Privacy Policy

Last updated: 2026-10-09

This Privacy Policy ("Policy") describes how E-Raiden collects, uses, shares and protects users' personal data in compliance with Regulation (EU) 2016/679 (GDPR) and applicable data protection laws.

1. Data Controller

The Data Controller for the processing of personal data is:

2. Data Collected

E-Raiden collects the following categories of personal data:

2.1 Data provided directly by the user

• Registration data: email address, password (hashed), name, date of birth, gender
• Profile data: photos, personal description, interests, search preferences
• Messages: content of conversations between users
• Reports: information provided through reports or support requests

2.2 Data collected automatically

• Location data: approximate geographic location (if authorized by the user)
• Device data: device type, operating system, browser, unique identifiers
• Usage data: pages visited, features used, session times
• IP address: used for security and fraud prevention
• Cookies and similar technologies: as described in our Cookie Policy.
• How you found us: if you reach the site through one of our links (for example a social post or a campaign page), we note the name of that link — source, medium and campaign, or the website that linked to us. Without your consent to analytics cookies this label stays only in the open page and is lost when you reload or close it: nothing is written to your device. Only with that consent do we also keep it in your browser — e_raiden_attribution in sessionStorage (until you close the tab) and in localStorage (up to 30 days), and the oauth_acq cookie (10 minutes, only while you sign in with Google or Apple). The legal basis for this storage is your consent, which you can withdraw at any time from the cookie settings. If you then create an account, the label is saved with it and becomes personal data linked to your account. We keep it on the basis of our legitimate interest (Art. 6(1)(f)) in measuring, in aggregate form only, which channels bring new members: it is never shared with third parties, never used to profile you or to show you content, and it is deleted with your account. You can object at any time by writing to privacy@e-raiden.vip, and we will remove it from your account.

2.3 Special categories of data

Some optional profile fields can reveal special categories of personal data (Art. 9 GDPR). We process them only with your explicit consent (Art. 9(2)(a) GDPR), which you give separately for each category by ticking a box next to the field that is never pre-ticked: until you tick it, the field stays disabled. Each of these fields also offers a 'prefer not to say' option.

• Appearance (phenotype): optional; it may reveal your ethnic origin.
• Religion and halal/kosher diet: optional; they reveal religious beliefs and are covered by one single consent. Other dietary choices are not special-category data and need no consent.
• Sexual orientation: optional profile field.
• Use and visibility: these data appear in your profile and are used in other users' search filters only if you have given the related consent. They are never used for advertising or profiling and never disclosed to advertisers or other third parties, apart from the technical providers that host the Service on our behalf. Data entered before this consent was introduced stay hidden and are not processed until you give it; you can also delete them.
• Withdrawal: you can withdraw each consent at any time in Settings › Privacy. On withdrawal the related data are deleted immediately. We keep a record of each consent (category, text version, date given and withdrawn) for as long as the account exists, to be able to demonstrate it (Art. 7(1) GDPR).

3. Purposes of Processing

Personal data is processed for the following purposes:

• Service provision: creating and managing the account, matching between users, displaying profiles
• Communication: sending Service-related notifications, user messages, support communications
• Security: fraud prevention, age verification (18+), content moderation, detection of abusive behaviour
• Service improvement: anonymous statistical analysis, research and development of new features
• Advertising: without your consent to ad profiling we only show contextual, non-personalised ads, chosen from the page and the country inferred from the request. Only with that consent are ads personalised, using exclusively: age range (derived from your date of birth), gender, profile country, interests chosen in your profile, education level and professional field. We never use for advertising or profiling, even with consent (Art. 26(3) DSA and Art. 9 GDPR): appearance/phenotype (ethnic origin), religion and diet, sexual orientation, weight. You can withdraw the consent at any time in Settings › Privacy. Promotional emails (launch announcements, newsletters) are only sent with their own consent, confirmed by double opt-in (Art. 6(1)(a) GDPR): we use your email address and, if you have an E-Raiden account, your profile name to greet you. You can withdraw this consent at any time via the unsubscribe link in every email or in Settings.
• Legal obligations: compliance with legal, tax or regulatory obligations
• Premium subscription: managing the optional paid ad-free subscription and related billing
• Free Premium trial: granting the free trial only once per person and preventing abuse (for example deleting the account and signing up again to get another one). For this purpose we keep an irreversible fingerprint (SHA-256 hash) of the email address, not the address itself

Pre-launch list and newsletter (people without an account)

If you leave your email address on the waitlist or newsletter form without creating an account, it is processed as follows:

• Purposes: sending you a one-off announcement when E-Raiden opens (launch notification) and/or the newsletter, depending on the boxes you ticked. The two purposes are independent, and nothing is sent until you confirm through the link we email you (double opt-in).
• Data: email address, chosen language, which consents you gave and the version of the text you agreed to, where on the site you subscribed, the date and time of the request and of the confirmation, and the IP address and browser user-agent of the request, kept to demonstrate the consent.
• Legal basis: your consent (Art. 6(1)(a) GDPR). You can withdraw it at any time with the unsubscribe link in every email, without affecting the lawfulness of earlier processing.
• Email provider: messages are sent through Resend (Resend, Inc., United States), acting as our processor. The transfer to the United States is covered by the safeguards in section 6.
• Retention: while at least one consent is active, for as long as it remains so. If you never confirm, your data is deleted 30 days after the confirmation link expires. After you unsubscribe from everything, it is deleted 183 days (about six months) later, so that we can still demonstrate the consent and its withdrawal during that period.
• Your rights: as you have no account, write to privacy@gibses.com to access, obtain a copy of, correct or erase your data, or to object to the processing.
• Area (optional): if you pick an area on the form (for example Milan – Lugano) or type a city or postcode, we keep it with your address to count how many subscribers there are in each area and to send you the launch alert for your area. It is not required, we use it for nothing else, and it follows the same retention and rights described above.

4. Legal Basis

The processing of personal data is based on the following legal grounds under Article 6 GDPR:

• Performance of a contract (Art. 6(1)(b)): processing is necessary for the provision of the Service requested by the user
• Consent (Art. 6(1)(a)) and explicit consent (Art. 9(2)(a)): consent for geolocation and personalised advertising; explicit consent for the special-category data described in section 2.3 (appearance/phenotype, religion and halal/kosher diet, sexual orientation), given separately for each category with a box that is never pre-ticked and withdrawable at any time in Settings › Privacy, which deletes the related data immediately.
• Legitimate interest (Art. 6(1)(f)): for the security of the Service, fraud prevention and Service improvement
• Legal obligation (Art. 6(1)(c)): to comply with regulatory obligations
• Legitimate interest (Art. 6(1)(f)): to keep, also after the account is deleted, the irreversible fingerprint of the email address that prevents the free Premium trial from being obtained more than once (abuse prevention)

5. Data Recipients

Personal data may be shared with:

• Other users: profile information publicly visible to other users of the Service
• Service providers: hosting providers, email services, analytics services, payment processors
• Advertising partners: ads are served in two modes — personalised (STANDARD tier, only with consent) or contextual and non-profiling (PRIVACY tier). Advertising partners (e.g. Google AdSense) do not receive your profile data; with your consent they may use their own cookies, as described in the Cookie Policy. Cookie consent is collected via an IAB TCF-compliant consent management platform (CMP). Premium users see no ads.
• Competent authorities: when required by law or to protect E-Raiden's rights or user safety
• Stripe: payment processor for the Premium subscription (billing data)

All service providers are bound by contractual agreements that ensure an adequate level of personal data protection (Data Processing Agreement under Art. 28 GDPR).

6. Transfers Outside the EU

Some of our service providers may be located outside the European Economic Area (EEA). In such cases, data transfers take place on the basis of:

• European Commission adequacy decisions
• Standard Contractual Clauses (SCC) approved by the European Commission
• EU-US Data Privacy Framework (for transfers to the United States)

Users may request a copy of the safeguards adopted by contacting the DPO at the address indicated in section 10.

7. Retention Period

Personal data is retained only for the period strictly necessary to achieve the purposes for which it was collected:

8. User Rights

In accordance with the GDPR, users have the following rights:

• Right of access (Art. 15): obtain confirmation of processing and access their data
• Right of rectification (Art. 16): correct inaccurate or incomplete data
• Right to erasure (Art. 17): request deletion of their data ("right to be forgotten")
• Right to data portability (Art. 20): receive their data in a structured, commonly used and machine-readable format
• Right to object (Art. 21): object to processing for direct marketing purposes
• Right to restriction (Art. 18): request restriction of processing in specific circumstances
• Right to withdraw consent: withdraw consent at any time, without affecting the lawfulness of prior processing

To exercise your rights, visit the GDPR Rights page or contact the DPO.

You also have the right to lodge a complaint with the competent supervisory authority, in Estonia the Eesti Andmekaitse Inspektsioon (Estonian Data Protection Inspectorate, www.aki.ee), or with the authority of the EU Member State of your residence (e.g. Garante per la Protezione dei Dati Personali in Italy, www.garanteprivacy.it).

9. Cookies

E-Raiden uses cookies and similar technologies for the operation of the Service, traffic analysis and ad personalization. For detailed information on the cookies used, their purposes and how to manage them, please see our Cookie Policy.

10. DPO Contact

The E-Raiden Data Protection Officer (DPO) can be contacted using the following details: