Privacy Policy

Cumpli ("we," "us," or "our") is a matchmaking platform for individuals practicing consensual non-monogamy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our platform.

We are committed to protecting your privacy, especially given the sensitive nature of the information you share with us. We understand that information about your relationship style, sexuality, and personal preferences deserves careful handling and practical safeguards.

If you do not agree with the terms of this Privacy Policy, please do not use the Service.

We collect the following categories of information:

Account and Application Information

• Name, email address, phone number, location, and preferred contact method
• Your birth month and year, and confirmation that you are already at least 18
• Password (stored in hashed form)
• Exactly one application material you select: either your resume or CV, or your LinkedIn personal-profile URL
• Between two and five private applicant photos in the order you submit them, with the first designated as your Primary head shot and the second as your full-body shot
• Your statement that every applicant photo was taken within the previous six months and that your first photo clearly shows your face and your second clearly shows your full body, together with the time we record that statement

Profile Information

• Relationship interest, current relationship context, and matching preferences
• Optional preferred minimum and maximum ages for people you are open to meeting
• Sexuality, sexual health, and lifestyle details you submit in surveys
• Optional product research responses you choose to share

Survey Data

• Lifestyle survey responses (values, communication style, relationship goals)
• Kink and intimacy preference data used for self-insight reports, matching triage, and conversation guidance

Payment Information

• Payment details are processed by PayPal. We do not store your full credit card number. We retain only the payment metadata needed to reconcile your application payment, such as provider, order, capture, and status information.

Background-Screening Information

• After payment, an authorized Cumpli staff member manually initiates a background screening through Checkr before making a final application decision.
• Checkr collects the information and authorization it requires directly from you under its own notices. Authorized Cumpli staff receive and review the resulting report.
• Cumpli's product stores operational screening progress and the final application decision. It does not store the raw Checkr report or its findings.

Communications and Support Information

• Messages, emails, forms, reports, appeals, feedback, and support requests you send us
• Communication metadata such as delivery status, timestamps, and contact preferences

Technical and Security Data

• Request and security metadata that our hosting and infrastructure providers may record, such as IP address, browser or device information, requested URL, timestamps, and error or security events
• Essential authentication and session cookies (see Section 12)

Note: Cumpli implements technical measures to keep non-public account, application, survey, and report surfaces behind authentication where applicable and outside external search indexing.

If you provide a LinkedIn profile URL, we store the URL you submit. Cumpli does not visit, fetch, scrape, validate the existence of, or otherwise contact that LinkedIn profile as part of your application.

Cumpli treats your photo-requirements statement as an applicant attestation. We do not use applicant photos to infer or automatically verify biometrics, recency, identity, age, whether a face or full body appears, authenticity, or attractiveness.

We do not collect your birth day. We use birth month/year to check that your application is consistent with being an adult and to honor both members' preferred age ranges. During a birth month, matching allows either of the two possible ages. Your confirmation that you are already 18 is an attestation; it does not verify your age.

Information From Other Sources

• Information we may receive from payment processors, fraud prevention providers, hosting providers, analytics providers, communications providers, and identity or safety vendors if we use them
• Information from other members, applicants, reporters, or witnesses when they contact us about safety, consent, privacy, support, or policy concerns
• Publicly available information or information from legal, regulatory, or law enforcement sources when reasonably necessary for safety, verification, fraud prevention, legal compliance, or enforcement of our policies

We recognize that some of the data we collect is particularly sensitive, including:

• Sexuality and related details you provide
• Kink and fetish preferences collected through our compatibility surveys
• Relationship context and matching preferences you provide

We handle this sensitive data with additional safeguards:

• Clear collection context: You provide this information when you submit the relevant form or survey, and we use it only for the purposes described in this policy
• Never sold: We will never sell your sensitive personal data to third parties
• Minimal access: Access to sensitive data is restricted to essential staff on a need-to-know basis

We use the information we collect for the following purposes:

• Matchmaking: To support staff matching decisions and curated introductions based on your profile, surveys, and preferences
• Account Management: To create, maintain, and secure your account
• Payments: To process payments, reconcile orders, handle refunds or chargebacks, prevent payment fraud, and maintain transaction records
• Application Screening: To initiate and manually review background screening for paid applicants and make final application decisions
• Communication: To send you important updates, matching updates, safety notices, support responses, payment messages, policy updates, and service-related communications
• Support and Enforcement: To respond to questions, investigate reports, review appeals, enforce our Terms & Conditions and Consent & Community Guidelines, and protect member privacy and safety
• Safety: To detect and prevent fraud, abuse, and violations of our Terms & Conditions
• Legal Compliance: To comply with applicable law, respond to legal process, preserve records, and establish, exercise, or defend legal claims
• Automated Processing: To support survey completion, report generation, matching triage, and access controls. Significant application, moderation, and safety decisions are made by staff

We process your personal information under the following legal bases:

• Consent: Particularly for the collection and processing of sensitive personal data (sexuality, sexual health information, kink preferences, and relationship context). You may withdraw consent at any time.
• Contract Performance: Processing necessary to provide you with the matchmaking services you have requested.
• Legitimate Interests: Processing necessary for our legitimate interests, such as improving our services, preventing fraud, and ensuring platform safety, where these interests are not overridden by your rights.

We may share your information with the following categories of third parties:

• PayPal: For payment processing. PayPal receives only the payment information necessary to process your transactions. We do not store your full card number.
• Checkr: For background screening of paid applicants. Checkr collects screening information and authorization directly and provides the report to authorized Cumpli staff for manual review. Cumpli's product retains only operational progress and the final decision, not the raw report or its findings.
• Hosting and Infrastructure: Cloud service providers that host our platform and databases, subject to strict data processing agreements.
• Communications and Support Providers: Email, messaging, customer support, and notification providers that help us deliver account, payment, safety, support, and service communications.
• Security and Safety Providers: Providers that help us prevent fraud or abuse, authenticate users, investigate incidents, protect systems, and enforce our policies.
• Legal Requirements: We may disclose your information if required by law, subpoena, or court order.
• Legal Claims and Rights Protection: We may disclose information where reasonably necessary to establish, exercise, or defend legal claims, enforce our agreements, investigate wrongdoing, or protect the rights, property, or safety of Cumpli, our members, or others.
• Safety and Fraud Prevention: We may share information to investigate, prevent, or respond to fraud, abuse, security incidents, or violations of our Terms & Conditions or Consent & Community Guidelines.
• Corporate Transactions: If Cumpli is involved in a merger, acquisition, financing, restructuring, sale of assets, bankruptcy, or similar transaction, your information may be disclosed or transferred as part of that process, subject to applicable confidentiality and legal requirements.
• Professional Advisors: Lawyers, accountants, auditors, insurers, and other professional advisors who need the information to provide services to Cumpli.

We do not sell your personal data. We will never sell, rent, or trade your personal information to third parties for marketing or advertising purposes.

Member Visibility

Your birth month/year, age or possible age window, and preferred age range are available to you and authorized Cumpli staff, and are not disclosed to other members or the public. Staff use age information for application review and matching eligibility. It stays out of member-facing compatibility reports and PDFs, including The Dirty Details.

Your selected resume or CV or LinkedIn profile URL, applicant photos, and photo attestation remain part of your private Application record. They are available to you and authorized Cumpli staff. Staff use them for application review, matchmaking, and support, and hosting and infrastructure providers process and store them on our behalf.

We do not show applicant photos or their attestation to prospective matches or other members, and we do not place them in public APIs, public object URLs, profiles, compatibility reports, member browsing, or external search results.

At launch, Cumpli does not provide a public member directory or member browsing surface. Profile, application, payment, and survey information is used by Cumpli staff for application review, matchmaking, and member support unless we add a sharing feature and explain that visibility before you use it.

Members are strictly prohibited from sharing, screenshotting, or redistributing another member's information, messages, or any other content obtained through Cumpli outside the platform. Violations of this policy may result in immediate account termination, as outlined in our Terms & Conditions and Consent & Community Guidelines.

We retain your personal information for as long as your account is active or as needed to provide you with the Service. This includes birth month/year and preferred age ranges. Specifically:

• Active accounts: Data is retained for the duration of your membership, including the resume or CV or LinkedIn profile URL, applicant photos, and photo attestation attached to your Application
• Unused resume uploads: A verified resume upload that you do not attach because you apply with LinkedIn instead may remain temporarily in our upload-cleanup process. If it remains unused, it is deleted after 24 hours.
• Unused applicant photo uploads: A verified applicant photo that you do not attach to a submitted Application remains temporarily in our upload-cleanup process. If it remains unused, it is deleted after 24 hours.
• Account deletion: Upon account closure, we will delete your personal data within 30 days, except where retention is required by law
• Legal holds: We may retain information longer if required for legal proceedings, regulatory compliance, or dispute resolution
• Safety and Fraud Controls: Limited records may be retained for backups, fraud prevention, safety enforcement, and to help prevent banned or abusive users from re-registering.

In some cases, residual data may remain in secure backups for a limited period before it is overwritten or deleted as part of our normal retention cycle.

You have the following rights regarding your personal data:

Access, portable-copy, correction, and deletion requests include your birth month/year and preferred age range. You can change or clear your age preferences in the Lifestyle Survey; contact us to correct birth information.

• Access: Request a copy of the personal data we hold about you
• Correction: Request correction of inaccurate or incomplete personal data
• Deletion: Request deletion of your personal data, including the resume or CV or LinkedIn profile URL, applicant photos, and photo attestation in your Application, subject to legal retention requirements
• Portability: Request a portable copy of your data in a structured, machine-readable format
• Objection: Object to processing of your personal data based on legitimate interests
• Withdrawal of Consent: Withdraw your consent for processing of sensitive personal data at any time

To exercise any of these rights, please contact us at [email protected]. We will respond to your request within 30 days.

For your protection and the protection of other members, we may request information needed to verify your identity before fulfilling an access, correction, portability, or deletion request.

We may limit or deny a request where compliance would conflict with applicable law, compromise another person's privacy, expose trade secrets or security controls, or prevent us from providing essential aspects of the Service.

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA):

• Right to Know: You may request information about the categories and specific pieces of personal data we have collected, the sources of that data, our purposes for collecting it, and the third parties with whom we share it.
• Right to Delete: You may request that we delete the personal information we have collected from you, subject to certain exceptions.
• Right to Opt-Out: You have the right to opt out of the sale of your personal information. As stated above, we do not sell your personal data.
• Non-Discrimination: We will not discriminate against you for exercising any of your CCPA rights.

If you are located in the European Economic Area (EEA), you have additional rights under the General Data Protection Regulation (GDPR), including:

• The right to lodge a complaint with your local data protection authority
• The right to restrict processing of your personal data
• The right to object to automated decision-making, including profiling, where it produces legal or significant effects

Automated processing supports survey completion, report generation, matching triage, and access controls. Significant application, moderation, and safety decisions are made by staff. Where automated processing would produce legal or similarly significant effects under applicable law, you may request human review, contest the decision, or provide additional context by contacting us.

If we transfer your data outside of the EEA, we will ensure appropriate safeguards are in place, such as Standard Contractual Clauses approved by the European Commission.

We implement technical and organizational measures to protect your personal data:

• Access Controls: Account and admin permissions limit who can access your data
• Breach Notification: In the event of a data breach affecting your personal information, we will notify you and relevant authorities as required by applicable law
• Sensitive Data Protections: Sensitive data categories, including sexuality and kink preferences, are subject to additional access restrictions
• Non-Public Surfaces: Account, application, survey, and report surfaces are protected by authentication where applicable and are not intended for external search indexing

While we strive to protect your personal data, no method of transmission or storage is 100% secure. We cannot guarantee absolute security.

Cumpli currently uses essential cookies for authentication and session management. We do not currently use analytics or advertising cookies. If that changes, we will update this policy and provide any consent controls required by law.

The Service is intended solely for individuals who are at least 18 years of age. We do not knowingly collect personal information from anyone under 18. If we become aware that we have collected data from a person under 18, we will take steps to delete that information promptly.

If you believe that a minor has provided us with personal information, please contact us immediately at [email protected].

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the updated policy on the Service and updating the "Effective Date" at the top of this page.

We encourage you to review this Privacy Policy periodically. Your continued use of the Service after any changes indicates your acceptance of the updated policy.

If you have any questions about this Privacy Policy or our data practices, please contact us: