Privacy notice

1. Controller

Andreas Petter (sole proprietorship), Rostocker Straße 4, 61130 Nidderau, Germany. Email: andreas.petter@pettersystems.de. [Data protection officer: still to be clarified]

2. What this is about

SoulMetrics provides a verifiable trust page (badge): verified identity, relationship status, personality and values profiles. In addition, two people can compare themselves on invitation. You decide per item who may see it, and you can withdraw each consent separately.

3. Which data we process and why

• Account: email, display name, password (as a hash only), confirmation that you are at least 18. Basis: contract (Art. 6(1)(b) GDPR).
• Identity check: profile photo, photo of the front and back of your ID, data read from it (name, date of birth, country, document number) and a similarity value from the face comparison. This is a biometric comparison. Basis: your explicit consent (Art. 9(2)(a), Art. 6(1)(a)). ID photos are deleted after a successful check; in a manual review only administrators with personal accounts see them, and each access is logged. So that each person can have only one account, we keep only an irreversible fingerprint of the document number (a hash with a secret key), not the number itself. It only shows whether the same document is already used for an active account, and it is deleted with the account.
• Tests: answers and results for Big Five, attachment style, values, relationship goals, life plans, and dominance and warmth; plus a private safety test (Dark Triad) only you can see. Each test has its own consent. Basis: consent (Art. 6(1)(a)). We treat this data as particularly sensitive.
• Visibility and badge: your releases per content type and audience, allow lists, the public badge address.
• Relationship opinions: other users can write a note about your relationship status (status, kind of acquaintance, note). Who wrote it is not disclosed to you. Basis: legitimate interest (Art. 6(1)(f)).
• Trust documents: documents you upload for manual review. Basis: consent or contract.
• Matching: invitations, blocks and one result per person built from the data the other person has released to you. Without payment you see a score. After unlocking you see concrete insights (for example shared relationship goals, attachment style, most important values, Big Five tendencies, dominance and warmth, life plans such as children and marriage) and a written summary. You never see the other person's individual answers or anything they have hidden from you. Basis: consent to matching and contract for the paid feature.
• Payments and wallet: payment processing through Stripe, wallet entries, subscription status, proof of the waiver of the right of withdrawal. Basis: contract and legal obligations (Art. 6(1)(b), (c)).
• Contact form: when you write to us through the contact form we process your name (optional), your e-mail address and your message in order to answer you. The message reaches us by e-mail and is not stored in the app; it stays in our mailbox as long as it is needed to deal with it. Basis: Art. 6(1)(b) or (f) GDPR. Against abuse we briefly count submissions per address in memory.
• Logs: a record of important privacy and payment actions (who, when, what) and a connection log. The connection log stores, for every request to our interface, the IP address, the source port, the time, your account (if signed in), the function called (without content or query parameters), the result and a trace id that ties the lines of all services to one request. Purpose: defending against attacks and abuse and tracing errors. When you waive the right of withdrawal we also store your IP address as proof. Basis: legitimate interest and accountability (Art. 6(1)(f), (c)). The connection log is part of your data export.

4. Who receives your data

• Stripe (payment processing). [data processing agreement and transfer basis to be clarified]
• Hosting provider: One.com Group AB (Carlsgatan 3, 211 20 Malmö, Sweden), data centre in Germany (subprocessor Envia TEL GmbH; system monitoring by Dogado GmbH, also in Germany). A data processing agreement is in place with the provider. We additionally encrypt uploaded photos and documents ourselves.
• Email delivery: Google Workspace (Google). [enter contracting entity, location and transfer basis from the data processing amendment] We only email registered users, and invitation emails only with your consent.
• AI service for the written summary of a comparison: Anthropic (Claude). Only fixed, neutral statements from a limited set are sent, for example "One person wants a lot of closeness, the other needs more space". No names, identifiers, numbers, free text or your answers leave our system. Processing currently takes place in the USA; a move to a European setup is planned. [data processing agreement and transfer basis to be clarified] Without the service you get fixed text blocks.
• The face and ID check runs on our own server. We pass no data to third parties for it.
• The other person in a comparison only sees what you have released to them (see section 3).

5. How long we keep data

• Account, profile and test data: until you delete your account. Superseded test results (a newer one of the same test exists) after 12 months.
• ID photos: deleted after a successful check; in a manual review at most 30 days. After a successful check we keep only date of birth (for your age), country and the fingerprint of the document number until the account is deleted; name, document number and the face comparison values are deleted.
• Match invitations and results: declined, expired and cancelled invitations 90 days after the last change; otherwise until deletion, withdrawal, blocking or account deletion. If a person withdraws a consent, the results built on their data are deleted.
• Payment records: pseudonymised until the end of the year of deletion plus 10 years (period still to be confirmed by the tax adviser).
• Logs of important actions and closed privacy requests: 3 years. Connection log with IP address: 14 days (deleted hourly) and with the account; server access logs without IP addresses: 14 days.

6. Your rights

• Access and data export: in the app under your account; we reply within one month.
• Rectification, erasure, restriction, objection and portability: through a request in the app or by email to andreas.petter@pettersystems.de.
• Withdrawing consent: at any time, each one separately under "Visibility and consents", effective for the future. Withdrawing a consent deletes the comparison results built on the data concerned.
• Complaint to a supervisory authority: for example at your place of residence or ours. For us this is the Hessian Commissioner for Data Protection and Freedom of Information (datenschutz.hessen.de).

7. Security

Connections are encrypted with TLS. Uploaded photos and documents are stored encrypted on the server. Administrators have personal accounts with a second factor, and every access to ID images and documents is logged. Data is not used for advertising and not sold.

8. Changes

If we change this notice materially, we will tell you in the app and, where needed, ask for your consent again.