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Privacy Policy

Last Updated: September 30, 2026

1. Introduction

This Privacy Policy describes how EMOTIQ SOCIAL LABS LTD ("we," "us," or "our") collects, uses, shares, and protects personal data in connection with Soul-meet.io (soul-meet.io) and related services (collectively, the "Service").

We are committed to protecting your privacy and handling your personal data responsibly. This Privacy Policy is designed to comply with the General Data Protection Regulation (GDPR) (EU) 2016/679, the UK GDPR, applicable US state privacy laws (including the California Consumer Privacy Act / CPRA), and other relevant data protection regulations.

By using the Service, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with the practices described here, please do not use the Service.

2. Data Controller Information

The data controller responsible for your personal data is:

EMOTIQ SOCIAL LABS LTD

1, Konstantinou Skokou Capital Chambers, 2nd Floor, 1061 Nicosia, Cyprus

Data Protection Officer: support@soul-meet.io

General Privacy Contact: support@soul-meet.io

We have designated a Data Protection Officer (DPO) to oversee compliance with applicable data protection laws. You may contact our DPO directly at support@soul-meet.io with any questions regarding our data processing practices.

3. Personal Data We Collect

3.1 Data You Provide Directly

When you register for and use the Service, you provide us with:

  • Account registration data: email address, username, password (stored in hashed form);

  • Age verification data: your confirmation that you are 18 years of age or older and, where additional verification is required by applicable law, the verification inputs described in Section 3.4;

  • Payment information: billing address, payment card details (processed by our third-party payment processors — we do not store full card numbers);

  • Communications: messages you send to our AI companions, customization preferences, feedback, and support correspondence;

  • Profile data: preferences, AI persona configurations, and subscription choices.

3.2 Data Collected Automatically

When you use the Service, we automatically collect certain technical data:

  • Device information: device type, operating system, browser type and version;

  • Log data: IP address, access timestamps, pages viewed, referring URLs;

  • Usage data: features accessed, session duration, interaction patterns;

  • Session recordings: we use session replay technology provided by Amplitude (Amplitude Session Replay) that records how you interact with the Service, such as clicks, scrolling, page navigation and the content displayed on the pages you visit. Text entered into input fields and other elements designated as sensitive are masked before the recording is transmitted;

  • Cookies and similar technologies: session cookies, analytics cookies, preference cookies (see Section 8 and our Cookie Policy).

3.3 Special Category Data

Due to the nature of the Service, your use may reveal information relating to your sexual preferences or lifestyle. This is considered special category (sensitive) personal data under the GDPR. We process this data only on the basis of your explicit consent, which you grant by choosing to use the relevant features of the Service. You may withdraw consent at any time, though this may limit your access to certain features.

3.4 Data We Do Not Collect

We do not knowingly collect personal data from individuals under the age of 18. We do not collect government-issued ID numbers (except where specifically required for age verification by applicable law, in which case such data is processed by a verified third-party age verification provider). We do not collect financial account passwords.

4. How We Use Your Personal Data

4.1 Purposes and Legal Bases (GDPR)

We process your personal data for the following purposes, relying on the indicated legal bases:

Providing the Service (Legal basis: Performance of a contract):

  • Creating and managing your account;

  • Enabling AI companion interactions and generating personalized content;

  • Processing payments and managing subscriptions;

  • Providing customer support.

Compliance with legal obligations (Legal basis: Legal obligation):

  • Age verification requirements;

  • Responding to law enforcement or regulatory requests;

  • Maintaining records required by applicable law.

Legitimate interests (Legal basis: Legitimate interests):

  • Improving, developing, and personalizing the Service;

  • Preventing fraud, abuse, and unauthorized access;

  • Ensuring platform security and integrity;

  • Communicating important service updates.

Marketing communications (Legal basis: Consent):

  • Sending promotional emails and newsletters (where you have opted in);

  • Personalized advertising (where consented).

Analytics and session recordings (Legal basis: Consent):

  • Measuring and analysing the use of the Service with Google Analytics and Amplitude, including the session recordings described in Section 3.2.

Sensitive data processing (Legal basis: Explicit consent):

  • Processing data that may reveal sexual preferences in connection with adult content features.

4.2 AI Interaction Data

Conversations with AI companions are processed to generate responses in real-time. We may also use de-identified or aggregated interaction data to improve our AI models. We do not sell or share your conversation content with third parties for their marketing purposes. Conversation data may be reviewed by authorized personnel for safety, moderation, and quality assurance purposes.

5. Sharing and Disclosure of Personal Data

We do not sell your personal data. We may share your data with:

5.1 Service Providers

We engage trusted third-party service providers to assist in operating the Service, including:

  • Payment processors and payment service providers (such as Centrobill) — for billing, payment processing and fraud prevention;

  • Cloud hosting and infrastructure providers — for data storage and service delivery;

  • Analytics providers (Google Analytics and Amplitude, including Amplitude Session Replay) — for understanding usage patterns and improving the Service;

  • Advertising partners (Meta Platforms and Google Ads) — for measuring the effectiveness of our advertising, only with your consent where required by applicable law;

  • Security providers (Amazon Web Services WAF) — for bot protection and preventing fraud and abuse;

  • Age verification services — to fulfill legal obligations;

  • Email delivery services — for transactional and marketing communications;

  • AI infrastructure providers — for model processing and generation.

All service providers are bound by data processing agreements and are required to process data only as instructed by us and in compliance with applicable law.

5.2 Legal Requirements

We may disclose personal data when required to do so by applicable law, court order, regulatory authority, or law enforcement request. We will notify you of such disclosures where legally permitted to do so.

5.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of assets, your personal data may be transferred to a successor entity. We will notify you and provide choices regarding your data prior to any such transfer where required by applicable law.

5.4 Aggregate Data

We may share aggregated, anonymized, or de-identified data that cannot reasonably be used to identify you, for research, analytics, or business development purposes.

6. International Data Transfers

As a Cyprus-registered company serving users globally, your personal data may be transferred to and processed in countries outside the European Economic Area (EEA). When we transfer data outside the EEA, we ensure appropriate safeguards are in place, including:

  • Standard Contractual Clauses (SCCs) approved by the European Commission;

  • Adequacy decisions by the European Commission where applicable;

  • Data Processing Agreements incorporating appropriate technical and organizational measures.

For US users, data processed in the EEA is subject to GDPR protections. For a copy of the safeguards applicable to your data transfer, please contact us at support@soul-meet.io.

7. Data Retention

We retain personal data only as long as necessary for the purposes described in this Privacy Policy, or as required by applicable law. Specifically:

  • Account data: retained for the duration of your account and deleted within 90 days of account deletion;

  • Payment records: retained for up to 7 years as required by applicable tax and financial laws;

  • Conversation data: retained for up to 12 months, after which it is anonymized or deleted;

  • Log and technical data: retained for up to 6 months;

  • Legal hold data: retained as required where data is subject to ongoing legal proceedings.

You may request deletion of your personal data at any time, subject to our legal obligations to retain certain records. See Section 9 for details on your rights.

8. Cookies and Tracking Technologies

8.1 Types of Cookies We Use

We use the following categories of cookies:

  • Essential cookies: required for the Service to function (authentication, security, session management);

  • Analytical/performance cookies: help us understand how users interact with the Service (Google Analytics and Amplitude, including Amplitude Session Replay);

  • Functional cookies: remember your preferences and settings;

  • Marketing cookies: used to measure and deliver relevant advertising (Meta Pixel, Google Ads) (only with your consent).

8.2 Your Cookie Choices

Non-essential cookies require your consent. You may withdraw your consent at any time by deleting cookies and blocking non-essential cookies in your browser settings, by using the opt-out tools described in our Cookie Policy (available at soul-meet.io/docs/cookie-policy), or by contacting us at support@soul-meet.io. Disabling certain cookies may affect the functionality of the Service.

9. Your Privacy Rights

9.1 Rights Under GDPR (EU/UK Users)

If you are located in the EU or UK, you have the following rights:

  • Right of access: obtain a copy of your personal data and information about how it is processed;

  • Right to rectification: request correction of inaccurate or incomplete data;

  • Right to erasure ('right to be forgotten'): request deletion of your data in certain circumstances;

  • Right to restrict processing: request limitation of processing in certain circumstances;

  • Right to data portability: receive your data in a structured, machine-readable format;

  • Right to object: object to processing based on legitimate interests or for direct marketing;

  • Right to withdraw consent: withdraw consent at any time where processing is based on consent;

  • Right to lodge a complaint: lodge a complaint with your national data protection authority.

9.2 Rights Under US Law (California and Other States)

If you are a California resident, you have rights under the CCPA/CPRA, including:

  • Right to know: request disclosure of personal data collected, used, and shared;

  • Right to delete: request deletion of personal data, subject to certain exceptions;

  • Right to correct: request correction of inaccurate personal data;

  • Right to opt out of sale or sharing: we do not sell personal data; if we share data for targeted advertising, you may opt out;

  • Right to limit use of sensitive personal information;

  • Right of non-discrimination: we will not discriminate against you for exercising your rights.

Users in other US states may have additional rights under applicable state law. We honor rights requests in accordance with applicable law.

9.3 How to Exercise Your Rights

To exercise any of the rights described above, please contact us by email at support@soul-meet.io, preferably from the email address associated with your account. The account dashboard does not currently provide a function for submitting privacy requests. We will respond within 30 days (GDPR) or 45 days (CCPA). We may need to verify your identity before processing your request.

10. Data Security

We implement appropriate technical and organizational security measures to protect your personal data from unauthorized access, disclosure, alteration, or destruction. These include:

  • Encryption of data in transit using TLS/SSL protocols;

  • Encrypted storage of passwords using industry-standard hashing algorithms;

  • Access controls limiting data access to authorized personnel on a need-to-know basis;

  • Regular security assessments and penetration testing;

  • Employee training on data protection and security practices;

  • Incident response procedures.

Please note that no method of electronic transmission or storage is 100% secure. While we strive to use commercially acceptable means to protect your data, we cannot guarantee absolute security. In the event of a personal data breach, we will notify you and relevant supervisory authorities as required by applicable law.

11. Children's Privacy

The Service is strictly intended for adults aged 18 and over. We do not knowingly collect, process, or retain personal data from individuals under 18. If we become aware that we have inadvertently collected personal data from a minor, we will take immediate steps to delete such data. If you believe we may have collected data from a minor, please contact us immediately at support@soul-meet.io.

12. Third-Party Links and Integrations

The Service may contain links to third-party websites or integrate with third-party payment and authentication services. This Privacy Policy does not apply to those third-party services, and we are not responsible for their privacy practices. We encourage you to review the privacy policies of any third-party services you interact with.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal obligations, or service offerings. We will notify you of material changes by posting a notice on our website and sending an email notification to your registered email address at least 14 days before the changes take effect.

The date at the top of this Privacy Policy indicates when it was last updated. Your continued use of the Service after the effective date of changes constitutes acceptance of the updated Privacy Policy.

14. Supervisory Authority

As a Cyprus-registered data controller, we are subject to the supervision of the Commissioner for Personal Data Protection (Cyprus). You also have the right to lodge a complaint with the supervisory authority in your country of residence within the EU. A list of EU supervisory authorities is available on the European Data Protection Board website.

Commissioner for Personal Data Protection (Cyprus): www.dataprotection.gov.cy

15. Contact Us

For any privacy-related inquiries, requests, or complaints, please contact:

EMOTIQ SOCIAL LABS LTD

1, Konstantinou Skokou Capital Chambers, 2nd Floor, 1061 Nicosia, Cyprus

Privacy: support@soul-meet.io

Data Protection Officer: support@soul-meet.io

General Support: support@soul-meet.io