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Privacy Policy

Last updated: June 16, 2026

SilentSpark ("we", "us", "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, and protect your personal data when you use our application and services.

1. Data Controller

The data controller responsible for your personal data is:

Andreas Hubenthal
Adalbert-Stifter-Straße 6
36199 Rotenburg, Germany
Email: andreas.hubenthal@gmail.com

2. What Data We Collect

SilentSpark is designed with privacy by design and by default. We minimize data collection to the absolute minimum necessary to provide the service.

2.1 Data You Provide

• Name — An optional display name you choose (not your real name). Stored locally on your device via browser local storage (LocalStorage).
• Join Code — A randomly generated 8-character code used to pair two devices. Not linked to any personal identity.
• Chat Messages — Text messages exchanged during an active match. Stored temporarily and automatically deleted when the match ends or expires.

2.2 Data Collected Automatically

• IP Addresses — Logged in server access logs for security and abuse prevention. Automatically rotated and purged.
• Device Tokens — Push notification tokens (if you enable notifications). Used solely to deliver match and message notifications.
• Socket.IO Data — Real-time connection data used to detect matches and deliver messages. Not stored persistently.

2.3 Special Categories of Data (Art. 9 GDPR)

SilentSpark facilitates intimate communication between partners. Under the EU General Data Protection Regulation (GDPR), this constitutes processing of special categories of personal data relating to sexual life (Art. 9(1) GDPR).

We process this data only with your explicit consent (Art. 9(2)(a) GDPR), which you provide when you first use the application by checking the consent checkbox. You may withdraw this consent at any time by disconnecting from your couple or deleting the application.

3. How We Use Your Data

• To facilitate match detection between partners
• To deliver real-time messages during active matches
• To send push notifications (only if enabled by you)
• To ensure security and prevent abuse

4. Data Storage & Retention

• Chat messages are deleted immediately when a match ends or expires — no exceptions.
• Mood signals (taps) are processed in real-time and never stored permanently. Unmatched signals are discarded instantly.
• Server logs (IP addresses) are rotated regularly.
• Device tokens are deleted when you disconnect from your couple or revoke notification permissions.

When you leave a couple or disconnect, all your data is permanently and irreversibly destroyed.

5. Data Hosting & International Transfers

SilentSpark's primary application infrastructure is hosted on ISO 27001 certified servers in Frankfurt, Germany. All core data is processed and stored within the European Union.

For the sole purpose of delivering push notifications (if actively enabled by you), encrypted device tokens may be processed by Google (Firebase Cloud Messaging). Google LLC is based in the United States and is certified under the EU-US Data Privacy Framework, ensuring an adequate level of data protection in compliance with GDPR requirements.

6. Data Sharing

We never sell, trade, or share your personal data with third parties. The only data sharing that occurs is:

• Between partners — Your chosen name and messages are visible to your matched partner during an active match only.
• Push notification providers — Firebase Cloud Messaging (Google) or web push services deliver notifications on our behalf. These providers act as data processors under our strict instructions.

7. Your Rights Under GDPR

As a user, you have the following rights:

• Right of Access (Art. 15) — Request a copy of all personal data we hold about you.
• Right to Erasure (Art. 17) — Request immediate deletion of all your personal data.
• Right to Data Portability (Art. 20) — Receive your data in a structured, machine-readable format.
• Right to Withdraw Consent (Art. 7) — Withdraw your consent to data processing at any time.
• Right to Object (Art. 21) — Object to processing of your personal data.
• Right to Lodge a Complaint — File a complaint with your local data protection authority.

Please note: Since SilentSpark does not utilize user accounts, email addresses, or real names, we generally cannot link any temporary server logs or session data to a specific natural person. To exercise your rights, you may need to provide additional identifiers (such as your current local Join Code) to help us verify and locate your data. To exercise any of these rights, contact us at andreas.hubenthal@gmail.com.

8. Cookies & Local Storage

SilentSpark uses browser local storage (LocalStorage) and a service worker for offline functionality. We do not use tracking cookies.

We use Plausible Analytics, a self-hosted, cookie-free analytics service that is fully GDPR-compliant. Plausible does not use cookies, does not collect personal data, and all analytics data is processed and stored on our own servers within the European Union.

To improve our service, we track anonymous usage events (e.g., feature interactions) via Plausible. These events contain no personal data, no IP addresses, and cannot be linked to individual users.

• LocalStorage stores your chosen name and join code locally on your device for convenience.
• Service Worker enables offline access and push notifications. It caches static assets only — no personal data.

9. Children's Privacy

SilentSpark is not intended for users under the age of 18 (or the applicable age of majority in your jurisdiction). We do not knowingly collect data from minors. If we become aware that a minor is using our service, we will immediately delete their data.

10. Security

We implement appropriate technical and organizational measures to protect your data, including:

• Encrypted data in transit (TLS/HTTPS)
• Authentication tokens for API access
• Rate limiting and abuse prevention
• Regular security audits

11. Changes to This Policy

We may update this Privacy Policy from time to time. Significant changes will be communicated through the application. The "Last updated" date at the top indicates when the policy was last revised.

12. Contact

For privacy-related inquiries, please contact:

andreas.hubenthal@gmail.com