Privacy Policy

EliteTreat ApS is the data controller for the processing of the personal data processed in connection with the operation of EliteDulce, unless otherwise expressly stated.

As data controller, we are responsible for ensuring that your personal data is processed in accordance with the General Data Protection Regulation, the Data Protection Act and other relevant legislation.

If you have questions about our processing of personal data, you can contact us by email: info@elitedulce.com.

When you visit, create a profile on or use EliteDulce, we process information about you. The information is used, among other things, to provide the platform, create and manage profiles, enable communication between users, handle payments, send necessary emails, prevent misuse, improve the user experience, comply with legislation and ensure the operation of the platform.

We process personal data only where there is a valid legal basis for processing, and we do not process more data than is necessary for the purposes described in this privacy policy.

If you do not wish us to process the information necessary to provide EliteDulce, you will not be able to create or use a profile on the platform.

We may process the following categories of personal data about you:

3.1 Account and profile information

When you create a profile, we may process information such as:

• email address,
• username,
• age or date of birth,
• gender,
• role on the platform,
• profile text,
• preferences,
• images,
• profile status,
• verification status,
• payment status,
• account settings,
• information you yourself choose to provide on your profile.

You yourself are responsible for ensuring that the information you provide is accurate, lawful and does not infringe the rights of others.

3.2 Information from your use of the platform

When you use EliteDulce, we may process information about your activity on the platform, including:

• login history,
• IP address,
• device information,
• browser type,
• operating system,
• technical identifiers,
• time of visit,
• pages and functions you use,
• interactions with profiles,
• message activity,
• profile views,
• notification history,
• security logging,
• error and operational logs.

This information is used, among other things, for operation, security, troubleshooting, improvement of the platform, prevention of misuse and enforcement of our terms.

3.3 Messages and communication

If you use EliteDulce's messaging features, we process message content, metadata and technical information necessary to provide the feature. Messages are stored in our database at Simply.com. For real-time signals – e.g. that a new message is on its way, online status, notifications and calls – we use Google Firebase (Realtime Database and Authentication).

As a general rule, we do not review private messages manually. However, we may review messages and other communication if it is necessary to enforce our terms, process reports, investigate suspected misuse, prevent illegal activity, protect users or comply with legal obligations.

3.4 Photos, media and verification material

When you upload profile photos, gallery photos, videos, voice messages, stories or Privista content, the files are stored and delivered via Cloudinary. We process the material to display your profile and content, administer the platform, carry out moderation and prevent fake profiles. Uploaded images are automatically screened by Hive (thehive.ai) for nudity and AI-generated content, see section 17. Stories expire automatically and are then deleted.

To message other members you must complete a selfie verification: you upload a selfie holding a sign with “EliteDulce” and today's date. The selfie is reviewed manually by our team, is never shown publicly and is deleted 30 days after the decision. ID verification is optional and is only offered when the feature is switched on; it takes place at Veriff, where images of your ID document and facial images (including a liveness check) are processed, and an approved ID verification gives an extra badge on your profile. Finally, you can optionally have your income or occupation verified by uploading documentation, e.g. an employment contract or annual tax statement. The documents are stored as private files at Cloudinary, which can only be accessed with separate authorisation, and are reviewed by our administrators.

3.5 Payment information

When you purchase subscriptions, credits, access to features or other digital services, payment information is processed through our payment provider Stripe.

We process information such as:

• payment status,
• transaction ID,
• order number,
• time of purchase,
• purchased services,
• amount,
• subscription status,
• billing information, if relevant,
• limited payment information, for example card type and the last four digits, if these are made available by the payment provider.

We do not store your full payment card details on our own systems. Payment card details are processed by Stripe and relevant acquirers/payment partners.

3.6 Support and enquiry information

When you contact us, we may process:

• name or username,
• email address,
• subject of the enquiry,
• the content of your message,
• history of previous enquiries,
• technical information relevant to support,
• documentation that you send to us yourself.

This information is used to answer your enquiry, provide support, document communication and improve our service.

3.7 Marketing and analytics information

If you consent to cookies or marketing, we may process information about:

• visits to the website,
• traffic channels,
• campaign sources,
• advertisements you have interacted with,
• conversions,
• user behaviour on the website,
• aggregated statistics,
• cookie IDs and similar online identifiers.

This information is used for analytics, statistics, marketing, conversion measurement, optimisation of advertisements and improvement of the website.

3.8 Location

We process the location you provide yourself and may estimate an approximate location from your IP address via ipinfo.io. Other members only see your location approximately – rounded to about 1 km – and the “near you” feature uses the location stored on your own profile. You can hide your location under Settings → Privacy.

3.9 AI features

EliteDulce offers optional AI features: suggestions for profile text, opening messages and replies. The features are provided by OpenAI and are only used when you choose them. Only your own text and non-identifying profile details (age, profile type, interests and public answers to profile prompts) are sent. The other person's messages are not sent.

EliteDulce is a dating platform. Your profile type (established or ambitious man/woman) and who you are looking for may reveal your sexual orientation or sexual preferences and are therefore special categories of personal data under Article 9 of the GDPR. The same may apply to information you choose to write on your profile or in messages.

We encourage you not to share more sensitive or private information than necessary.

We process your profile type and who you are looking for on the basis of your explicit consent, which you give when creating your profile in a separate checkbox. The consent is recorded with version and timestamp.

Processing this information is a precondition of the service, because profiles are shown and matched on the basis of it. You therefore withdraw your consent by deleting your profile under Settings → Account → Delete account. You can change or delete other information on your profile at any time, to the extent the features allow.

Selfie verification involves processing facial images, which are reviewed manually. In an optional ID verification at Veriff — when offered — your face is automatically compared with the photo in your ID document, which is processing of biometric data.

We process personal data for the following purposes:

1. 1. to create and administer user accounts,
2. 2. to deliver EliteDulce's functions and services,
3. 3. to display profiles and enable interaction between users,
4. 4. to enable messages, notifications and platform communication,
5. 5. to administer subscriptions, purchases and payments,
6. 6. to send transactional emails, system emails and necessary service notifications,
7. 7. to provide customer support,
8. 8. to carry out profile and image moderation,
9. 9. to verify profiles and reduce the risk of fake profiles,
10. 10. to prevent fraud, abuse, spam, harassment, prostitution, illegal activities and violation of our terms,
11. 11. to ensure the technical operation and security of the platform,
12. 12. to analyse the use of the website and improve the user experience,
13. 13. to measure the effect of marketing and advertising,
14. 14. to send marketing if you have given consent,
15. 15. to comply with accounting, tax, consumer, payment and data protection law obligations,
16. 16. to document, establish, exercise or defend legal claims.

We do not use your personal data for other incompatible purposes without a valid legal basis for processing.

We process your personal data on the following legal bases:

6.1 Performance of a contract

We process information when it is necessary to perform the agreement with you, including in order to:

• create and administer your profile,
• provide access to the platform,
• provide free and paid functions,
• process purchases and subscriptions,
• send necessary service emails,
• handle support concerning your account.

6.2 Legitimate interests

We process information when it is necessary for our legitimate interests, unless your interests or fundamental rights override them.

Our legitimate interests include, among other things:

• operation and improvement of the platform,
• technical security,
• prevention of fraud and abuse,
• enforcement of terms,
• moderation of content,
• handling of reports,
• customer support,
• documentation of communication,
• analysis of the platform's functions,
• protection of users and the platform's integrity.

6.3 Consent

We process information on the basis of consent where required, including for:

• non-essential cookies,
• Google Analytics, where consent is required,
• Google Ads cookies and conversion tracking, where consent is required,
• newsletters and marketing,
• your profile type and who you are looking for, which may reveal your sexual orientation (Article 9(2)(a)), as well as other sensitive information that you voluntarily choose to provide or publish.

You may withdraw your consent at any time. The withdrawal of consent does not affect the lawfulness of the processing carried out prior to the withdrawal.

6.4 Legal obligation

We process information where it is necessary to comply with legal obligations, including:

• accounting rules,
• tax rules,
• payment documentation,
• consumer-law requirements,
• requirements from public authorities,
• obligations under data protection legislation.

6.5 Legal claims

We may process information where it is necessary to establish, exercise or defend legal claims.

EliteDulce uses cookies and similar technologies on the website.

Cookies are small text files that are stored on your device via your browser. Cookies may, among other things, be used to make the website function, remember your choices, measure traffic, improve the user experience, analyse usage patterns and target or measure advertising.

Cookies can be divided into the following categories:

7.1 Essential cookies

Essential cookies are necessary for the website and the platform to function correctly. They may, among other things, be used for login, security, payment, session management and basic functionality.

These cookies may, as a general rule, be used without consent because they are necessary to provide the service you have requested.

7.2 Statistics cookies

Statistics cookies are used to understand how visitors use the website, so that we can improve content, features and the user experience.

We use Google Analytics for analytics and statistics if you give your consent thereto.

7.3 Marketing cookies

Marketing cookies are used to measure the effect of advertisements, optimise campaigns and display more relevant advertisements.

We use Google Ads, formerly known as Google AdWords, for advertising and conversion tracking if you give your consent thereto.

Google Ads may use cookies or similar technologies to register whether a user who has clicked on an advertisement subsequently performs an action on the website, for example creates a profile or completes a purchase.

7.4 Opting out of and deleting cookies

You can change or withdraw your cookie consent at any time via the “Cookie settings” link at the bottom of the page.

You may also delete or block cookies in your browser. If you block essential cookies, parts of the website or platform may cease to function correctly.

We use Google Analytics to collect statistics on the use of our website and platform, including information on traffic, visits, usage patterns, devices, pages and general interaction.

The purpose is to understand how the website is used, improve the user experience, optimise technical operation and develop better features.

Google Analytics is only loaded if you have consented to statistics cookies. IP addresses are anonymised and data is processed in Google's EU region.

Information collected via Google Analytics may be processed by Google in accordance with Google's own terms and data processing conditions.

We use Google Ads for marketing, campaign management and conversion tracking.

Google Ads may be used to measure whether advertisements lead to actions on the website, for example profile creation, purchase, subscription start or other relevant activity.

Processing for Google Ads, including the use of marketing cookies, takes place only to the extent that it is lawful and, where necessary, on the basis of your consent.

If we use enhanced conversion tracking or similar functions, certain information, for example an email address, may be processed in hashed form for the purpose of conversion tracking. This only takes place if the function is enabled, and the processing is carried out in accordance with applicable data protection rules.

We send emails via Simply.com's mail servers (SMTP) and, where configured, via Resend (email API).

Emails are used for, among other things:

• account activation,
• login and security emails,
• verification emails,
• payment confirmations,
• subscription emails,
• notifications,
• support-related emails,
• operational messages,
• marketing, if you have given your consent.

When we send emails, Simply.com and, where applicable, Resend process information such as email address, name or username, email content, delivery time, delivery status, technical information and any error messages.

Simply.com and Resend act as data processors for us to the extent they process information on our behalf.

Our lifecycle emails (e.g. welcome and reminder emails) contain a small tracking pixel that records whether and when the email is opened. The unsubscribe page and certain emails load fonts from Google Fonts, which sends your IP address to Google.

We use Stripe as a payment gateway to process payments.

Stripe may process information necessary to complete payments, including payment card details, transaction information, amount, time, payment status and technical payment data.

As a rule, we do not receive your full payment card details. Card payments and other payment methods are handled by Stripe and the relevant payment partners.

We process only the payment information necessary to administer your purchase, your subscription, your access to paid features, accounting, documentation, support and any handling of objections or chargebacks.

When the mobile app is available, purchases in the app (in-app purchases) are made via the Apple App Store or Google Play, which process the payment under their own terms and privacy policies. We receive information about the purchase, but not your payment details.

We may share or entrust personal data to third parties where it is necessary to provide EliteDulce, comply with the law or protect our rights.

We use, among others, the following providers:

• Simply.com (Denmark) – hosting, database and sending of emails via SMTP.
• Resend – sending of transactional emails via API, where configured.
• Stripe – payments and subscriptions.
• Veriff (Estonia, EU) – optional ID verification, when offered: images of ID documents and biometric facial comparison.
• Cloudinary (USA) – storage and delivery of profile photos, gallery photos, videos, voice messages, stories and Privista content, as well as documents for income and occupation verification, which are stored as private files that can only be accessed with separate authorisation.
• Google Firebase (Google, USA) – Realtime Database and Authentication for real-time chat signals, online status, notifications and calls.
• OpenAI (USA) – optional AI features (profile text, suggestions for opening messages and replies), see section 3.9.
• Hive / thehive.ai (USA) – automatic screening of uploaded images for nudity and AI-generated content.
• Cloudflare Turnstile (USA) – bot protection at login and sign-up when enabled; processes IP address and device signals.
• ipinfo.io (USA) – approximate location from your IP address.
• Apple App Store and Google Play – in-app purchases, when the mobile app is available.
• Google Analytics – statistics, only with your consent; IP addresses are anonymised and data is processed in Google's EU region.
• Google Ads – advertising and conversion measurement, only with your consent.
• Google Fonts (Google, USA) – fonts on the unsubscribe page and in certain emails; your IP address is sent to Google.
• Advisers – for example auditors, lawyers or IT security advisers, if necessary.

Data processors may only process personal data in accordance with our instructions and pursuant to data processing agreements, where this is required.

We may also disclose information to public authorities, courts, the police or other relevant parties if we are legally obligated to do so, or if it is necessary to prevent or investigate unlawful conduct.

Several of our providers are US companies or use sub-processors outside the EU/EEA, including Cloudinary, Google (Firebase, Analytics, Ads and Fonts), OpenAI, Hive, Cloudflare, ipinfo.io, Stripe and Resend. Personal data may therefore be transferred to the USA.

Transfers to the USA are based on the EU–US Data Privacy Framework where the provider is certified, and otherwise on the European Commission's standard contractual clauses. In general, we ensure that a valid transfer basis exists, for example:

• the European Commission's standard contractual clauses,
• an adequacy decision,
• supplementary safeguards,
• or another lawful basis for transfer under the data protection rules.

You may contact us if you would like further information about the basis for transfer for the relevant providers.

We store personal data only for as long as it is necessary for the purposes for which the data was collected, or for as long as we are obligated to under the law.

As a rule, the following applies:

• Account and profile information is stored for as long as you have an active profile. If you delete your account, it is hidden immediately and anonymised after 30 days: email, username, name, profile texts, photos, the text of messages you have sent, likes, notifications and verification material are deleted.
• Photos and other media are stored for as long as the profile is active, unless you delete them earlier. Stories expire automatically and are deleted.
• Messages are stored for as long as necessary to provide the messaging feature. The text of messages you have sent is deleted when your account is anonymised.
• Bookkeeping records of purchases, payments and Dulces transactions are kept even after account deletion for as long as the Danish Bookkeeping Act requires – as a rule for 5 years.
• Support inquiries are stored for as long as it is necessary to handle the inquiry, document the process and address any subsequent questions.
• Security events are stored for 180 days, and expired or revoked login sessions are deleted after 90 days.
• Cookie and analytics data are retained in accordance with our cookie settings and the retention periods of the relevant providers.
• Login codes are deleted 24 hours after they have been used or have expired.
• Verification selfies are deleted 30 days after the decision.
• Bug reports are stored for 180 days.
• Logs of sent emails are stored for 13 months.
• App event logs are stored for 180 days.
• Server logs are stored for 30 days.

When information is no longer necessary, it is deleted or anonymised, unless continued retention is necessary in order to comply with legislation, document a claim or protect EliteDulce or our users.

We have implemented appropriate technical and organisational security measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure and unauthorised access.

These measures may include, among other things:

• encrypted connection via HTTPS,
• access control,
• restriction of employee access,
• logging and monitoring of security incidents,
• firewall and technical security measures,
• ongoing maintenance and updates,
• internal procedures for handling personal data,
• use of professional data processors and providers.

Only persons with a legitimate need have access to personal data, and such persons are subject to confidentiality.

EliteDulce is not intended for persons under the age of 18.

Persons under the age of 18 are not permitted to create a profile, use the platform or communicate with other users via EliteDulce.

We do not knowingly collect personal data about minors. If we become aware that a person under the age of 18 has created a profile or provided personal data, we will take steps to delete the profile and the relevant information.

In the event of suspicion of unlawful conduct, exploitation, grooming, abuse or other serious content involving minors, we may retain relevant information and report the matter to the police or other relevant authorities.

EliteDulce may use technical systems to suggest profiles, sort content, improve relevance, detect suspicious activity and protect the platform against abuse.

We do not make decisions that produce legal effects concerning you or similarly significantly affect you based solely on automated processing, unless this is lawful and necessary.

Uploaded profile and gallery photos are automatically screened by Hive for nudity and AI-generated content. With a high score, the photo is automatically hidden until a moderator has reviewed it; with a lower score, it is flagged for manual review. A moderator can always reverse an automatic hiding.

Under the data protection rules, you have a number of rights.

Among other things, you have the right to:

1. 1. Access – you can request access to the personal data we process about you.
2. 2. Rectification – you can have inaccurate information corrected.
3. 3. Erasure – in certain cases you can have information deleted.
4. 4. Restriction – in certain cases you can have the processing restricted.
5. 5. Data portability – in certain cases you can receive your information in a structured, commonly used and machine-readable format.
6. 6. Objection – in certain cases you can object to our processing.
7. 7. Withdrawal of consent – if the processing is based on consent, you can withdraw your consent at any time.

If you wish to exercise your rights, you can contact us by email: info@elitedulce.com. There is currently no self-service data export, so requests for access and data portability are handled manually when you contact us.

We may ask you to verify your identity, where necessary to ensure that information is not disclosed to unauthorised parties.

You can delete your account yourself under Settings → Account → Delete account. You can change or withdraw your cookie consent via the “Cookie settings” link at the bottom of the page. You withdraw your consent to the processing of your profile type and who you are looking for (section 4) by deleting your account.

If you are dissatisfied with our processing of your personal data, you can contact us.

You also have the right to lodge a complaint with Datatilsynet:

Datatilsynet

Carl Jacobsens Vej 35

2500 Valby, Danmark

www.datatilsynet.dk

We may amend this privacy policy if necessary as a result of changes in legislation, case law, our processing of personal data, the platform's features, the use of providers or for other legitimate reasons.

The privacy policy in force at any given time is available on EliteDulce. In the event of significant changes, we may notify you, for example by email, notification or clear information on the platform.

We encourage you to keep yourself informed on an ongoing basis about the privacy policy in force.

Questions regarding this privacy policy or our processing of personal data may be directed to:

EliteTreat ApS

E-mail: info@elitedulce.com

Adresse: Enghavevej 182, 3. tv., 2450 København SV

CVR-nr.: 46250559