Privacy Policy

1 What This Policy Covers

This Privacy Policy explains how [KYNK Legal Entity Name] ("KYNK", "we", "us", "our") collects, uses, stores, shares, and protects your personal information when you use the KYNK platform and its associated services.

This policy applies to all registered users, users who have not yet completed identity verification, suspended or deactivated users, visitors to the KYNK website or application, vendors registered on the KYNK marketplace, and event organisers who list events on the platform.

This policy covers all features and functions of the KYNK platform including Feed, Discover, Playground, Groups, Events, Shop, Profile, and private messaging.

KYNK is committed to meeting the highest applicable data protection standard. Our baseline standard is the EU General Data Protection Regulation (GDPR). This policy is also designed to satisfy the requirements of the UK GDPR and the California Consumer Privacy Act (CCPA/CPRA).

Contact Details

The data controller responsible for your personal information is [KYNK Legal Entity Name], [Registered Address], [Jurisdiction of Incorporation].

For all privacy enquiries and data subject rights requests: [privacy@kynk.com]

2 What Information We Collect

We collect information in three ways: information you give us directly, information generated by your use of the platform, and information received from third parties. We do not collect more information than we need.

Registration Data

When you create a KYNK account we collect your email address, password (stored in encrypted form — we never have access to your password in plain text), date of birth, username, and country of residence.

Identity Verification Data

When you complete the identity verification process we collect a government-issued identity document image. This image is used solely to confirm your identity and that you meet the minimum age requirement. It is permanently deleted immediately after verification is confirmed. We retain only a record of your verified status — not the document itself.

Profile and Preference Information

Information you choose to include in your profile, including your biography, interests, kink preferences, preferred dynamics, relationship structures, profile images, and any other information you add to your profile or Playground settings. This information is provided voluntarily by you and can be updated or removed at any time.

Activity and Content Data

Content you create and share on the platform, including posts on the Feed, messages sent through Messaging, contributions to Groups, and any other user-generated content.

Connection and Interaction Data

Information about your connections, matches, and interactions with other users through Playground, Groups, Events, and the Shop.

Transaction Data

Information about payments, subscriptions, and purchases made through the platform, including payment method details processed by KYNK's payment processing partners. KYNK does not store complete payment card details on its own systems.

Device and Technical Data

Information about the device, software, and network you use to access the platform, including your device type, operating system, IP address, browser type, and connection information.

Usage and Activity Data

Information about how you use the platform, including the features you access, the content you engage with, the time and duration of your sessions, and your navigation patterns within the platform.

3 How We Use Your Information

KYNK uses your personal data for the following purposes:

• Providing and Operating the Platform — to create and maintain your Account, deliver the features and services of the Platform, process payments, and fulfil KYNK's obligations under the Terms of Service
• Identity Verification and Age Confirmation — to verify your identity and confirm that you meet the minimum age requirement. Government-issued ID data is deleted immediately after this purpose is fulfilled
• Personalisation and Matching — to personalise your experience, including curating your Feed, powering Playground matching, surfacing relevant Groups and Events, and recommending relevant products in the Shop
• Safety, Security, and Integrity — to protect the safety and security of the Platform and its users, detect and prevent fraud, investigate reported violations, and maintain technical integrity
• Communications — to communicate with you about your Account, subscription, Platform updates, and policy changes
• Legal Compliance — to comply with applicable laws, regulations, court orders, and valid requests from law enforcement and regulatory authorities
• Platform Improvement — to analyse how users use the Platform, identify areas for improvement, and test new features

What KYNK Does NOT Use Your Data For

• Advertising targeting — KYNK is an ad-free platform. Your personal data is never used to target advertising or generate advertising revenue
• Selling your data — KYNK does not sell your personal data to any third party under any circumstances
• AI training without consent — KYNK does not use your personal data or your content to train artificial intelligence or machine learning models without your separate and explicit consent

4 Special Category Data — Enhanced Protections

KYNK recognises that the information shared by its members includes data that attracts special protections under privacy law. This includes information about sexual orientation and sexual interests, kink practices and BDSM dynamics, relationship structures, and gender identity.

KYNK applies enhanced protections to this category of data:

• Processing on the Basis of Explicit Consent — where KYNK processes special category data about you, it does so on the basis of your explicit consent, which you provide by choosing to share this information in your profile
• Strict Purpose Limitation — special category data is used only for the purpose for which it was provided, primarily to enable matching and personalisation within the Platform
• No Advertising Use — special category data is never used for advertising purposes
• No Outing Without Consent — KYNK will never disclose information about a user's sexual interests, kink identity, or lifestyle choices to any third party without the user's consent, except where KYNK is legally compelled to do so by a valid court order

5 How We Share Your Information

KYNK shares your personal data only in the following circumstances:

With Other Users

KYNK makes the information you choose to share in your profile and through platform features available to other users, in accordance with your privacy and visibility settings. You control what other users can see about you through your Account Settings and Profile.

With Service Providers

KYNK shares personal data with trusted third-party service providers who assist in the operation of the Platform — including payment processing providers, identity and age verification service providers, cloud hosting and infrastructure providers, content moderation service providers, and customer support service providers. All service providers are subject to data processing agreements requiring them to handle your data with protections equivalent to those in this policy.

In Response to Legal Requests

KYNK may share your personal data with law enforcement authorities, courts, regulators, and other governmental bodies where required to do so by applicable law, court order, or valid legal process.

In Connection With Business Transfers

In the event that KYNK is involved in a merger, acquisition, or sale of assets, your personal data may be transferred to the acquiring entity, subject to the acquiring entity agreeing to honour the privacy commitments in this policy. You will be notified of any such transfer with 30 days' prior notice.

With Your Consent

KYNK may share your personal data with third parties in any other circumstances where you have given your explicit, informed, and specific consent to that sharing.

6 Cookies and Tracking Technologies

KYNK uses cookies and similar tracking technologies in connection with the operation of the Platform for the following purposes:

• Essential cookies — necessary for the operation of the Platform, including authentication, session management, and security
• Functional cookies — used to remember your preferences and settings to improve your experience
• Analytics cookies — used to understand how users interact with the Platform, identify areas for improvement, and monitor performance
• Security cookies — used to detect and prevent fraud, abuse, and other security threats

KYNK does not use advertising cookies or tracking technologies designed to build profiles for advertising targeting purposes. Full details are set out in KYNK's Cookie Policy, available at [Cookie Policy URL].

7 Data Retention

KYNK retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, to comply with legal obligations, and to protect the legitimate interests of KYNK and its users.

• Account Data — retained for as long as your Account is active. Following Account closure, the deletion process begins within 30 days
• Verification Data — government-issued identity document data is deleted immediately after your identity and age have been confirmed. A record of your verification status is retained for the lifetime of your Account
• Transaction Data — retained for the period required by applicable accounting, tax, and financial compliance laws
• Safety and Legal Preservation — data may be retained beyond normal retention periods where required for ongoing investigations, legal compliance, protection of platform security, or prevention of re-registration by permanently banned users

8 Deletion of Your Data

When you delete content from the Platform or close your Account, the following deletion process applies:

• Content Deletion — when you delete individual content items, that content becomes immediately invisible to other users. Full deletion from active systems is completed within 90 days
• Account Deletion — when you close your Account, your profile and content will no longer be visible to other users immediately. The deletion process begins within 30 days. Full deletion from active systems is completed within 90 days. Removal from backup systems may take up to a further 90 days

Once your Account has been permanently deleted, you will not be able to recover your Account, your content, or any other data associated with it. You are encouraged to export any data you wish to retain before closing your Account.

9 Your Rights Over Your Data

Subject to applicable law, you have the following rights in relation to your personal data held by KYNK:

• Right of Access — you have the right to request a copy of the personal data that KYNK holds about you
• Right to Rectification — you have the right to request that inaccurate or incomplete personal data be corrected
• Right to Erasure — you have the right to request the deletion of your personal data in certain circumstances
• Right to Data Portability — where required by applicable law, you have the right to receive a copy of your personal data in a structured, machine-readable format
• Right to Restrict Processing — you have the right to request that KYNK restricts the processing of your personal data in certain circumstances
• Right to Object — you have the right to object to the processing of your personal data in certain circumstances
• Right to Withdraw Consent — where KYNK processes your data on the basis of your consent, you have the right to withdraw that consent at any time
• Right to Complain — you have the right to lodge a complaint with the data protection supervisory authority in your jurisdiction

To exercise any of your rights, please contact KYNK at [privacy@kynk.com] or through the privacy controls available in your Account Settings. KYNK will respond to all valid requests within the timeframe required by applicable law.

10 International Data Transfers

KYNK may store and process your personal data in countries other than the country in which you reside. Where KYNK transfers personal data internationally, it will ensure that appropriate safeguards are in place to protect your data, including standard contractual clauses approved by the European Commission or equivalent authorities, and adequacy decisions issued by relevant data protection authorities.

11 Data Security

KYNK implements and maintains appropriate technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, alteration, disclosure, and destruction. These measures include:

• Encryption of personal data in transit over public networks
• Encryption of sensitive data at rest
• Access controls restricting access to personal data to authorised personnel only
• Regular security assessments and vulnerability testing
• Data breach detection and response procedures
• Contractual security requirements imposed on all third-party service providers

In the event of a data breach that is likely to result in a risk to your rights and freedoms, KYNK will notify you and the relevant supervisory authority as required by applicable law and as promptly as practicable.

12 Changes to This Policy

We may update this Privacy Policy from time to time. Where we make a material change, we will notify you at least 30 days before the change takes effect, via email to your registered address or through an in-app notification. We will clearly describe what is changing and why.

Where changes involve new or different processing of special category data, we will obtain your explicit consent before that processing begins. Your continued use of the Platform after the effective date of any material change constitutes your acceptance of the updated policy.

13 Contact for Privacy Matters

If you have any questions, concerns, or requests relating to your personal data or to KYNK's privacy practices, please contact us:

• Email: [privacy@kynk.com]
• Post: [KYNK registered address, marked for the attention of: Privacy]

If your concern is not resolved to your satisfaction through KYNK's internal process, you have the right to escalate your complaint to the data protection supervisory authority in your jurisdiction.