Last updated: 20 October 2026 Privacy Policy for the "Po100gram" service. This policy is deliberately written in plain language: you should be able to understand what happens to your data without a lawyer. Legal references appear only where they explain something. 1. Who is responsible for your data The data controller is the Administration of the "Po100gram" service. For anything about your data: privacy@po100gram.com Also: in the app (Profile → Support) or via the Service's Telegram bot. The servers holding your data are located in Germany (European Union). Backups are kept there too, encrypted. We do not transfer your data outside the European Economic Area. We process data of people located in the EU, so the General Data Protection Regulation (GDPR) applies to us. 2. What data we collect Account: — phone number and your Telegram ID, if you registered through the Telegram bot. When registering with Apple or Google a phone number is optional: you may enter it yourself, and it is then stored as unconfirmed until you confirm it in the bot; — if you added Apple or Google sign-in — the permanent identifier that provider issues and the email address it passes to us (with Apple this may be a relay address at privaterelay.appleid.com). We never see your Apple or Google password and cannot see it; — if you turned on browser notifications — the delivery address issued by your own browser, two encryption keys and a short description of the device, so you can tell in settings which device it is; — if you use the app from the App Store or Google Play and allowed notifications — the device token issued by Apple or Google, and which platform it is (iOS or Android). A token is a delivery address, not an identifier of you: it changes on its own, becomes a different one when the app is reinstalled, and tells us nothing about you. The app does not read or collect advertising identifiers (IDFA, GAID); — name, age and, optionally, an "about me" text; — profile photo; — language, theme and notification settings. Verification (optional): — a selfie compared against your profile photo. Only moderators see it. The image is deleted 90 days after the moderator's decision; the verification status remains; — additional confirmation of age, if the selfie was not enough. Sending it is not required, and it need not be an official document — anything showing your age will do. It goes only to support, is stored as a support request and is deleted together with it. Location: — your position when you drop a pin, see a distance or a route. There is no background tracking; — while alerts about people nearby are on (they are on by default), we keep your last position. It is refreshed only when you open the map and is used only to tell you about a pin close by. You can turn the alerts off in Settings at any time and the position is erased immediately; — your approximate city (never coordinates) is shown to your friends on your profile. Meetings: — pins: format, description, tags, time, place, number of guests; — a pin's condition, if its author set one: the age range and gender they are looking for. Everyone who sees the pin sees it, including those who do not match, so they understand why they cannot respond; — confirmation of a meeting by location: we check that both people are genuinely together (within 30 metres) and keep the fact of that check and the coordinates at that moment; — who is coming: on a group pin everyone interested sees that list; on a "one person only" pin, just the pin owner; — a shared photo confirming the meeting. It shows the people who met — that is, not only the person who sent it. ONLY our team sees this photo; it is never shown to other users. It is kept for 90 days after the moderator's decision and then deleted. If anyone shown in it deletes their account, the photo is deleted at once, without waiting for that period. Profile photos: — up to six photos separate from your avatar. You choose how long each lives when you upload it: a day, a week, a month, or as long as the account exists. Once the time is up, the photo is deleted automatically. Posts feed: — your posts: text and up to five photos. Posts live 7 days, then are deleted for good together with their photos, likes and comments; — your likes, comments and replies to comments; likes on comments; — reports you filed about other people's posts or comments. Communication: — chat messages, reactions, delivered/read marks, edit history (only moderators see the history); — video notes: a short video from the front camera. Kept like any other chat video — 7 days; — messages you deleted: they are gone from the chat for both of you, but the record stays in the database for handling reports. Only verified users can delete messages; — photos and videos in chats are kept 7 days and then deleted automatically (the text remains). They may be reviewed by moderators for prohibited content — images of minors, violence, drugs or fraud; — video calls: audio and video go directly between users (through our relay server in encrypted form when needed) and are never recorded. We keep only call metadata (who, with whom, when, how long) for up to 24 hours, then only anonymous per-account counters; — group chats: members, messages, reactions. Reputation and connections: — reviews after confirmed meetings; — friendships and friend requests; the list of people you blocked (the blocked person is not told); — achievements (collectible cards) and your position on the leaderboard. You can opt out of the leaderboard in settings; — your "Friends → Discover" profile (interests, what you are looking for, city or district) — visible to others only if you turned that on; your phone number is never shown there. Safety: — trusted contacts (up to 3) opt in themselves in the Telegram bot and can withdraw at any time. On an SOS alert we send them only your name, age, the name and age of the person you are meeting, the meeting place, and the time and place of your last known position with a map link — no photos, no phone numbers. Our team is notified too; — warnings, freezes and blocks issued by our team, and their reasons. Enquiries: — internal flags about you (a colour mark), moderators' notes, and the history of your names and profile photos. You do not see these: they exist so the next moderator does not start the same complaint from nothing, and so a person cannot change their name and photo to escape a decision; — conversations with the Telegram bot that did not become a support request (what you wrote and what the bot answered), so we can check the bot works; phone numbers in those records are masked; — support requests from the site and Telegram. Technical data: — device type, language, time zone, IP address, pages visited. Page statistics are aggregated: individual profiles and chats are not distinguished and are counted together as "a person's profile" or "a chat". All data is encrypted in transit (TLS). This is NOT end-to-end encryption: authorised moderators can read message content when handling reports, automatic spam flags, "Unsafe" button cases, and when checking messages against a list of prohibited words (drugs, fraud, intimate services). That check is performed as a database search, so a moderator sees only the matching messages, not the conversation as a whole. Only team members with individually granted permissions can access the admin panel, and each permission is granted separately. 3. Why we collect it and on what legal basis The GDPR requires a legal basis for every processing activity. Here they are. Performance of our contract with you (Art. 6(1)(b) GDPR) — without this the service simply would not work: — sign-up, sign-in and running your account; — pins, meetings, routes, chats, video calls, friends, groups; — reviews after confirmed meetings; — service notifications in Telegram about requests, messages and meeting reminders. Your consent (Art. 6(1)(a) GDPR) — you give it yourself and can withdraw it at any time, without explanation: — access to your location; — storing your last position for nearby alerts; — showing your profile in "Friends → Discover"; — going through selfie verification and sending additional confirmation of age; — publishing posts in the feed and adding photos to your profile. You decide what to publish, and you pick the retention period when you upload. Withdrawing consent does not affect the lawfulness of processing before withdrawal and does not cut you off from the rest of the service. Our legitimate interests (Art. 6(1)(f) GDPR) — the safety of people who meet through the service, and protecting the service itself: — moderation, handling reports, freezing and blocking offenders; — confirming meetings with a shared photo, so that meetings, reviews and ratings reflect reality; — automatic detection of spam, advertising and fraud in chats; — checking photos and videos for prohibited content; — preventing sign-ups by minors, and the phone blacklist; — the leaderboard (you can opt out in settings); — moderating the feed: handling reports about posts and comments, removing entries that break the rules; — keeping deleted messages and posts for handling reports: without them a moderator could not see what a person was actually penalised for; — technical analytics, protection against abuse and overload; — operational announcements about the service. You have the right to object to any of these — see section 6. Legal obligation (Art. 6(1)(c) GDPR): — responding to lawful requests from law enforcement. We do not use your data for advertising, do not profile you for marketing, and do not sell data to anyone. 4. Who we share data with — Telegram — for sign-in, notifications and SOS alerts. Telegram is a SEPARATE data controller, not our processor: what you do inside Telegram is governed by their privacy policy, not ours; — our hosting provider (servers in Germany, EU) — data storage; — OpenStreetMap / OpenFreeMap mapping services — map, address search, routes, nearby cafés. They receive only coordinates or a search query, with no name, phone number or identifier; — Apple and Google — only if you chose to sign in through them. They confirm it is you and pass us your permanent identifier and email address. Like Telegram, they are SEPARATE data controllers: what they know about you is governed by their policies, not ours; — your browser's push delivery service (Google, Apple or Mozilla, depending on the browser you use) — only if you turned on browser notifications. They deliver the notification to your device; its contents are encrypted with keys your browser issued and those services cannot read them; — Apple Push Notification service and Firebase Cloud Messaging — only if you use the app and allowed notifications. They carry the notification to your phone and see its title and text, which is why chat notifications carry only the sender's name, never the message itself; — law enforcement — only upon a lawful request. Separately, about what other users see: posts in the feed, comments, profile photos and video notes are visible to those you addressed them to — the feed is seen by all users of the service, profile photos by anyone who opens your profile, and a video note only by your chat partner or the members of the group. People you have blocked see none of it. The list of processors may change; we provide the current one on request by email. 5. How long we keep data — account data — while the account exists; — after account deletion: photos, pins, reviews, selfies and other data disappear immediately; the profile (name, age, phone) and chats live for 3 more days marked "deleted", then are erased for good; — photos and videos in chats, including video notes — 7 days; — profile photos — for the period you chose: a day, a week, a month, or while the account exists; — posts in the feed together with their photos, likes and comments — 7 days; — messages you deleted — while your account exists (as evidence in case of a report); they disappear from the chat immediately; — shared meeting photo — 90 days after the moderator's decision, or immediately if anyone shown in it deletes their account; — verification selfie — 90 days after the moderator's decision; — video call metadata — up to 24 hours; anonymous counters — while the account exists; — SOS alerts and "I'm OK" timer data — 7 days; — bot conversations that did not become support requests — 30 days; — IP addresses and visit data — up to 90 days; — an Apple or Google link — until you unlink it in Settings or delete the account. When you unlink Apple or delete the account, we separately tell Apple to forget the connection — otherwise "Po100gram" would stay in the app list in your iPhone settings even after the account is gone; — a browser notification subscription — until you turn notifications off or withdraw the permission in the browser; subscriptions that have stopped working are erased automatically at the first attempt to send; — a device token from the app — while the app is installed on the phone. When you delete the app, Apple or Google tells us so at the first attempt to send, and the token is erased automatically; — internal flags and moderator notes about you, and the history of your names and profile photos — for as long as the account exists; — confirmation of a meeting by location — together with the meeting itself; — database backups — up to 14 days, in encrypted storage; — a phone number on the blacklist (confirmed minor, serious misconduct, ban evasion) — indefinitely, since otherwise a block would be meaningless. All that person's other data is deleted immediately. These periods are not a declaration: a daily automated job enforces them and erases expired data. 6. Your rights Under the GDPR you have the following rights. To use any of them, write to privacy@po100gram.com. We answer within one month; for complex requests that period may be extended by two further months, and we will tell you and explain why. — Access (Art. 15): confirmation that we process your data, and a copy of it. — Rectification (Art. 16): correct inaccurate data. You can change your name, age and "about me" yourself in your profile. — Erasure (Art. 17): delete your account and data. You can do this yourself in Settings → "Delete account"; step-by-step instructions and the full list of what is deleted: po100gram.com/en/legal/delete-account. Some data may remain where the law requires us to keep it or where it is needed to protect other people's rights (for example, a number on the blacklist). — Restriction (Art. 18): ask us to pause processing while we consider your objection or a dispute about accuracy. — Portability (Art. 20): receive the data you provided in a structured, machine-readable format (JSON), or ask us to pass it to another service where technically feasible. — Objection (Art. 21): object to processing based on our legitimate interests. We will stop unless we can demonstrate compelling legitimate grounds that override your interests. You may object to operational announcements at any time, with no justification needed. — Withdraw consent: any consent (location, discover profile, verification) can be withdrawn in settings or by email, without giving a reason. — Complaint to a supervisory authority (Art. 77): if you believe we have infringed your rights, you may complain to the data protection authority of your country of residence or of the place of the alleged infringement. We would appreciate hearing from you first — most things are resolved faster directly. Exercising your rights is free of charge. We may ask you to confirm your identity if it is unclear that the request is yours, but we will ask only for the minimum needed. 7. Cookies and data on your device We use no advertising networks and do not track you across other sites. Strictly necessary (the service does not work without them; no consent required): — session cookie — keeps you signed in. Your own preferences (stored only in your browser and never sent anywhere): — theme, language, map filters, notification sound, last known position, and whether you have seen the intro. Referral analytics: — when you arrive via a link like po100gram.com/r/code, we count the visit itself, and the campaign code travels onward in the page address. Nothing is stored on your device, the code contains no name, and it is never used to show you advertising. In the installed app, one more thing is stored on the phone itself and sent nowhere: — whether the Face ID / Touch ID / fingerprint lock is on. The lock is the phone's own work: we receive no fingerprint, no face data, not even a yes-or-no answer on the server — the app simply does not show the screen until the phone recognises its owner. The setting applies only to the device where you turned it on. You can clear all of this by deleting site data in your browser settings, or, in the app, by deleting the app itself. 8. Automated decisions Chat messages and pin texts are automatically checked for signs of spam, advertising and fraud. The automation only FLAGS suspicious cases for review — a human always makes the decision to warn, freeze or block. There is no processing that produces legal or similarly significant effects for you based solely on automated means (Art. 22 GDPR). Selfie verification and photo confirmation of meetings are likewise reviewed by a person. 9. Security — data is encrypted in transit (TLS); — backups are encrypted (AES-256); — admin panel access is split into individual permissions granted personally; some administrators can access only the chats that have a report on them; — access from Russian and Belarusian addresses is blocked; — data is stored on servers in Germany (EU). If a data breach occurs that is likely to result in a high risk to your rights, we will notify the supervisory authority within 72 hours and you without undue delay. No system is perfectly secure. We cannot guarantee absolute safety, but we commit to reasonable measures and to telling you honestly if something goes wrong. 10. Children The service is for people aged 18 and over only. We do not knowingly collect children's data. If an account turns out to belong to a minor, their data is deleted immediately and the phone number is blacklisted to prevent re-registration. If you believe a child has created an account, please write to us. Our child safety standards: po100gram.com/en/legal/child-safety. 11. Changes to this policy We may update this policy. We will announce material changes in the app or via the Telegram bot at least 14 days before they take effect. Changes affecting processing based on consent will require your fresh consent — silence is not consent. The date of the last update is always shown at the top. 12. Contact privacy@po100gram.com In the app: Profile → Support The Service's Telegram bot Technical note: the service was built independently by its developer. That does not limit your rights under the GDPR, nor does it relieve us of our obligations as a data controller.