Privacy notice — launch candidate

Controller and contact

The controller is Malcolm Aber, an individual trading as DoubleYes and established in Malta. No company-registration or VAT number applies at this stage. Privacy requests may be sent to the monitored mailbox info@doubleyes.eu.

Public geographic service address: Triq il-Bistra, Mosta, Malta. No data protection officer has been appointed for Stage 1; the need for one will be reassessed before processing reaches a scale that could trigger that requirement.

Information collected in Stage 1

• Account data: verified email address, provider identifiers, account status, session and authentication security information.
• Identity and eligibility data: legal and public first names, surname, date of birth, age, city, country and declared gender. Legal name and full date of birth are kept private.
• Profile data: relationship intention and status, languages, physical and lifestyle traits, interests, family information, biography and a private main photograph.
• Preference data: gender, age, location and other compatibility preferences, including required, preferred and no-preference choices.
• Special-category or sensitive inferences: profile answers and preferences may reveal or indicate sexual orientation, religion, health, ethnicity or philosophical beliefs.
• Governance data: versions and hashes of legal notices, consent and withdrawal events, marketing choice, registration progress, moderation decisions and account-status history.
• Attribution data: referral code, first landing path, referrer host, campaign source, medium and campaign name where supplied by the browser URL or referral link.
• Technical and security data: request time, route, network and device information made available by normal web protocols, rate-limit identifiers, errors and security events.
• Correspondence: messages, requests, complaints and the minimum identity evidence needed to deal with them.

Required and optional information

A verified email address, adult date of birth, core identity and location fields, required profile fields, compatibility preferences, current terms acceptance, privacy acknowledgement and explicit sensitive-data consent are needed to prepare a Stage 1 dating profile. If they are not provided, DoubleYes cannot create or retain that profile.

Fields marked optional, marketing consent and campaign parameters are not required for registration. Optional profile answers may be left blank where the form permits. Technical security data is generated automatically when the service is used.

Purposes and legal bases

• Create and operate a requested Stage 1 account and private profile: steps before and performance of the user agreement under GDPR Article 6(1)(b).
• Protect accounts, prevent abuse, secure infrastructure, moderate content and keep proportionate audit evidence: legitimate interests under Article 6(1)(f), balanced against user rights.
• Meet legal, regulatory, safeguarding and law-enforcement obligations: Article 6(1)(c), and Article 6(1)(e) only where a relevant public-interest task lawfully applies.
• Process profile information that reveals special-category data: explicit consent under Article 9(2)(a). This consent is separate from accepting the terms.
• Send optional product news or marketing: consent under Article 6(1)(a) and applicable electronic-communications rules. Refusal does not prevent registration and consent may be withdrawn at any time.
• Measure referral and launch-campaign effectiveness using limited attribution fields: legitimate interests under Article 6(1)(f), without cross-site behavioural tracking or advertising profiles.

Recipients and service providers

Access is limited to authorised personnel and providers that need information for a defined purpose. Stage 1 uses an EU-hosted Supabase production project for authentication, database and private photo storage; Google Workspace for the info@doubleyes.eu contact mailbox; and controller-operated application, reverse-proxy, monitoring and encrypted-backup infrastructure. Brevo is selected and configured for transactional email, but production application delivery remains disabled pending the remaining contract, transfer, retention, counsel and browser-authentication gates.

Professional advisers, regulators, courts, emergency services or law-enforcement bodies may receive limited information where lawfully necessary. DoubleYes does not sell profile information and does not use it for third-party advertising.

International transfers

The production Supabase project is deployed in an EU region. Project-level region evidence, provider contracts, subprocessors and any non-EEA support or delivery access still require inclusion in the final approval record. Where the GDPR requires a transfer mechanism, DoubleYes will rely on an adequacy decision, approved standard contractual clauses or another lawful safeguard and assess supplementary measures where needed.

The final processor and transfer register, contracts and professional confirmation of the published service-address wording must be completed before Stage 1 registration opens. A person may request information about the applicable transfer safeguard, including how to obtain a copy where legally available, through info@doubleyes.eu.

Retention and deletion

• Proposed target — incomplete Stage 1 accounts and private profile drafts: while actively used, then reviewed after 12 months without sign-in or update, with a warning and reasonable retention choice where contact remains possible.
• Proposed target — account and private profile content after an authenticated deletion request: restrict access promptly and complete erasure or irreversible anonymisation within 30 days, unless a documented legal, security, fraud or safeguarding hold applies.
• Retention control — a replaced profile photograph becomes superseded and is queued for deletion after a 24-hour safety window. A documented moderation or legal hold pauses deletion and must be reviewed within 90 days.
• Retention control — a rejected main photograph remains private and unusable for submission, and is queued for deletion 30 days after rejection if it has not been replaced and is not subject to a documented hold.
• Proposed target — routine application and reverse-proxy security logs: up to 90 days; security incidents and investigation records: up to 24 months after closure where proportionate.
• Proposed target — support, rights requests, complaints and attribution records: up to 24 months after closure or collection; longer only where needed for an active dispute or legal obligation.
• Proposed target — consent, terms-acceptance and essential account-status evidence: up to six years after the account ends to establish, exercise or defend legal claims, with content minimised and access restricted.
• Retention control — encrypted operational backups use rolling 30-day retention while preserving at least seven verified generations. Registration remains closed until independent/off-site retention, hold handling and restore-time erasure controls are operationally accepted.

Your rights

Depending on the circumstances, you may request access, correction, erasure, restriction, portability or objection, and you may withdraw consent without affecting earlier lawful processing. You also have the right not to be subject to a qualifying solely automated decision with legal or similarly significant effects. Stage 1 does not make live matching or activation decisions solely by automated means.

Send a request to info@doubleyes.eu. DoubleYes may ask for proportionate verification and will normally respond within one month, subject to the lawful extensions and exceptions in the GDPR. You may complain to Malta's Office of the Information and Data Protection Commissioner or another competent European supervisory authority.

Security and changes

Controls include encrypted transport, private storage, restricted administrative access, multifactor authentication for operational administration, rate limits, append-only or tightly guarded security evidence, encrypted backups and tested fail-closed feature gates. No system is risk-free; confirmed personal-data breaches will be assessed and notified where the law requires.

Material changes will be published with a new version and effective date. Where a change affects the basis or reasonable expectations for processing, a fresh acknowledgement or consent will be requested as required.