Privacy Policy

Last updated: May 16, 2026

Effective date: May 16, 2026

Please read this Privacy Policy (the "Policy") carefully. It explains what personal data we process when you use the Truo application, why we process it, how we use it, to whom we may disclose it, how long we keep it and what rights you have under Regulation (EU) 2016/679 on data protection (the "GDPR").

This Policy applies to the use of the Truo application, the Truo website, if available, and other services operated under the Truo brand, to the extent that they do not have a separate policy. The Policy forms part of the Truo Terms and Conditions of Use.

In brief

This section is only a summary. The full Policy below remains applicable.

• Truo processes data necessary for account creation, profile display, matching, messaging, safety, moderation, support and premium features.
• The application may request access to location, but access to the device location is not mandatory. You may use Truo without allowing location access.
• If you refuse location access, certain features based on distance, area or nearby profiles may be limited, less accurate or unavailable.
• Truo does not display your exact location to other users and does not publish precise GPS coordinates in the profile.
• We do not sell your personal data.
• As of the date of this Policy, Truo does not display third-party behavioral advertising and does not share personal data with advertising partners for ad targeting.
• We do not collect or store your bank card data. Payments are processed through the App Store, Google Play or other available payment processors, as applicable.
• We may use algorithms for recommendations, profile ordering and safety, but we do not make solely automated decisions that produce legal effects concerning you or similarly significant effects.
• You may request access, rectification, erasure, restriction, portability or objection, under the GDPR.
• Requests regarding personal data may be sent to contact@truo.ro.

1. Data controller

The data controller is NEXT LEVEL ENTERTAINMENT SRL, with its registered office in Drobeta-Turnu Severin, 17A George Coșbuc Street, registered with the Trade Register under no. J2026008954000, tax identification number 53863207 ("Truo", "we", "the controller").

Address for personal data requests: contact@truo.ro

This address is intended for personal data requests and the exercise of rights provided by the GDPR. To identify the account, the request must be sent from the email address associated with the Truo account or must include that address in the message.

As of the date of this Policy, we have not appointed a Data Protection Officer ("DPO"), because we have assessed that the appointment is not mandatory at this time. If the situation changes or if we appoint a DPO, we will update this Policy and publish the relevant contact details.

2. What personal data we process

We process the data necessary for the operation of a dating application, for user safety, account administration and, if you choose, for premium features, support or optional profile verification.

2.1. Account and authentication data

We may process:

• first name;
• email address;
• password or other authentication data, stored securely;
• account status;
• account creation date;
• date of last authentication;
• information necessary for password reset, account confirmation or account security.

We do not usually request the last name.

2.2. Data from authentication through third-party services

If you choose to create an account or log in through a third-party service, such as Apple, Google, Facebook or a similar service, we may receive certain data permitted by you and by the settings of that service, such as email address, account identifier, display name or profile photo.

We do not receive the password of your account from the third-party service. The third-party service will process the data according to its own privacy policy.

If Truo does not offer or activate authentication through third-party services, this section applies only from the moment such a feature becomes available.

2.3. Profile data

We may process the data you add to your profile, such as:

• photographs;
• profile description;
• age or date of birth, if necessary to verify 18+ eligibility;
• gender, preferences, matching criteria or visibility settings, if you choose to complete them;
• city or approximate area, if you choose to provide them or if they are necessary for the operation of the application;
• interests, answers to profile questions or other information you choose to publish;
• other information you voluntarily enter in the profile.

Please do not enter in your profile data that you do not want to be visible to other users.

2.4. Location data

The application may request access to the device location for features such as displaying relevant profiles, calculating approximate distance, recommendations based on area, safety, abuse prevention and proper operation of the service.

Location access is not mandatory. You may use the Truo application without allowing access to the device location. In that case, certain features based on location, distance or displaying nearby profiles may be limited, less accurate or unavailable.

Truo does not display your exact location to other users and does not publish precise GPS coordinates in the profile.

Depending on the permissions granted, device settings and available features, we may process exact or approximate location. For display to other users, we may use derived information, such as approximate distance or general area, without publishing precise GPS coordinates.

Location data may be used for:

• displaying relevant profiles;
• calculating approximate distance;
• area-based or proximity-based features;
• security and abuse prevention;
• detecting unusual or fraudulent use of the account;
• improving the operation of the application.

You may change location permissions at any time from your device settings.

2.5. Data regarding use of the application

We may process information generated through use of the application, such as:

• swipes, likes, matches and basic interactions;
• accessing certain features;
• in-app preferences and settings;
• views, actions and technical events necessary for operation;
• information about how you interact with profiles, recommendations and features;
• information necessary for security, abuse prevention and improvement of the service.

2.6. Recommendations, profile ordering and limited profiling

We may use information such as profile preferences, approximate area, age, visibility settings, interactions, likes, matches, in-app activity and safety signals to recommend profiles, order the displayed profiles and improve the relevance of the service.

These processing activities may involve profiling within the meaning of the GDPR, to the extent that we use data to estimate preferences or relevance. We do not use this data for solely automated decisions that produce legal effects concerning you or similarly significant effects.

You may influence recommendations through the settings available in the application, by updating your profile and by changing device permissions, where applicable.

2.7. Messages and interactions

We process messages sent and received in the application, as well as metadata necessary for the operation of the service, such as the date and time of the message, sender, recipient and delivery status.

Messages are processed for delivery, operation of conversations, safety, moderation, investigation of reports and compliance with legal obligations.

We do not systematically read all conversations. We may analyze specific conversations or content when there are reports, indicators of abuse, fraud, spam, harassment, breaches of the Terms or legal obligations.

If a user requests a copy of their personal data, it may include the messages you sent to that user, to the extent that they are part of that user's conversations and in accordance with applicable law. We cannot guarantee deletion of copies or screenshots made by other users.

2.8. Reports, blocks and moderation

If you report a user or you are reported, we may process:

• the content of the report;
• the profiles involved;
• messages or content relevant to the report;
• screenshots or information submitted by users;
• measures taken following the review;
• the history of violations relevant to community safety.

If you submit a report, we may tell you, in a reasonable form, whether we have taken measures, without disclosing excessive personal information about the reported user.

2.9. Subscriptions and purchases

If you use premium features, we may process information such as:

• subscription status;
• purchased product;
• validity period;
• purchase history;
• confirmations received through the App Store, Google Play or other available payment processors;
• information necessary for purchase support.

We do not collect or store your bank card data when payment is processed through the App Store or Google Play. If in the future we activate direct payments or other payment processors, payment data will be processed by the payment processor according to its own terms and policies, and Truo will receive only the information necessary to confirm payment, activate the premium feature, provide support and keep legal records.

2.10. Technical and security data

We may process technical data necessary for the operation and protection of the application, such as:

• IP address;
• device technical identifiers;
• tokens for push notifications;
• device type, operating system and application version;
• authentication logs;
• technical errors and crash logs;
• suspicious events or anti-fraud signals;
• technical settings necessary for application operation.

This data is used for security, diagnostics, abuse prevention, prevention of fake accounts, account protection and maintaining the operation of the application.

2.11. Data for optional profile verification

If this feature is available and you choose to use it, we may process one or more images, selfies or a short video recording, exclusively for profile verification, prevention of fake accounts, fraud fighting and community safety.

These materials are not displayed publicly, except for a possible "verified profile" indicator, if the feature is available.

If we use facial comparison technology involving biometric data for the unique identification of a person, we will request your explicit consent before using this feature and will provide additional information about the processing.

If we introduce identity document verification, we will explain separately what data is collected, who verifies it, how long it is kept and whether third-party providers are used. Identity document verification will not be mandatory unless necessary for safety, fraud prevention, legal compliance or for a feature that requires such verification.

2.12. Support data

If you contact us, we may process:

• email address;
• message content;
• account information;
• documents, screenshots or other information that you voluntarily send to us;
• history of communication with us.

3. Sensitive data or special categories of data

Truo is a dating application. Depending on the information you choose to enter in your profile, preferences, photographs or messages, it may reveal sensitive information about you, including aspects related to private life, relationships, personal preferences, sexual life or sexual orientation.

We do not ask you to publish sensitive data and we recommend that you do not include very personal information, banking details, passwords, identity documents or information that you do not want to make known to other users.

Some information that you choose to voluntarily enter in your profile, preferences, photographs or messages may reveal special categories of data, including data concerning sexual life or sexual orientation. If you choose to provide such information, we will process it only to the extent necessary to provide the service, according to your choices and, where necessary, on the basis of explicit consent.

You may avoid providing this information or delete it from the profile, depending on the available settings.

4. Why we process data and what the legal basis is

We process your data only for specified, explicit and legitimate purposes.

We do not use your data for solely automated decisions that produce legal effects concerning you or similarly significant effects. Algorithms may suggest profiles, matches or display orders, but these recommendations are indicative and may be influenced by your settings and activity.

5. Where we obtain data from

We obtain the data:

• directly from you, when you create an account, complete your profile, send messages, use the application or contact us;
• automatically, through use of the application, such as technical data, logs, operation events and, if you allow it, location data;
• from your device, depending on the permissions granted, for example for notifications, photographs, camera or location;
• from third-party authentication services, if you choose to use them;
• from app stores or payment processors, such as the App Store or Google Play, for confirmation of subscriptions and purchases;
• from other users, when they submit reports or information related to interactions with you.

6. To whom we disclose data

We disclose data only to the extent necessary for the operation of the service, safety, support, legal obligations or the exercise of our rights.

6.1. Other users

Your profile may be visible to other users, depending on the application settings and features. For example, your first name, photographs, description, certain selected preferences, approximate distance or general area, if these features are available, and any verified profile status may be visible.

We do not display your exact location to other users and do not publish precise GPS coordinates in the profile.

Messages are visible to the users to whom you send them. If a user requests the export of their data, the export may include messages received from you, in accordance with applicable law.

6.2. Technical providers and SDKs

We may use providers that help us operate the application, such as providers of cloud infrastructure, databases, storage, backup, email, push notifications, error monitoring, security, anti-fraud, technical analytics, subscription processing, user support or optional profile verification.

These providers process the data according to our instructions, on the basis of contractual confidentiality and security obligations, and should not use the data for their own purposes incompatible with this Policy.

When we publish a list of providers or SDKs used, it may be included in the application, on the website or in a separate section of this Policy.

6.3. App stores and payment processors

The App Store, Google Play or other available payment processors may process payments and subscriptions according to their own terms and policies. We receive only the information necessary to confirm the purchase, activate premium features, provide support and keep records.

6.4. Authorities and legal situations

We may disclose data to public authorities, courts, lawyers, consultants or other relevant parties when we have a legal obligation, when necessary for the investigation of serious abuses or for the establishment, exercise or defense of a right.

We may retain and disclose certain data for a longer period if there is a legal request, an investigation, a dispute, a request from an authority, fraud prevention needs or a need to protect user safety.

6.5. Business transfer

If the company, application or certain assets are transferred, reorganized or sold, the data may be transferred to the successor entity, in accordance with the law and with protection of your rights.

We do not sell your personal data.

6.6. Advertising and advertising partners

As of the date of this Policy, Truo does not display third-party behavioral advertising and does not share personal data with advertising partners for ad targeting.

If in the future we introduce behavioral advertising, advertising partners, tracking pixels, marketing SDKs or similar technologies, we will update this Policy, publish relevant information and request consent where required by law.

7. International transfers

We aim to use, as far as possible, infrastructure and providers located in the European Union or the European Economic Area.

However, some technical providers may involve processing or access from outside the EEA. In such cases, we use appropriate safeguards provided by the GDPR, such as adequacy decisions, Standard Contractual Clauses, additional security measures or other applicable legal mechanisms.

Additional details may be provided on request, to the extent permitted by law and by confidentiality obligations applicable to providers.

8. How long we keep data

We keep data only for as long as necessary for the purposes described in this Policy, for the operation of the account, for compliance with legal obligations, for security, for dispute resolution or for the defense of our rights.

If we cannot indicate an exact period, we use criteria such as the duration of the account's existence, applicable legal obligations, the risk of fraud or abuse, the existence of a report, the need to defend rights and technical backup cycles.

By way of guidance:

• account and profile data are kept for the duration of the account's existence;
• photographs and profile description are kept for the duration of the account's existence or until you delete them;
• exact location data, if collected, are kept only for as long as necessary for the active feature, security, abuse prevention or other purposes described in this Policy;
• approximate or derived location data may be kept for the duration of the account's existence or for as long as necessary for the operation of the service and safety;
• messages are kept for the duration of the account's existence and according to the application's features; in case of reports, abuse, disputes or legal obligations, they may be kept for a longer period for investigations and safety;
• data regarding reports and moderation may be kept for as long as necessary for analysis, abuse prevention, community protection and defense of rights;
• data of accounts that are suspended, blocked or associated with abuse may be kept for a longer period, to the extent necessary for the prevention of fraud, fake accounts, harassment or repeated violations;
• optional verification data are kept for as long as necessary for verification and maintaining verified profile status, if the feature is active; afterwards, they may be deleted or anonymized, except in cases of fraud, abuse, dispute or legal obligation;
• if biometric data are used for the unique identification of a person, we will establish and communicate a specific retention period before activating the feature;
• purchase and subscription data are kept according to applicable tax, accounting and legal obligations;
• technical and security logs are generally kept for limited periods established according to security risks, technical needs and applicable legal obligations;
• support communications are kept for as long as necessary to resolve the request and to keep a record of the interaction;
• evidence of consents granted may be kept for as long as necessary to demonstrate compliance with the law.

After account deletion, your profile will no longer be visible to other users. We will delete or anonymize the data from active systems, except for data that we must or have the right to keep for legal obligations, security, fraud prevention, dispute resolution or defense of rights.

We may apply a limited retention period after account closure for safety, abuse prevention and request resolution. For accounts closed in the ordinary course, this period is usually up to 90 days, except where law, security, disputes or legal obligations justify a longer period. For blocked accounts or accounts associated with abuse, we may retain relevant data for a longer period, for as long as necessary to protect the community and prevent repeated violations.

Data may temporarily remain in backups until overwritten according to ordinary technical cycles. We cannot control copies made by other users, such as screenshots of messages or photographs.

8.1. Inactive accounts

If an account remains inactive for an extended period, we may notify the user and may deactivate, hide or delete the account according to our internal policies and applicable legislation. We may consider an account inactive when there are no logins or relevant activity for a long period, for example 24 months.

9. Your rights under the GDPR

Under the conditions provided by the GDPR, you have the following rights:

• the right of access to your personal data;
• the right to rectification of inaccurate or incomplete data;
• the right to erasure of data, where applicable;
• the right to restriction of processing;
• the right to data portability, where applicable;
• the right to object to certain processing based on legitimate interest;
• the right to withdraw consent, where processing is based on consent;
• the right not to be subject to a solely automated decision that produces legal effects or similarly significant effects concerning you;
• the right to lodge a complaint with the competent data protection authority.

Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

To exercise your rights, requests may be sent to contact@truo.ro. We may request reasonable additional information to verify your identity, for example confirmation through the email associated with the account. We will respond without undue delay, within the time limits provided by law.

The competent authority in Romania is the National Supervisory Authority for Personal Data Processing ("ANSPDCP"). If you are not satisfied with how we respond to your request, you have the right to contact this authority.

10. Data security

We apply reasonable technical and organizational measures to protect personal data, such as:

• encryption in transit;
• secure storage;
• access control;
• limitation of internal access to data;
• authentication and account protection measures;
• technical monitoring;
• security logs;
• backups;
• incident management procedures.

However, no IT system is 100% secure. Please protect your password, access codes and email account and notify us immediately at contact@truo.ro if you suspect unauthorized access to your account.

11. Minor users

Truo is intended exclusively for persons who are at least 18 years old.

We do not knowingly collect data from minors. If we learn that an account belongs to a person under 18 years old, we will close the account and take reasonable measures to delete the related data, in accordance with the law.

If you have reason to believe that a minor is using Truo, please contact us at contact@truo.ro.

12. Messages, reporting and moderation

Messages and interactions are processed for delivery, operation of conversations, safety and moderation.

We may intervene specifically when there are:

• reports from users;
• indicators of fraud, spam, harassment or abuse;
• attempts to create fake accounts;
• risks to community safety;
• legal obligations.

We may use both automated tools and human review to detect and manage abuse, spam, fraud or breaches of the Terms. Measures may include a warning, limiting visibility, account suspension, account blocking, retention of relevant evidence or transmission of information to authorities, where the law permits or requires this.

13. Essential communications and marketing

We may send you essential communications related to the account, security, operation of the service, changes to the Terms or Policy, subscriptions, payments or other aspects necessary for provision of the service.

Promotional messages will be sent to you only if you have opted in to them, where the law requires consent. You may withdraw your consent at any time from the available settings, by unsubscribing or through a request sent to contact@truo.ro.

We do not make use of the service conditional on acceptance of promotional messages.

14. SDKs, notifications, cookies and similar technologies

The application may use SDKs and similar technologies for operation, security, authentication, push notifications, location, error monitoring, technical analytics, fraud prevention, subscription processing and performance improvement.

These technologies may collect technical data, such as device identifiers, notification tokens, application version, device type, crash logs, operation events or, if you allow it, location information.

If we use a website that uses cookies, we will publish the relevant information in a Cookie Policy or in a dedicated section. Cookies or similar technologies that are not strictly necessary will be used in accordance with applicable legal consent requirements.

15. Changes to the Policy

We may update this Policy to reflect changes to the application, the way we process data or applicable law.

We will publish the updated version in the application and/or send reasonable notice when the changes are important. The date of the last update will be displayed at the beginning of the document.

Continuing to use the application after the Policy is updated means that you have acknowledged the new version. Where processing requires your consent, we will request it separately, in accordance with the law.

16. Personal data requests

For the exercise of GDPR rights or for requests strictly related to the processing of personal data, the following address may be used:

Email: contact@truo.ro

If you are not satisfied with our response, you have the right to contact the National Supervisory Authority for Personal Data Processing ("ANSPDCP").

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End of the Privacy Policy