Privacy policy

1. Controller

TechMentum Consulting LTD (Private company limited by shares (Cyprus))

Registered office: Gladstonos 12, Paphos, Paphos 8046, Cyprus

Company registration: HE 452035

Register authority: Department of Registrar of Companies and Intellectual Property (Cyprus)

Authorised director(s): Paolo Sfilio

VAT identification number: CY 60042048Q

Contact: p.sfilio@techmentum.eu · +49 157 35513469

Product brand: Adonis

Data protection officer: Paolo Sfilio, ps@paolo-sfilio.com, Paolo Sfilio, Con. Palaiologou 17, Yeroskipou 8201, Cyprus

2. Categories of data subjects

• Registered users of the service
• Non-registered dating contacts whose data users upload
• Visitors of public share links (pseudonymised snapshots)

3. Categories of personal data

Account data

Email, authentication data (Supabase Auth), profile fields such as display name, language, plan, user facts and style notes.

User content

Advisor chats, Match Memory, Match Profile, Real Talk messages, date summaries and uploaded profile/chat screenshots.

Non-registered dating contact data

Names, platform, chat content, images and derived analyses that users import via matches. Adonis does not create accounts for these individuals.

Images and screenshots

Profile images and screenshots are stored in private storage buckets under the user id and may be sent to Gemini for extraction.

Transcripts and audio

Voice input is converted to text via ElevenLabs STT. Audio is not persistently stored in Adonis. Optional TTS from short scripts.

AI inputs and outputs

Server-side prompts to Gemini include user and match context. Responses are stored in structured form (e.g. advisor_messages.ai_response).

Note: Model training configuration is not fully verified yet (LEGAL_REVIEW_REQUIRED).

Personal Insights

Optional cross-match behaviour analysis (premium, opt-in). May derive patterns from Real Talk and advisor history.

Share links

Anonymised snapshots with token-hash storage, maximum 7 days, public access by token only.

Billing

Checkout is currently a placeholder. Planned: Stripe subscription and invoice metadata.

Logs and security

Usage counters, admin Gemini logs (configurable), ops error logs without full chat text by default.

4. Purposes and legal bases (proposed)

Binding legal bases are PROPOSED and require legal review.

5. Art. 9 risk

Intimate or sexual content may appear in user uploads. Art. 6(1)(f) does not create an Art. 9 exemption. Adonis does not solicit such data and rejects misuse.

6. Recipients and subprocessors

See the subprocessors page. Core providers: Supabase, Google Gemini, ElevenLabs, Netlify, Stripe (planned).

7. International transfers

Gemini region: LEGAL_REVIEW_REQUIRED. ElevenLabs region: LEGAL_REVIEW_REQUIRED. Transfer mechanisms: LEGAL_REVIEW_REQUIRED.

8. Retention

• Share links: 7 days
• Account data: Until the user deletes the account
• Temporary admin exports: 24 hours
• Extraction review leftovers: 30 days
• Billing records: 7 years (target)
• Security logs: 90 days (target)
• Gemini admin logs: Until admin purge; default logging mode off in production

9. Your rights (Art. 15-22 GDPR)

• Access, rectification, erasure, restriction
• Data portability
• Object to processing based on Art. 6(1)(f)
• Withdraw consent
• Lodge a complaint with a supervisory authority

Submit requests to privacy@techmentum.eu.

To exercise your data protection rights, you can contact the privacy email address stated in this privacy notice.

• You can submit requests by email.
• We may need additional information to securely match your request.
• We do not routinely ask for a copy of your ID.
• Requests about third-party content are reviewed manually.
• Responses are generally sent electronically.

10. Right to complain

Supervisory authority: Office of the Commissioner for Personal Data Protection (Cyprus)

11. Contact without an account

Data subjects without an account may contact privacy@techmentum.eu. More information: https://adonis-beta.netlify.app/privacy-request