Privacy Policy

This Privacy Policy explains how [COMPANY LEGAL NAME] ("Riyo," "we," "us," or "our") collects, uses, shares, and protects information when you use the Riyo website and services (the "Service").

1. Information We Collect

1.1 Information you provide directly

• Account information: email address and password (or other sign-in method), if you create an account.
• Date of birth: where our simple age gate is used (instead of, or before, the selfie check below), the date of birth you enter when you first use the Service. It is used to calculate your age and confirm you meet our 18+ requirement; we do not store the date of birth itself — we keep only a signed cookie in your browser confirming the check was passed. (Plus and Premium members also enter their age in their profile; see below.)
• Age-assurance check: before you chat, you complete a check run by our age-assurance provider, Didit (a selfie for facial age estimation and, where offered, an ID document). The provider processes your image or document under its own privacy terms. We do not receive or store your photo or ID; we store only the outcome (passed, under 18 or failed), the method, the date, and the device identifier and account it applies to, for as long as the pass is valid.
• Payment information: if you buy a prepaid pass or make a one-time payment (such as a ban reinstatement fee), you pay in cryptocurrency through our payment processor (currently BTCPay Server). We do not collect card details. We keep a payment record: the amount, our invoice identifier, the time, the plan bought, and the public transaction details the blockchain shows. If you redeem a prepaid code, we record that the code was redeemed by your account.
• Profile and matching details (Plus and Premium): your gender, age, and main language, plus the partner preferences you choose (partner gender, age range, country, language, and whether to match only exact preferences). These are self-declared and not verified, are used only to apply matching filters, and are never shown to the person you are matched with.
• Content you provide in chat: text messages you send during a conversation, and any preferences you set (interests, region, language, matching filters).
• Reports: if you report another user, the reason you provide and related session details.

1.2 Information collected automatically

• Device identifier: a randomly generated identifier stored in your browser (in local storage and a first-party cookie; not tied to your name or account unless you sign in), used to enforce blocks, bans, and prevent repeat matching with someone you've already reported or skipped. See Section 6 for details.
• Device fingerprint: a hash calculated from technical characteristics of your browser and device (for example screen size, graphics hardware, time zone, language settings, and how your browser draws a test image). We store only the resulting hash, not the underlying characteristics. It is used for ban enforcement and abuse prevention — for example, to recognize a banned device after its identifier has been cleared. See Section 6.
• Approximate country: when you connect, we estimate your country from your IP address. It is used to apply country matching preferences and is shown, as a flag and country name, to the person you are matched with — for every user, free or paid. It is used in memory only and is not saved to your profile, and we do not collect precise location. If you use a VPN, the country shown may differ from where you are.
• Video and audio: your live video/audio feed during a call. Calls between users travel directly between devices (peer-to-peer) or through a relay server when a direct connection isn't possible; we do not record or store call audio/video, except for the limited, automated moderation sampling described in Section 2.
• Sampled video frames: while you are in an active video call, still frames are periodically captured from your own device's camera feed (not your call partner's), checked by software running on your device and, when that check flags a frame (and for occasional random audit samples), sent to our automated content-moderation vendor for real-time analysis. See Section 2 for detail on what happens to these frames.
• Chat message copies for moderation: a copy of each text message you send is sent to our automated content-moderation vendor for analysis, in parallel with normal delivery to your chat partner.
• Technical and usage data: IP address, browser type, connection metadata, session duration, match outcomes (matched, skipped, reported, disconnected), and similar technical logs, used for security, abuse prevention, and service operation. Your IP address is also used transiently to estimate your region (above) and to rate-limit abusive traffic.
• Cookies and local storage: used for session management, remembering your preferences, the age-verification cookie, and the device identifier described above (the device identifier cookie lasts up to two years unless you clear it).

1.3 Information from third parties

• Payment status from our crypto payment processor (invoice paid, expired or invalid), used to unlock paid features or lift a ban.

2. How We Use Automated Content Moderation

We use automated tools to help detect content that violates our Terms of Service and Community Guidelines, including nudity/explicit imagery and abusive or prohibited text.

• Video: while you're in a video call, a still frame from your own camera feed is captured every few seconds and first checked by software running on your device; frames that check marks as possibly explicit, plus occasional randomly chosen frames, are sent to our moderation vendor (currently Sightengine) for real-time analysis. The frame is analyzed and, per our vendor's data handling terms, is not retained by them for longer than necessary to return a result. If a frame is flagged, we log the detection result (not necessarily the image itself) for review, and may end your call and take enforcement action as described in our Terms of Service.
• Text: each chat message you send is also sent, in parallel with normal delivery, to our moderation vendor for automated analysis (profanity, sexual content, personal-information sharing, and similar categories). Messages containing shared contact information (e.g., social media handles) are logged for visibility but generally not blocked; other flagged categories may be blocked from delivery and logged.

We do not use automated moderation results to build an advertising profile about you, and we do not sell this data. Automated moderation is supplemented by human review of reports and flagged content, and by the steps described in Section 4.

3. How We Use Information

We use the information described above to:

• Operate the Service, including matching you with other users (applying the matching filters you choose) and facilitating calls and chat;
• Verify you meet our age requirement;
• Detect, investigate, and act on violations of our Terms of Service and Community Guidelines;
• Process payments and manage subscriptions;
• Maintain the security and integrity of the Service, including preventing abuse, fraud, and repeat violations;
• Comply with legal obligations, including responding to lawful requests from law enforcement and reporting apparent child sexual abuse material to the relevant authorities where we are able to and where the law requires;
• Improve the Service (e.g., understanding match success rates, session length, and abuse-report rates in aggregate).

We do not use your chat content or call video/audio for advertising purposes, and we do not sell your personal information.

4. Child Safety and Reporting

If we become aware of apparent child sexual abuse material (CSAM), through a user report, our moderation, or otherwise, we will end the session, ban the device, preserve the minimum information needed for an investigation, and report it to the relevant child-protection or law-enforcement authorities where we are able to and where the law requires, and cooperate with them. See our Terms of Service, Section 4.1 and Section 13, for more detail.

5. How We Share Information

We share information with:

• Service providers who help us operate the Service, under contractual confidentiality and data-use restrictions, including Supabase (authentication and database hosting), our crypto payment processor (BTCPay Server), our age-assurance provider (Didit), Sightengine (automated content moderation, as described in Section 2), Google Cloud Translation (live chat translation for Premium members — the text of messages being translated is sent to Google), and our hosting/infrastructure providers (servers, and Cloudflare's TURN/relay servers for calls).
• Other users, limited to what's inherent to the Service itself: your live video/audio/chat during a call is visible to the person you're matched with, and your subscription tier (e.g., "Premium") may be shown to your match as a badge.
• Law enforcement or government authorities, where required by valid legal process, or where we believe in good faith it's necessary to comply with the law, protect someone's safety, or investigate violations of our Terms.
• A successor entity, in the event of a merger, acquisition, or sale of assets, subject to this Policy or a materially similar one.

We do not sell your personal information to third parties for their own marketing purposes.

6. Device Identifiers, Fingerprints, Blocks, and Bans

To make reporting, blocking, and bans effective — including across a page refresh or reconnect, which a temporary connection ID cannot survive — we use two technical identifiers, whether or not you have an account:

• A device identifier: a persistent, randomly generated identifier stored in your browser's local storage and a first-party cookie. It is not, by itself, tied to your real name or identity, and it persists until you clear both (after which a new one is generated).
• A device fingerprint: a hash of technical characteristics of your browser and device, described in Section 1.2. Because it does not depend on stored data, it can survive clearing your browser storage.

We use them to:

• Remember which other devices you've been matched with, blocked, or reported;
• Enforce moderation bans. We keep a record linking device identifiers to the fingerprints seen with them. If a banned device returns with a new identifier but a matching, distinctive fingerprint, we treat it as the same device and the ban applies to the new identifier too. Fingerprints shared by many devices (for example identical phone models) are not used for this, to avoid affecting other people;
• Prevent abuse, fraud, and ban evasion.

These identifiers may be linked to your account if you sign in. We do not use them for advertising or sell them. We do not ban based on IP address alone.

7. Data Retention

• Account information is retained while your account is active, and for a limited period after deletion as needed for legal, security, or fraud-prevention purposes.
• Chat message content is not stored after delivery, except where flagged by moderation (in which case the flagged message and moderation result are retained for review) or where you've reported a conversation.
• Call video/audio is not recorded or stored by us; moderation frame-analysis results (not necessarily the images) are retained for review purposes.
• Device identifiers, fingerprints, and ban records are retained for as long as needed to enforce a ban and prevent abuse; records not linked to a ban are kept only for a limited period (see counsel note below).
• Reports and moderation records are retained as needed for safety, legal compliance, and to enforce bans.
• Payment records are retained as required by tax, accounting, and legal obligations.

8. Your Rights and Choices

Depending on your location, you may have rights to access, correct, delete, or export your personal information, or to object to or restrict certain processing. To exercise these rights, contact us at [PRIVACY CONTACT EMAIL].

• EU/UK users (GDPR): you have rights including access, rectification, erasure, restriction, portability, and objection, and the right to lodge a complaint with your local data protection authority.
• California users (CCPA/CPRA): you have the right to know what personal information we collect, to request deletion, to correct inaccurate information, and to opt out of the sale or sharing of personal information (we do not sell personal information, as noted above).

9. Children's Privacy

The Service is not directed at, and must not be used by, anyone under 18. We do not knowingly collect personal information from anyone under 18. If we become aware that someone under 18 has provided us with personal information, we will take steps to delete it and terminate the associated account.

10. Security

We use reasonable technical and organizational measures designed to protect your information, including encrypted connections, access controls on our systems, and least-privilege access to sensitive data. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

11. International Data Transfers

12. Changes to This Policy

We may update this Privacy Policy from time to time. If we make material changes, we will provide notice (such as a banner on the Service or an email, where feasible) before the changes take effect.

13. Contact Us

Questions about this Privacy Policy, or requests to exercise your privacy rights, can be directed to: [PRIVACY CONTACT EMAIL].

[COMPANY LEGAL NAME] · [COMPANY ADDRESS, if required in your jurisdiction]