Data Protection Policy

 

February 14, 2025

1. Introduction

Hello! Thank you for your interest in our Data Protection Policy. The protection of your privacy is important to Latch GmbH (“Latch“, “We” or “Us“) is particularly important. We value your trust in our products and services, which is why We have the highest data protection requirements for our websites, apps, products and services. For all Our products and services, We follow the principles of “privacy by design” and “privacy by default” in order to take your privacy into account in the technical design and default settings of Our websites, apps, platform, products and services.

This Data Protection Policy shows you transparently what personal data We process from you, how We process it and to whom your personal data may be disclosed when you interact with Us (e.g. when you use Our website or Our app). In this Data Protection Policy, We also show you what rights you have under the applicable data protection laws and how you can exercise them. You should read this Data Protection Policy regularly so that you are always up to date on how We process your personal data and how you can exercise your rights.

2. Who are We?

We (Latch GmbH, Ebersberg 2, CH-8415 Berg am Irchel) are responsible for the processing of your personal data in accordance with this data protection notice. Data controllers determine which, how and for what purpose personal data is processed.

Other companies may be jointly responsible under data protection law for the processing of personal data in accordance with this Data Protection Policy if they are involved in deciding on the purpose or manner of processing personal data. However, We remain your main point of contact for data protection matters.

3. Where does this Data Protection Policy apply?

This Privacy Protection Policy applies to Our websites, apps, products, services, events and other services that We offer (collectively “Products“). We have linked our Data Protection Policy to all relevant Products. Some Products may have their own data protection policy. In these cases, the specific data protection policy for the respective Product applies and not this Data Protection Policy.

4. How do We process your data?

4.1. Fundamentals

So that We can support you in getting to know each other and making new connections, We need to process certain personal data about you – e.g. which other people you would like to meet. In principle, We only collect and process personal data from you when you interact with Us (e.g. when you use our Products). All information on how We process your personal data can be found in the sections below.

4.2. What is personal data?

Personal data is all information and details that relate to you or say something about you, such as your first name, surname, date of birth, email address or telephone number.

All information that does not relate to you or cannot be associated with you is not personal data. This means that anonymized information, for example, is not personal data.

 

What is sensitive personal data?

Sensitive personal data includes all personal data relating to religious, ideological, political or trade union views or activities, health, private sphere or racial or ethnic origin, genetic data, biometric data, data relating to administrative and criminal prosecutions or sanctions or data relating to social assistance measures.

4.3. What does “processing” mean?

“Processing” refers to any handling of your personal data. This includes, among other things, the collection, anonymization, storage, use, keeping, modification, disclosure or deletion of personal data.

4.4. On what legal basis do We process your personal data?

We always comply with the principles and requirements of the Swiss Federal Act on Data Protection and – if applicable in certain cases – the General Data Protection Regulation of the European Union or other applicable data protection laws. We only process your personal data lawfully and if We have a legal basis for the processing. The legal basis may include contracts, your consent, legal requirements, public interest or Our legitimate interest.

4.5. Visiting and using our Products

When you visit or use Our Products, technical information – so-called log data – is processed automatically. This includes – depending on the Products – the IP address, details of the browser used, details of the internet service provider, details of the operating system, language settings, time of the visit or use of Our Products, duration of the visit or use of Our Products. It also includes your actions in Our app (e.g. when and to whom you gave a Like or WOW, when or to whom you sent a chat message, when and to whom you made an audio or video call – We do not have access to the content of your chats or conversations that you make via Our app). This information is processed in order to ensure the highest possible security and trouble-free functionality of Our Products. If there is a personal reference in the processing of this information, We process this personal data on the basis of Our legitimate interest.

4.6. User account

In order to use Our app, you must create a user account. We process all information that you provide to Uu when creating or editing your profile. These are for example:

• Email address
• Phone number
• User name
• Date of birth
• Gender
• Search criteria
• Video
• Pictures
• Profile description
• Funfacts
• Languages
• Dating interests
• Preferences for messages (e.g. newsletters, push messages)
• Data protection settings

We process this personal data from your user account primarily so that We can provide you with Our app and thus fulfill Our contract with you. We may also process certain personal data of your user account for other purposes (e.g. for purchases in Our app, for advertising purposes), which may have other legal bases. Further information on the other processing purposes can be found in the corresponding sections. For your information: You can change most of your profile data at any time.

4.7. Geolocalization

In order for Us to show you other users within your search radius, We need your location. You can choose whether We should use your exact or approximate location. The basic processing of your location information is based on our contractual obligations to you. To determine your location, WE use the localization data (coordinates) of your device.

4.8. Purchases

You may be able to purchase products or services on Our website or app. Purchases are processed via external service providers (e.g. payment service providers). In Our app, purchases are processed via your Play Store account with Google or your App Store account with Apple. The data protection provisions of the external service providers therefore also apply to these purchases.

We process personal data about your purchases (e.g. what you bought, when you bought it) in order to fulfill Our legal and contractual obligations.

4.9. Contact

When you contact Us, We process your contact details (e.g. title, first name, surname, e-mail address, user account) and all personal data that you provide to Us in your message. We have a legitimate interest in the processing of personal data when you contact Us. In particular, We want to process all messages appropriately so that We can, for example, process your requests appropriately. To process the request efficiently, WE may use artificial intelligence, whereby only the content of your message will be processed with artificial intelligence.

4.10. Events or competitions

Events

You can voluntarily participate in Our events. If you take part in one of Our events, We may process your personal data (e.g. e-mail address, first name, surname) for the organization and implementation of Our events. Your information may also be passed on to an organizer. The processing of this personal data is based on Our legitimate interest.

Furthermore, audio, photo and video recordings can be made at Our events, which We can publish on Our website or Our social media channels, for example. If the recordings made have a personal reference, the processing is based on your consent.

 

Competitions

You can voluntarily take part in Our competitions. If you take part in one of Our competitions, We may process your personal data (e.g. e-mail address, first name, surname) for the organization and implementation of Our competitions. The processing of this personal data is based on Our legitimate interest. In our competitions, specific conditions of participation may also apply.

4.11. Surveys, interviews or market research

You can voluntarily participate in Our surveys, interviews or other market research activities. During these activities, We process your personal data (e.g. user account ID, age, gender). We use the information from market research activities exclusively to improve Our Products and the user experience of Our Products. The processing of this personal data is based on your consent when you take part in these surveys, interviews or market research.

4.12. E-Mail Newsletter

You can subscribe to Our email newsletter on Our website so that you are always kept up to date. By subscribing to Our email newsletter, you consent to the processing of your personal data in the context of the email newsletter. You can unsubscribe from the e-mail newsletter at any time by clicking on the corresponding link at the end of the e-mail newsletter. For sending the email newsletter We useSendinblue GmbH as a service provider.

4.13. Necessary notifications

If you have a user account with US, WE may notify you by push, e-mail or SMS. E.g. for important notifications about your account (e.g. missing e-mail address, video was rejected), if there is possible misuse or to verify your identity. We use Sendinblue GmbH as a service provider for sending e-mails and text messages. For the push messages WE use Google Firebase. You can deactivate push notifications for OUR app in the settings of your cell phone.

4.14. Voluntary notifications

If you have a user account with US, WE may notify you by push, e-mail or SMS. For example, if there is a match, if other users have sent you a message or even if you have not used your account for a longer period of time. You can change these notifications at any time in the app settings. We use Sendinblue GmbH as a service provider for sending emails and text messages. For the push messages WE use Google Firebase. You can deactivate push notifications for OUR app in the settings of your cell phone.

4.15. Cookies and similar technologies

We may use cookies and similar technologies on Our websites or apps. Some of these cookies and technologies are technically necessary to ensure the security, stability and functionality of Our websites and apps, so these cookies or similar technologies must always be enabled.

Furthermore, We may use cookies or similar technologies to analyze your behavior in order to improve Our websites and apps and your user experience. In this case, the processing of your personal data is based on your consent. You therefore decide whether these cookies or similar technologies should be activated.

We may also use cookies or similar technologies on Our websites or apps to show you relevant advertising based on your location, information (e.g. gender, age, hobbies) or behavior on Our apps. In this case, the processing of your personal data is based on your consent. You therefore decide whether these cookies or similar technologies should be activated.

You can find more information about the cookies or similar technologies We use in Our cookie policies. You can also manage your cookie settings in these policies.

• Cookie Policy (Website) applies.
• Cookie Policy (App)

We do not link information from our website with information from our app. This means that your cookie settings in Our app have no influence on your cookie settings on Our website (and vice versa). You must therefore manage your cookie settings for Our websites and apps separately.

4.16. Fraud prevention and prevention of unauthorized or illegal activities

In order to prevent (possible) violations of applicable law, OUR general terms and conditions, OUR User Guideline or other applicable regulations, WE may process certain personal data in order to detect, investigate, process or take action against – e.g. in the context of reports of (possible) violations or to check your content (e.g. images, videos, profile descriptions). For this purpose, WE use, among other things Cloud Vision API from Google, which uses artificial intelligence. In this case, your personal data is processed on the basis of Our legitimate interest.

4.17. Enforcement of rights

We may process your personal data in order to enforce our contractual or legal rights and in the context of judicial or arbitration proceedings (including mediation). This processing is based on Our legitimate interest.

4.18. Legal requirements

We process certain personal data due to legal obligations. This includes, for example, transaction data that We store as part of Our accounting or tax obligations. This may also include information on consents (what consent you have given Us and when). In addition, We may have to disclose personal data to the competent authorities due to legal obligations. In these cases, We adhere to the requirements of the responsible authorities. In this case, your personal data will be processed on the basis of compliance with Our legal obligations.

5. External links and plug-ins

External links (e.g. social media icons, app stores) can be embedded on Our websites or apps. If you click on these links, you will be redirected to the corresponding external website or app. The data protection provisions of these external websites or apps then apply. We are not responsible for the external websites or apps and cannot accept any liability for their content or data processing.

6. Disclosure of personal data to third parties

We may disclose personal data to authorized third parties who perform services on Ourr behalf to enable Us to fulfill the above purposes or because We need these services for Our business. Authorized third parties are, for example, our hosting service provider. The authorized third parties are mainly located in Switzerland or the European Union – but they may also be located in other countries around the world. We contractually oblige Our service providers to process your personal data exclusively on Our behalf and in accordance with Our instructions, and to protect your personal data with appropriate technical and organizational measures. If a recipient of your personal data is located in a country without adequate legal data protection, We contractually oblige this recipient to comply with data protection. For this purpose, We use, among other things, the revised standard contractual clauses of the European Commission if the relevant recipient is not already subject to a legally recognized set of rules to ensure data protection and We cannot base the transfer of your personal data on an exemption clause or provision. An exception may be, for example, legal proceedings abroad, overriding public interest, contract processing or your consent (or if you have made your personal data generally accessible and have not objected to the processing). These contractual measures can partially compensate for the weaker or lack of legal protection in such countries, but they can never eliminate all risks.

Otherwise, We will only disclose your personal data to third parties if you have given your explicit consent or if We are required by law to disclose your personal data, e.g. to a law enforcement agency.

7. How long will my personal data be processed?

We will only process your personal data for as long as We are permitted to do so on the basis of the stated purposes, the statutory retention periods or Our legitimate interest. Furthermore, storage may be required for technical reasons (e.g. if We cannot separate personal data from other data and We have to store this other data). For example, We have a legitimate interest if We need your personal data for evidence purposes or to ensure information security. In principle, We have the following retention periods – however, We may deviate from them in individual cases: We will retain your personal data for 3 months after the deletion of your user account for the protection and security of Our users (e.g. if this personal data is required to prove illegal, unlawful or harmful behavior). In addition to these 3 months, We retain certain personal data due to our legal obligations. For example, We generally retain transaction data for 10 years after the transaction has been completed. Furthermore, We store your consent for at least 5 years after you have deleted your user account with Us. In this way, We can prove compliance with applicable laws. In addition, WE may retain personal data if this is necessary for Our legitimate interest – e.g. to enforce Our rights (e.g. if We want to protect users of Our Products in accordance with Our General Terms and Conditions exclude).

If We no longer need to retain your personal data due to legal or contractual requirements or due to Our legitimate interest, We will delete or anonymize your personal data after the retention period has expired during Our standard processes.

8. What are your rights?

When it comes to your personal data that We process, you have the following rights under applicable data protection laws:

• You can request information from Us as to whether and what personal data We process about you (if you have a user account for Our app, you must make this request via Our app)
• You can request that your personal data is corrected by Us if it is currently incorrect
• You can request that We restrict the processing of your personal data
• You can request the deletion of your personal data
• You can ask Us to provide you with certain personal data in a commonly used electronic format and to transfer it to another controller (if you have a user account for Our app, you must make this request via Our app)
• You can withdraw your consent to the processing of your personal data for the future if Our processing is based on consent
• You can request further information if this information is necessary for the exercise of your rights mentioned here.

If you wish to exercise your rights set out in this section, you can contact US either by post (Latch GmbH, Ebersberg 2, CH-8415 Berg am Irchel) or by e-mail (dataprotection@loviz.app). For these requests, you must send Us a copy of your valid passport or identity cardso that We can prevent abuses. If you have a user account for Our app, you can download your personal data in Our app.

We draw your attention to the fact that certain conditions, exceptions or restrictions (e.g. to protect business secrets) apply to the rights set out in this section under applicable data protection laws. It is therefore possible that We may not be able to fulfill your request in full or at all. We will of course inform you about the conditions, exceptions or restrictions in such cases.

If you do not agree with how We process your personal data or how We handle your rights set out in this section, We kindly ask you to let Us know about it (dataprotection@loviz.app). You can also file a complaint with the competent supervisory authority at your place of residence or work, or at the place where the potential data breach took place. You can find the contact details of the Swiss supervisory authority here. You can find a list of the supervisory authorities of the European Economic Area here.

9. Minors

Our Products are for people who are at least 18 years old. Therefore, We generally do not process any personal data of persons under the age of 18. If persons under the age of 18, for example, create a user account with Us, they violate Our General Terms and Conditions.

10. Data security

We take appropriate technical and organizational measures to protect your personal data against destruction, loss, falsification, manipulation or unauthorized access. Even though We try conscientiously to protect your personal data, we cannot accept any liability for such events.

11. Contact details

You can contact US by post (Latch GmbH, Ebersberg 2, CH-8415 Berg am Irchel) or by e-mail (dataprotection@loviz.app) at any time. We are available to answer your questions.

12. Legal basis

When processing personal data, WE always comply with the Swiss Data Protection Act and – if applicable in certain cases – the Data Protection Act of the European Union or other applicable data protection laws.

13. Amendments and consent

We may adapt this Data Protection Policy at any time due to new circumstances and requirements. The current version of this Data Protection Policy always applies. We always publish the current version in a suitable place.