Effective date: October 6, 2026
1. About the Data Controller
1.1. The data controller responsible for your personal data is VADEKVATE, TOO, a limited liability partnership (TOO) organised under the laws of the Republic of Kazakhstan, BIN 260740039072, 39A Ryskulbekov St., Almaty, Republic of Kazakhstan (the "Company", "we", "us").
1.2. The Vadekvate mobile application, its web version and the website vadekvate.com are together the "Service".
1.3. Contact for all privacy requests: support@vadekvate.com.

2. Applicability and Acceptance of the Policy
2.1. This Privacy Policy explains what personal data we collect when you use the Service, why, on what legal grounds, with whom we share it and what rights you have. It is not intended for citizens of the Russian Federation or CIS countries; if you are such a citizen, please use the policy published at vadekvate.ru/privacy.
2.2. By using the Service you acknowledge this Policy. When you register, you confirm that you have read it and consent to the processing of your personal data as described in it. You may withdraw your consent at any time by writing to support@vadekvate.com. Because the Service cannot be provided without the data needed for your account, withdrawal of consent results in deletion of your account.
2.3. The Service is intended only for persons aged 18 and over.

3. Data Processing Legal Grounds; Personal Data UseWe process personal data on the following legal grounds, to the extent applicable under the law of your country, including Article 6 of the GDPR for Users in the European Economic Area and the United Kingdom:
Performance of a contract (Art. 6(1)(b)) — to create and maintain your account; provide the features of the Service, including showing your profile to other Users, matching and messaging; deliver purchased Paid Features and manage subscriptions; and provide support.
Consent (Art. 6(1)(a)) — for profile verification when you choose to take a photo for it; for approximate location; and for analytics cookies, if used. You can withdraw consent at any time.
Legitimate interests (Art. 6(1)(f)) — to keep the Service safe and prevent fraud, abuse and fake accounts; to moderate content and handle reports; to analyse and improve the Service using aggregated statistics; and to establish, exercise or defend legal claims.
Legal obligation (Art. 6(1)(c)) — to comply with tax, accounting, sanctions and other legal and regulatory requirements, and requests of public authorities that are based on law.
We do not sell your personal data.

4. Personal Data Collection 4.1. Information you provide
Account data: phone number, account identifier.
Profile data: name, date of birth, gender, city, height, education, occupation, marital status, whether you have children, habits, interests, languages, your goal of using the Service and partner preferences and other information you choose to add to your profile; photos, videos and voice messages.
Communications: messages you send to other Users, reports, and your messages to our support team.

4.2. Information collected automatically
Device and technical data: device model, operating system, IP address, installation identifier, language, time zone, and event and error logs.
Usage data: your actions in the Service, such as likes, interactions with features and purchases.
Location: approximate location, only if you allow access in your device settings.
Cookies: the website vadekvate.com uses only strictly necessary cookies. If we introduce analytics cookies, we will do so only with your consent.

4.3. Information from third parties
App stores: confirmation of purchases and the status of subscriptions from Apple or Google. We do not receive your payment card details.

4.4. Verification data
See section 9.

5. Sharing of Personal Data
5.1. Affiliates and service providers. We share personal data with our affiliates and with providers that act on our behalf and under contract, such as cloud storage and hosting, messaging and email providers, and technical support, solely to the extent necessary to provide the Service. They are required to keep the data confidential and secure.
5.2. Other Users. Information in your profile and the content you choose to share is visible to other Users in accordance with your visibility settings. Visibility controls limit display only; they do not stop processing for security, support, billing and legal compliance.
5.3. Apple and Google. Apple and Google process purchases and subscriptions as independent controllers under their own terms and privacy policies. The Company does not hold payment card information.
5.4. Authorities and legal reasons. We may disclose data where required by law or lawful request of a public authority, to enforce our Terms, or to protect the rights, safety and property of our Users, the Company or others.
5.5. Business transfers. If the Company is involved in a merger, acquisition or sale of assets, personal data may be transferred to the successor, which will be bound by this Policy.

6. International Transfers6.1. The Company is established in the Republic of Kazakhstan. Your personal data may be transferred to, stored and processed in Kazakhstan and in other countries where our affiliates and service providers operate, including countries outside your country of residence and, for Users in the EEA and the United Kingdom, outside the EEA and the United Kingdom. These countries may have data protection standards different from those of your country. By giving your consent at registration you agree to these transfers.
6.2. Where the law of your country requires safeguards for such transfers, we rely on your consent, on contractual protections with the recipients, or on other lawful transfer mechanisms. You may request details at support@vadekvate.com.

7. Protection of Personal Data. Security MeasuresWe take legal, organisational and technical measures to protect personal data against unauthorised access, alteration, disclosure and destruction. No system is completely secure, and we cannot guarantee absolute protection. If we become aware of a breach affecting your data, we will notify the competent authority and, where required, you, within the periods established by law.

8. Retention of Information
8.1. We keep personal data for as long as your account exists and as reasonably necessary for the purposes described in this Policy.
8.2. When you delete your account, we delete your account and related data within thirty (30) days. We keep for longer only information that we are required to keep by law (for example, records of purchases for tax and accounting purposes), information needed to handle a pending dispute or investigation, and security logs, and only for as long as necessary.

8.3. How to delete your Vadekvate account and data
You can request deletion of your Vadekvate account and the data associated with it at any time, including if you have uninstalled the application:
in the application: use the Delete account option;
by email: write to support@vadekvate.com with the subject "Delete account" and the phone number of your account; we may ask you to confirm that the account is yours.
8.4. Deleting your account does not cancel a subscription purchased through Apple or Google. Cancel it in your App Store or Google Play settings.

9. Profile Verification
9.1. To keep the Service authentic, we may ask you to verify your profile, for example when you register or replace your main photo, by taking a photo with your device camera to confirm that it matches your profile photos.
9.2. The photo is processed automatically: facial features are compared with those of your profile photos. The image and the data derived from it exist only in the working memory for the duration of the check and are deleted once the result is obtained; they are not written to disk or stored. Only the result ("passed" or "not passed") with date and time is stored.
9.3. Verification is optional. If you decline, the check is not carried out and features that require a verified profile may not be available.

10. User Rights
To the extent provided by the law applicable to you, you have the right to:
Access: obtain confirmation of whether we process your personal data and receive access to it and to information about the processing.
Rectification: have inaccurate or incomplete data corrected without undue delay.
Withdraw consent: at any time, without affecting the lawfulness of processing before withdrawal. Withdrawing consent required to provide the Service may result in deletion of the account.
Erasure: have your data deleted, subject to exceptions for legal obligations and legal claims.
Restriction: restrict processing while accuracy or the lawfulness of processing is being verified or a legal dispute is pending.
Data portability: receive your data in a structured, commonly used and machine-readable format.
Object: object to processing based on legitimate interests.
Complain: lodge a complaint with the data protection authority of your country of residence or of the Republic of Kazakhstan, or with a court.
To exercise a right, write to support@vadekvate.com. We respond within ten (10) business days, or any shorter period required by law, and may ask you to confirm your identity.

11. Children's Privacy and Child Safety Standards (CSAE/CSAM)
11.1. The Service is for adults only. We do not knowingly collect personal data from anyone under 18. If we learn that an account belongs to a person under 18, we delete it with its data.
11.2. We have zero tolerance for child sexual abuse and exploitation (CSAE) and child sexual abuse material (CSAM), including grooming, sextortion and trafficking. Such content, and the accounts responsible, are removed immediately, and where we have actual knowledge of CSAM we preserve the relevant information and report it to the competent authorities and, where applicable, to the relevant national child-protection organisations. These standards apply globally, regardless of where a User is located.
11.3. Report any concern through the in-app support chat, or write to support@vadekvate.com with the subject "Child Safety / CSAM". Reports are reviewed with priority.

12. Cookies
The website vadekvate.com uses only cookies that are strictly necessary for it to work. You can delete or block cookies in your browser settings. If we start using other cookies, we will ask for your consent first and update this Policy.

13. Amendments to the Policy
We may update this Policy from time to time. The current version is always available at vadekvate.com. We will notify you of material changes in the Service or by other available means at least ten (10) calendar days before they take effect. If there is a discrepancy between the English version and a translation, the English version prevails.

14. FeedbackQuestions, requests and complaints about this Policy: support@vadekvate.com, or VADEKVATE, TOO, 39A Ryskulbekov St., Almaty, Republic of Kazakhstan.