knowingly collect data from anyone under 18, and accounts found to be created by minors will be removed.
12. Data Breach Notification
In case of a data breach affecting your personal data, we will notify you within 72 hours if the breach poses a high risk to your rights and freedoms.
13. Automated Decision Making
We may use automated systems for:
- Friend recommendations based on interests and location
- Content moderation and spam detection
- Safety and abuse prevention
These processes help surface relevant content and protect the Service. They do not produce legal effects or similarly significant effects on you without human involvement.
Your rights: You can object to profiling for direct marketing and request human review where decisions are based solely on automated processing. We do not use automated decision-making that produces legal or similarly significant effects on you.
14. Complaints and Supervisory Authority
You have the right to lodge a complaint with your local data protection authority:
For Belgium: Data Protection Authority (APD-GBA)
Website: www.dataprotectionauthority.be
Email: contact@apd-gba.be
15. Changes to This Policy
We may update this Privacy Policy from time to time. We will notify you of material changes by email or through our service.
16. Contact Information
For privacy-related questions or to exercise your rights:
Privacy Contact
Email: vicinexofficial@gmail.com
Data Protection Officer: [If you have one]
Response time: We aim to respond within 30 days