Privacy notice
What data we process about you, why, for how long, who can access it, and what rights you have.
This is an earlier version. The current version
Overview
1. Who processes your data
The controller is Tóth Alex egyéni vállalkozó (Tóth Alex e.v.), a Hungarian sole trader. Registered office and postal address: 2220 Vecsés, Róder Imre utca 11., Hungary. Tax number: 90852150-1-33. Registration number: 60197290. Email: support@vagylak.hu. Phone: +36 30 338 2096. Contact us here with any data protection question or request. We have not appointed a data protection officer at present; if the size of the service makes it necessary, we will publish their contact details here.
This notice is based on the EU General Data Protection Regulation (GDPR, Regulation (EU) 2016/679) and Hungarian Act CXII of 2011 on informational self-determination, and covers vagylak.hu and the related emails and notifications.
2. Our principles
- We only ask for data we need and only use it for the purposes described here.
- No ads, no tracking cookies, no selling of data, and no advertising profile about you.
- We only process your intimate data (orientation, desires, boundaries, secret desires) with your explicit consent, and you decide who can see it.
- We store your exact location encrypted and never give it to other members; others only see an approximate distance.
- We only store your password and PINs as one-way hashes, and we never see your card details at all.
- Our servers are in the European Union; where we use a provider outside the EU, appropriate safeguards are in place.
3. Overview of processing
The table below shows what data we use for what, on what legal basis and for how long. Legal bases are under Article 6(1) GDPR: (a) consent, (b) performance of a contract, (c) legal obligation, (f) legitimate interest. For special category data, the basis is explicit consent under Article 9(2)(a) GDPR.
| Purpose | Data | Legal basis | How long |
|---|---|---|---|
| Account and contract | email address, password hash, date of birth, language, when you accepted the Terms and this notice, plan, account status | (b) contract; to prove acceptance (c) and (f) | until the account is deleted, then a 30-day grace period |
| Dating profile | nickname, gender, orientation, partners and relationship types sought, age, town, introduction, answers, desires, boundaries card, secret desires, quiz answers, for couple profiles the partner’s date of birth, gender and orientation, photos | (b) contract; for data on sex life and sexual orientation, explicit consent under Article 9(2)(a) | until the account is deleted, or until you delete the data or withdraw consent |
| Matching and recommendations | likes, skips, matches, saved profiles and searches, daily picks, profile views, activity | (b) contract | until the account is deleted; profile views for 90 days |
| Messages | message text, chat photos, gifts, read status, withdrawn and disappearing messages | (b) contract; for intimate content Article 9(2)(a) | until the account is deleted; in disappearing chats 24 hours or 7 days; a view-once photo disappears for the recipient once viewed and its file is deleted 48 hours later (until then only a moderator can see it, if it is reported); on account deletion the text of sent messages is deleted too |
| Exact location (optional) | the coordinates your browser provides, encrypted, and a coarse area for distance calculation | (a) consent | until you turn it off or delete the account |
| Selfie verification (optional) | the requested pose, the selfie, the decision and its time | (a) consent | the selfie is deleted within 10 minutes of the decision; the outcome stays until the account is deleted |
| Safe date (optional) | time, place, the partner’s nickname, your friend’s name and email address, when you checked in. Your friend is told in the first email what we process about them and for how long | (a) your consent; for your friend’s data (f) legitimate interest: your safety | 30 days after the check-in deadline |
| Feedback after a meeting | whether you met, whether they matched their photos, whether you felt safe | (f) legitimate interest: community safety | until the account is deleted; never public |
| Unlock PIN and disguise (optional) | hashes of the PIN and the decoy PIN, whether disguise is on | (b) contract | until you turn it off or delete the account |
| Community | groups, membership, posts, comments, reactions, events and attendance, stories | (b) contract; for intimate content Article 9(2)(a) | until the account is deleted |
| Payment and invoicing | order, product, amount, VAT, payment method, payment reference, dates, transfer reference, invoicing details, Flame transactions | (b) contract; for accounting records (c) legal obligation (Hungarian Accounting Act, section 169) | accounting records for 8 years; everything else until the account is deleted |
| Security and abuse prevention | IP address at sign-up, sign-in log (IP address, time, browser), device identifier and browser, failed logins, risk signals | (f) legitimate interest: protecting accounts, preventing fraud and abuse, legal claims | sign-in log 12 months; devices 400 days after last use; sign-up IP address until the account is deleted |
| Moderation and reports | reports, moderator decisions and reasons, when a disappearing chat is reported a copy of its last 50 messages, fingerprints of banned images and banned email addresses | (c) legal obligation (DSA) and (f) legitimate interest; for special category data Article 9(2)(f) legal claims | reports and decisions 5 years; chat copy 30 days; fingerprints for as long as the ban lasts |
| Notifications | email, push subscription, system messages, VágyLak’s in-site announcements, reminders and summaries, notification settings and quiet hours. We may tell you about our own services (such as plans) on the site and in account-related emails; we do not send third-party advertising, and would only send marketing emails with separate consent | (b) contract; for reminders and our own offers (f) legitimate interest, can be turned off by topic | until the account is deleted or you turn the notification off |
| Feedback about the site | ideas or bug reports sent with the Feedback button, the page you sent it from, and your account if logged in | (f) legitimate interest: improving the service | 1 year |
| Support and complaints | your messages, the complaint, our reply, the record of an oral complaint | (b) contract; for complaints (c) legal obligation (Hungarian Consumer Protection Act, section 17/A) | complaints 3 years; other correspondence 1 year after the matter is closed |
| Requests from authorities | the request and the attached stamped document, the officer’s official name and contact details, the member concerned, the scope of data provided, the lock | (c) legal obligation; (f) legitimate interest in proving lawful handling | 5 years |
| Admin log | who did which moderation or admin action and when | (f) legitimate interest: accountability and preventing abuse | 5 years |
4. Where the data comes from
Most data you give us yourself: at sign-up, in your profile, in your messages and settings. Other data is created as you use the service, such as the sign-in log, likes and matches. Data about you may also come from other members: a message, a report, feedback after a meeting, or in a couple profile your partner’s details, which they enter with your knowledge. In safe date mode, the member enters their friend’s details. Authorities may send data in their requests. For payments, SumUp or the bank sends us the result of the payment.
5. Special category data
Data about your sex life and sexual orientation is special category data. This includes the orientation you give, the partners you seek, your desires, boundaries card, secret desires, quiz answers, and intimate messages and photos. We process it on the basis of the explicit consent you give when signing up, solely for dating, and only show it to people your settings allow: for example, only mutual secret desires are shown, and only to your matches; from your boundaries card only what you agree on is shown, and only to your matches or people you chat with.
Filling in optional fields is your choice. You can withdraw consent at any time: delete the fields in the profile editor or write to us. Because this data is the core of a dating profile, withdrawing consent completely means closing the profile; we will warn you first. Withdrawal does not affect the lawfulness of earlier processing. We do not treat intimate data shared on a community site as public to everyone.
6. Automated decisions and profiling
Recommendations (discovery, browsing, daily picks) rank profiles based on your settings, distance, activity, profile completeness, mutual interest, your earlier choices and paid highlights; this may count as profiling but has no legal effect on you. Section 11 of the Terms explains the ranking.
We also use automated signals: an advertising and contact detail filter on profile texts, a warning to the recipient on messages asking for money or payment (the text is checked automatically but not stored separately), matching against fingerprints of banned images, and a risk score for spam and abuse. A moderator decides on these. The one exception: if at least three different members report someone within 24 hours, their messaging is automatically paused for 7 days pending review. You can ask for human review, give your side and contest the decision.
7. Who can access your data
Other members see your profile according to your settings. The operator and appointed moderators can access data only as far as their tasks require; members’ email addresses, phone numbers and postal addresses are hidden from moderators. All of them are bound by confidentiality, and moderator actions are logged. Our processors (who process data on our behalf and on our instructions):
| Provider | Task | Where | Safeguard |
|---|---|---|---|
| Contabo GmbH (Welfenstraße 22, 81541 Munich, Germany) | servers, hosting, database, backups, mail server | European Union (Germany; Contabo’s data centre subcontractor is Contabo France SAS, France) | data processing agreement |
| Cloudflare, Inc. (101 Townsend Street, San Francisco, CA 94107, USA) | routing and encrypting traffic, attack protection, the Turnstile bot check | worldwide, European Union and USA | data processing agreement, EU-US Data Privacy Framework, standard contractual clauses (SCC) |
| Accounting service provider | meeting accounting obligations | Hungary | data processing agreement, confidentiality |
Independent controllers who receive data in order to provide the service, and who act under their own privacy notices:
- SumUp Limited (Block 8, Harcourt Centre, Charlotte Way, Dublin 2, D02 K580, Ireland; an electronic money institution supervised by the Central Bank of Ireland): card payments. SumUp handles your card details directly; we only receive the result and reference of the payment.
- Your bank and ours for bank transfers: the transfer details (name, account number, amount, reference) appear in the banking systems.
- Your browser’s push service (for example Google, Mozilla, Apple, Microsoft), if you turn on push notifications: it delivers the encrypted notification to your device.
- Your friend in safe date mode: if you do not check in by the deadline, they receive by email the time, place and partner nickname you entered.
- Have I Been Pwned: when you set a new password, it receives the first five characters of the password hash; neither the password nor your identity can be worked out from this.
- Authorities and courts: only on a request based on law, as described in section 8.
8. Requests from authorities
The police, prosecutors, courts, national security services, the tax authority or other authorities may ask us for data under the law (for example under Hungarian Act XC of 2017 on criminal procedure), order data to be preserved, or order illegal content to be removed. In such cases:
- We check the request: we only provide data on the basis of a document bearing the authority’s official stamp and signature, or one authenticated electronically, that states the authority, the case number and the legal basis. Authorities can also send requests through the data request form for authorities, uploading the stamped document. We check the document through the authority’s official contact details, and no data can be provided until this has been done.
- We only provide what is necessary: exactly the data the request names, for the period given. We do not store passwords, PINs or card details, so we cannot provide them.
- Preservation: if an authority orders preservation, we lock the data of the member concerned. While the lock is active, automatic deletions (account deletion, inactive accounts, disappearing messages, report copies, old logs) skip that data.
- We tell you: we inform the member concerned about the request and the scope of data provided, unless the authority prohibits it under the law, or telling them would endanger the proceedings or someone’s life or safety.
- We keep a record: we record every request, our decision and the scope of data provided, and keep the record for 5 years.
- On our own initiative we only contact authorities if a crime threatening someone’s life or safety is suspected (DSA Article 18), or in cases of sexual abuse involving a minor.
Authorities can send requests as described on the Contact page.
9. Transfers outside the European Union
Through Cloudflare’s global network, your data may also reach the United States or other countries outside the EU. Cloudflare participates in the EU-US Data Privacy Framework, and we also apply the European Commission’s standard contractual clauses (SCC) with them. There are no other transfers outside the EU.
10. Security
- The site and emails use encrypted connections (HTTPS, TLS).
- Passwords and PINs are stored as argon2 hashes, and exact location is stored encrypted.
- Team members can only reach the admin area with two-step verification, and only get the access their tasks require.
- Photos are resized, their metadata (such as location) is removed, and private photos never go into a public cache.
- In case of a data breach we notify the Hungarian data protection authority (NAIH) within 72 hours, and you without delay if the breach poses a high risk to you.
11. Backups
Before each update of the site, a backup of the database is made at the same hosting provider, in the European Union. We keep backups for 30 days and then delete them automatically (the three most recent backups are always kept). If we ever restore the database from a backup, we carry out again any deletions requested in the meantime.
12. Your rights
- Access and copy: you can ask what data we process about you. On the Settings page you can download your data with one click.
- Rectification: you can edit your profile at any time; for anything else, write to us.
- Erasure: you can delete your account in Settings, or ask us to delete specific data.
- Restriction: you can ask us to only store the data while a dispute or review is ongoing.
- Objection: you can object to processing based on legitimate interest; we then review it and stop unless there is a stronger reason.
- Portability: you get the data you provided in a machine-readable format (JSON).
- Withdrawing consent: at any time, without affecting the lawfulness of earlier processing.
- Human review: of the automated decision described in section 6.
We reply to requests within one month; for complex cases this may be extended by two months, and we will tell you within the first month. Exercising your rights is free. We only ask for the identification that is necessary and proportionate; do not send copies of ID documents. If your request also concerns other people’s data (for example a conversation), we may redact their data.
13. Complaints and remedies
If you feel we have breached your data protection rights, please write to us first so we can put it right. You can complain to the Hungarian National Authority for Data Protection and Freedom of Information (NAIH): 1055 Budapest, Falk Miksa utca 9-11.; postal address: 1363 Budapest, Pf. 9.; phone: +36 1 391 1400; website: https://www.naih.hu. You can also go to court, including the regional court for where you live or stay, or complain to the data protection authority in your own EU country.
14. Minors
VágyLak is only for people over 18. If we find that an account is used by a minor, we close the account and delete its data, except what we must keep to protect the minor or for proceedings by an authority.
15. Cookies and changes to this notice
The Cookies page explains cookies and data stored in your browser. We will notify you of material changes to this notice by email and system message before they take effect; earlier versions remain available on this page with their dates.
