Privacy Policy

Last updated: April 2026

1. Introduction

Welcome to Galerie Minuit ("we", "us", "our"). We are an adult social networking and dating platform designed for consenting adults who wish to connect, explore, and build community around lifestyle interests.

This Privacy Policy explains what personal data we collect about you, why we collect it, how we use it, who we share it with, and what rights you have under the General Data Protection Regulation (GDPR) and applicable UK and EU data protection law.

Please read this policy carefully before creating an account. By registering with Galerie Minuit, you acknowledge that you have read and understood this policy.

If you have any questions about this policy or how we handle your data, please contact us at the details provided in Section 10.

2. Data We Collect

We collect the following categories of personal data:

Account Data

Email address
Username and display name
Hashed password (we never store your password in plain text)
Date of birth (to verify you are 18 or older)
Country and region

Profile Data

Profile photos and videos uploaded by you
Bio and personal description
Relationship status and configuration (e.g. single, couple, polyamorous)
Location (city/region level — we do not store precise GPS coordinates persistently)
Physical attributes you choose to share (height, body type, etc.)

Preference and Interest Data

Sexual orientation
Kinks, fetishes, and lifestyle interests you voluntarily add to your profile
Partner preference settings used for matching

Usage Data

Pages and features you interact with
Search queries within the platform
Messages sent and received (encrypted in transit and at rest)
Login timestamps and device type
IP address (retained for security and fraud prevention)

Cookies and Tracking

We use cookies and similar technologies as described in Section 8 of this policy.

3. Special Category Data (Article 9 GDPR)

Some of the data we process falls under Article 9 of the GDPR as "special category" data. Specifically, this includes:

Sexual orientation — inferred from or directly provided in your profile
Sexual interests, desires, and kinks — entered voluntarily as part of your profile and preferences

Legal Basis

We process this special category data only with your explicit consent, as required under Article 9(2)(a) GDPR. When you create an account and complete your profile, you are asked to provide this consent explicitly and separately from other terms.

Right to Withdraw Consent

You may withdraw your consent at any time by:

Navigating to Settings → Privacy → Consent Management
Revoking consent for special category data processing

What happens when you withdraw consent: We will immediately cease processing your special category data for matching and profile purposes. Your profile will be hidden from other users. You may retain a basic account, but core platform features that depend on this data will be unavailable until consent is re-granted.

Withdrawing consent does not affect the lawfulness of processing that occurred before the withdrawal.

Why We Need This Data

This data is the core purpose of the platform. Without it, we cannot provide meaningful matching or community features. We do not use this data for any purpose outside of operating the platform and improving safety.

4. How We Use Your Data

We use your personal data for the following purposes:

| Purpose | Legal Basis | |---------|-------------| | Creating and managing your account | Contract performance | | Matching you with compatible members | Explicit consent (Article 9) | | Displaying your profile to other members | Explicit consent | | Sending transactional emails (account, security alerts) | Contract performance | | Content moderation and safety enforcement | Legitimate interests / Legal obligation | | Fraud prevention and platform security | Legitimate interests | | Analytics to improve the platform | Legitimate interests | | Legal compliance and responding to lawful requests | Legal obligation |

We do not use your data for automated individual decision-making that produces legal or similarly significant effects without human review.

5. Data Sharing

We share personal data only as necessary and never sell your data to third parties.

Service Providers

| Provider | Purpose | Data Shared | |----------|---------|-------------| | NudeNet | AI-based adult content classification | Images and videos uploaded for moderation | | Sightengine | Content moderation (violence, spam, illegal content) | Images and videos for scanning | | CCBill | Payment processing for subscriptions | Name, billing address, payment card details | | Cloudflare R2 | Photo and media file storage | Your uploaded photos and profile images | | Backblaze B2 | Video original file storage | Your uploaded video files | | Supabase | Database and authentication infrastructure | Account and profile data |

All service providers are bound by data processing agreements and may only use your data to provide services to us.

Legal Disclosure

We may disclose your data if required by law, court order, or to protect the rights, safety, and property of our users or the public. We will notify you of any such disclosure where legally permitted to do so.

No Sale of Data

We never sell, rent, or trade your personal data to any third party for their own marketing or commercial purposes.

6. Your Rights Under GDPR

As a data subject under GDPR, you have the following rights:

Right of Access (Article 15) — You can request a copy of all personal data we hold about you.

Right to Rectification (Article 16) — You can correct inaccurate data by updating your profile or contacting us.

Right to Erasure ("Right to be Forgotten") (Article 17) — You can request deletion of your account and all associated data. See Section 7 for what this includes.

Right to Data Portability (Article 20) — You can request your data in a machine-readable format (JSON) via Settings → Privacy → Export My Data.

Right to Restriction (Article 18) — You can ask us to restrict processing of your data while a complaint is being investigated.

Right to Object (Article 21) — You can object to processing based on legitimate interests (e.g. certain analytics).

Right to Withdraw Consent — You can withdraw consent for special category data at any time (see Section 3).

Right to Lodge a Complaint — You have the right to complain to a supervisory authority. In the UK, this is the Information Commissioner's Office (ICO).

To exercise any of these rights, visit Settings → Privacy or contact us at the details in Section 10.

7. Data Retention

We retain your data for as long as your account is active and as necessary to provide our services.

| Data Type | Retention Period | |-----------|-----------------| | Account and profile data | Duration of account + 30 days after deletion request | | Messages | 2 years, or until account deletion | | Usage logs and analytics | 12 months rolling | | Payment records | 7 years (legal/tax obligation) | | Moderation logs | 3 years (safety and legal compliance) |

Media File Deletion

Your photos are stored on Cloudflare R2. Your video originals are stored on Backblaze B2.

When you delete your account or request erasure:

All photos are deleted from Cloudflare R2
All video files are deleted from Backblaze B2
Deletion is processed within 30 days of the request

Your data export (see Right to Portability above) includes download links for your media files and remains available for 7 days after the export is generated.

8. Cookies

We use cookies and similar tracking technologies to operate the platform, remember your preferences, and understand how you use our service.

Cookie Categories

| Category | Purpose | Can be declined? | |----------|---------|------------------| | Essential | Login sessions, security tokens, CSRF protection | No — required for the platform to function | | Functional | Language, theme, and preference settings | Yes | | Analytics | Aggregated usage data to improve the platform | Yes |

You can manage your cookie preferences at any time via the Cookie Settings link in the site footer, or by visiting Settings → Privacy → Cookie Preferences.

We do not use advertising or tracking cookies that share your data with ad networks.

9. International Data Transfers

Our services involve data processors and infrastructure in multiple jurisdictions. Transfers outside the UK/EEA are protected by:

Standard Contractual Clauses (SCCs) — used for transfers to US-based processors
Adequacy decisions — where applicable

A list of processors and the applicable transfer mechanisms is available on request.

10. Contact

Data Controller: Galerie Minuit Ltd

Email: privacy@galerieminuit.com

Data protection contact: privacy@galerieminuit.com

For general privacy queries, account data requests, or to exercise your rights, email us at the address above. We aim to respond within 30 days as required by GDPR.

11. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements.

When we make material changes, we will:

Update the "Last updated" date at the top of this policy
Notify you by email or in-app notification at least 14 days before changes take effect
Where required by law, seek fresh consent

Continued use of the platform after changes take effect constitutes acceptance of the updated policy.