Privacy Policy and User Agreement

Privacy Policy

This Privacy Policy explains how Social Spot collects, uses, stores, shares, transfers, and deletes personal data when you use the application, website, or related services, including login through Telegram and optional AI-powered features.

1. Who We Are

Social Spot is operated by Tsifrovye Servisy, TOO, Republic of Kazakhstan.

Address: ul. Kairbaeva 34, Pavlodar, Pavlodar region, Kazakhstan
E-mail: support@social-spot.kz
Website: https://social-spot.kz

2. Data We Collect

Depending on how you use the Service, we may collect the following categories of data:

• account and profile data, such as name, age, date of birth, gender, photos, biography, interests, language, and profile preferences;
• Telegram authentication data, such as Telegram user ID, username, profile photo (if available), and other basic account identifiers required to sign in or link your account;
• contact and technical authentication data, such as device identifiers, login data, session information, and communication details you provide to us;
• user-generated content, such as messages, profile descriptions, media, reactions, reports, blocks, verification submissions, and support requests;
• approximate or precise location data, only if you grant permission and use geolocation-based features;
• usage and diagnostic data, such as app events, crash logs, IP address, browser type, device model, operating system, interaction data, viewed profiles, likes, matches, and session timestamps;
• purchase and subscription metadata necessary for in-app purchases, such as product identifiers, transaction status, receipt or transaction references, subscription status, and billing support information received from Apple, Google, or other authorized payment platforms. We do not store full payment card details ourselves;
• safety and moderation data, such as complaints, reports, internal review notes, verification signals, and information reasonably necessary to detect fraud, scams, spam, policy violations, or harmful behavior.

3. Why We Use Data

We use personal data to:

• create and manage user accounts;
• provide matching, messaging, profile display, and social networking functions;
• show nearby users or location-based functionality when enabled by the user;
• provide subscriptions, paid features, billing support, and purchase restoration where applicable;
• moderate content, process reports and blocks, prevent abuse, detect fraud, and enforce community rules;
• provide customer support and respond to legal, trust and safety, or technical requests;
• improve app performance, security, reliability, and user experience;
• develop, test, and improve recommendation systems, compatibility logic, AI-assisted tools, and product features;
• comply with legal obligations, protect rights and safety, and resolve disputes.

4. Use of Artificial Intelligence

We may use artificial intelligence and machine learning technologies to improve the Service, including:

• providing personalized recommendations;
• improving matching algorithms between users;
• analyzing user interactions to enhance user experience;
• supporting moderation, fraud prevention, spam detection, and quality assurance processes.

These technologies may process user data such as profile information, preferences, interactions, reports, and in-app behavior.

For AI-powered features such as the built-in coach and the relationship assistant "Mira", we may send to OpenAI the data reasonably necessary to generate relevant responses or suggestions, including your name, city, interests, profile description or biography, answers to questionnaires, surveys, onboarding prompts, and the questions or other inputs you submit to the assistant through the Service.

The Service may also provide AI-generated suggestions or responses to users. Such content is provided for informational purposes only and should not be considered legal, medical, psychological, financial, or other professional advice.

Where we use third-party AI or analytics providers, we do so only where reasonably necessary for the functionality described in this Policy, under appropriate contractual, confidentiality, and data protection safeguards.

Artificial intelligence is used as a supportive tool and does not make legally significant decisions about users without appropriate human review. We do not rely exclusively on automated decision-making where such processing would produce legal or similarly significant effects on users under applicable law.

5. Legal Basis and Consent

Where required by applicable law, we process personal data on one or more of the following legal bases: your consent, performance of a contract with you, our legitimate interests in operating and securing the Service, compliance with legal obligations, and protection of vital interests, rights, or safety of users and third parties.

Where processing is based on consent, you may withdraw consent at any time, although this will not affect processing already carried out before withdrawal. Some Service features may not function properly if certain permissions or consents are withdrawn.

6. Geolocation and Device Permissions

If you allow location access on your device and choose to use location-based functionality, we may collect approximate or precise geolocation data to provide features such as showing nearby users or improving local relevance. You can disable location permissions in your device settings at any time, but some features may stop working properly.

We may also request access to your camera, photo library, microphone, contacts, or notifications only when needed for app functionality and subject to your device permissions.

7. How We Share Data

We do not sell personal data. We may share data only in the following cases:

• with service providers and infrastructure partners that help us host, secure, analyze, moderate, verify, or support the Service;
• with payment platforms and app stores, such as Apple App Store, Google Play, or other authorized payment providers, to process subscriptions and purchases;
• with Telegram, solely to the extent necessary to authenticate users or support Telegram-based login or account linking features;
• with OpenAI and other AI service providers, where reasonably necessary to operate AI-powered features such as the built-in coach and the relationship assistant "Mira"; this may include sharing your name, city, interests, profile description, answers to questionnaires or surveys, and the questions or prompts you submit to the assistant;
• with analytics, moderation, anti-fraud, or AI service providers only where reasonably necessary for the functionality described in this Policy and only under appropriate data protection obligations;
• with affiliated entities, successors, or transaction counterparties in connection with a merger, acquisition, reorganization, financing, or sale of assets, subject to appropriate confidentiality protections;
• with law enforcement, regulators, courts, or other authorities where required by law or where reasonably necessary to protect rights, safety, property, or the integrity of the Service.

8. International Transfers

Your data may be processed in countries other than your country of residence where our service providers or infrastructure are located. Where required, we take reasonable contractual, organizational, and technical measures to ensure an adequate level of protection for transferred data in accordance with applicable law.

9. Data Retention

We retain personal data only for as long as necessary to provide the Service, fulfill the purposes described in this Privacy Policy, resolve disputes, enforce agreements, maintain security, and comply with legal obligations.

In most cases, account data is retained for the lifetime of your account. After a valid deletion request, we delete or anonymize personal data within up to 10 business days where operationally feasible, except where retention for a longer period is necessary for legal compliance, fraud prevention, moderation, security, dispute resolution, defense of claims, or technical backup processes.

Some technical logs, backups, moderation evidence, and safety-related records may remain for a limited period after account deletion where required for security, fraud prevention, legal compliance, defense of claims, or technical recovery processes.

10. Account Deletion and Data Deletion

You may request deletion of your account and associated personal data by using available in-app functionality or by contacting us at support@social-spot.kz.

After receiving a valid deletion request, we will delete or anonymize your personal data within the period described above, except where retention is necessary for legal, security, fraud-prevention, dispute-resolution, moderation, or technical backup purposes.

11. Children

The Service is intended only for adults aged 18 and older. We do not knowingly collect or process personal data from minors. If we learn that a minor has provided personal data, we will take steps to suspend or delete the account and remove the data as required by applicable law.

12. Security

We use reasonable technical and organizational measures to protect personal data against unauthorized access, loss, misuse, alteration, or disclosure. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

13. Your Rights

Depending on applicable law, you may have the right to access, correct, update, delete, restrict, or object to certain processing of your personal data, to withdraw consent where consent is the legal basis for processing, and to request portability of certain data where such a right exists.

You may also have the right, under applicable law, to request human review of certain important decisions if you believe they were made solely by automated means. To exercise your rights, contact us at support@social-spot.kz.

14. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in the Service, legal requirements, or our data practices. The latest version will be published on our website, and where required we will provide additional notice through the Service or by other appropriate means.

15. Contact

If you have questions about this Privacy Policy or your personal data, contact us at support@social-spot.kz.

User Agreement

The copyright holder of the "Social Spot" website/application (hereinafter referred to as the "Copyright Holder") grants an unlimited number of persons the right to use the services of the "Social Spot" website/application under a simple non-exclusive license and in accordance with the provisions of this User Agreement, which is a public offer.

"Service" – an information resource located on the Internet at the domain name https://social-spot.kz, including subdomains, and all related software that ensures its functioning.

"Copyright Holder" – Tsifrovye Servisy, TOO, legally registered in the Republic of Kazakhstan, which owns the intellectual property rights of the "Social Spot" Service.

"User" – any person who uses the services and functionality of the Website or Application. The User has the right to go through the registration procedure for access to additional functionality.

"User Agreement" – this agreement, which is a public offer, concluded upon registration in the Service between the User and the Administrator.

"Registration" – the process of providing the User’s identifying information via the application, website, or Telegram account, and the subsequent processing of this information by the Service, as a result of which an Account is created.

"Services" – the "Social Spot" service, which is the intellectual property of the Copyright Holder, providing a dating and social networking platform.

1. General Terms of Use

1. 1.1. By creating a "Social Spot" account, you agree to comply with:
   • this User Agreement;
   • this combined Privacy Policy;
   • Safety Recommendations and Community Rules;
   • all published and accepted terms and conditions if you purchase additional features, products, or services as part of the Service.
2. 1.2. If you do not agree with the terms of this Agreement or the Privacy Policy, you should discontinue using the Service.
3. 1.3. The Copyright Holder may amend this Agreement and the Service itself for reasons including legislation changes, new features, security requirements, moderation requirements, operational needs, or business practices. The latest version of this Agreement is available at https://social-spot.kz.
4. 1.4. The Service is intended for personal, non-commercial use unless the Copyright Holder expressly authorizes otherwise in writing.

2. Legality and Eligibility

2.1. Individuals cannot create an account or use the Service unless:

• they are at least 18 years old. The Service is intended only for users over the age of 18;
• they are legally capable;
• they comply with all applicable national and international laws;
• they confirm they have not been convicted of sexual or violent crimes and are not required to register as a sex offender where such status is relevant under applicable law;
• their account has not previously been permanently banned or removed by the Service for serious violations.

3. User Account

1. 3.1. An authorized User can log in via the application, website, or Telegram account, and by any other authentication methods made available by the Service from time to time.
2. 3.2. The User is responsible for maintaining the confidentiality of credentials and for all actions performed under their account.
3. 3.3. If the User suspects unauthorized use of their account, they should immediately contact technical support.
4. 3.4. The User is responsible for ensuring that the information provided in their profile is accurate, lawful, current, and does not infringe the rights of third parties.
5. 3.5. Unless expressly permitted by the Service, each User may create and maintain only one active account.
6. 3.6. The Copyright Holder may request additional confirmation, verification materials, or other information where reasonably necessary for safety, moderation, fraud prevention, or account recovery purposes.

4. Intellectual Property

4.1. All rights related to the Service belong to the Copyright Holder and are protected under the laws of the Republic of Kazakhstan on intellectual property.

4.2. Except for the limited right to use the Service in accordance with this Agreement, no rights, title, or interest in the Service or its content are transferred to the User.

5. Service Changes

5.1. The Copyright Holder may add, change, remove, suspend, or discontinue features of the Service, including paid features, moderation tools, and technical integrations, with prior notice to Users where reasonably possible.

6. User Safety

1. 6.1. The Copyright Holder promotes respectful relationships between Users but is not responsible for their actions inside or outside the Service.
2. 6.2. Users must exercise caution when meeting other Users offline and must independently assess any risks arising from such interactions.
3. 6.3. The Copyright Holder does not guarantee the good faith, intentions, identity, background, or compatibility of Users.
4. 6.4. The Service may provide reporting, blocking, moderation, and safety tools, but the availability of such tools does not constitute a guarantee that all harmful conduct will be detected or prevented.

7. User Rights and Restrictions

1. 7.1. The User receives a non-transferable, non-exclusive, revocable license to access and use the Service.
2. 7.2. It is prohibited to:
   • use the Service for unauthorized commercial purposes;
   • copy, modify, license, distribute, reverse engineer, or otherwise exploit copyrighted materials or software without permission;
   • use bots, scrapers, crawlers, or other automated tools to access, collect, extract, or index data from the Service;
   • upload malicious code or attempt to disrupt, overload, or interfere with the Service;
   • impersonate other people or create fake or misleading profiles;
   • post illegal, offensive, pornographic, hateful, deceptive, or otherwise prohibited content;
   • harass, threaten, stalk, extort, exploit, or abuse other users;
   • request money, financial credentials, intimate content, or other sensitive information for fraudulent or manipulative purposes;
   • attempt to obtain data or access that the User is not authorized to access.

8. User Content

1. 8.1. By posting content, the User grants the Copyright Holder a non-exclusive, royalty-free, sublicensable license to host, store, reproduce, adapt, display, process, moderate, and otherwise use such content within the Service to operate, improve, secure, moderate, and promote the Service.
2. 8.2. The User confirms that all provided information is accurate and lawful and that they have all rights, permissions, and consents necessary for the content they upload.
3. 8.3. The Copyright Holder may moderate, restrict, age-gate, blur, hide, or remove any content that violates this Agreement, the Privacy Policy, community rules, App Store or platform requirements, or applicable law.

9. Purchases and Subscriptions

1. 9.1. The Service may offer paid features, digital goods, or subscriptions (“in-app purchases”), available through official payment providers such as the App Store, Google Play, or other authorized platforms.
2. 9.2. Auto-renewing subscriptions may be provided. Payment will be charged periodically using the selected payment method until canceled by the User in accordance with the rules of the relevant payment platform.
3. 9.3. Renewal charges may occur automatically unless the subscription is canceled before the end of the current billing period.
4. 9.4. Refunds are processed in accordance with the rules of the App Store, Google Play, the relevant payment provider, and applicable law.
5. 9.5. Deleting the application or deleting an account does not automatically cancel an active subscription purchased through a third-party store. The User must manage cancellation through the applicable store account settings.

10. Termination

1. 10.1. The User may stop using the Service at any time.
2. 10.2. The Copyright Holder may suspend, restrict, investigate, or terminate access to the Service in case of violations of this Agreement, legal requirements, moderation needs, safety risks, fraud, abuse, impersonation, spam, suspected illegal activity, or misuse of the Service.
3. 10.3. The Copyright Holder may preserve relevant records after suspension or termination where reasonably necessary for legal compliance, fraud prevention, defense of claims, or user safety.

11. Limitation of Liability

11.1. To the maximum extent permitted by applicable law, the Service is provided on an “as is” and “as available” basis. The Copyright Holder does not guarantee uninterrupted, secure, or error-free operation of the Service.

11.2. The Copyright Holder is not responsible for the conduct of Users, user-generated content, third-party services, offline meetings, or outcomes of interactions between Users.

12. Use of Artificial Intelligence

We may use artificial intelligence and machine learning technologies to improve the Service, including:

• providing personalized recommendations;
• improving matching algorithms between users;
• analyzing user interactions to enhance user experience;
• supporting moderation, fraud prevention, spam detection, and quality assurance processes.

These technologies may process user data such as profile information, preferences, interactions, reports, and in-app behavior.

For AI-powered features such as the built-in coach and the relationship assistant "Mira", the Service may transmit to OpenAI the data reasonably necessary to generate relevant responses or suggestions, including the User's name, city, interests, profile description or biography, answers to questionnaires or surveys, and the questions or other prompts submitted to the assistant.

The Service may also provide AI-generated suggestions or responses to users. Such content is provided for informational purposes only and should not be considered legal, medical, psychological, financial, or other professional advice.

Where we use third-party AI or analytics providers, we do so only where reasonably necessary for the functionality described in the Privacy Policy and under appropriate contractual, confidentiality, and data protection safeguards.

Artificial intelligence is used as a supportive tool and does not make legally significant decisions about users without appropriate human review.

13. Governing Law

This Agreement is governed by the laws of the Republic of Kazakhstan, without regard to conflict of law principles.

14. Contacts

Tsifrovye Servisy, TOO
ul. Kairbaeva 34, Pavlodar, Pavlodar region, Kazakhstan
E-mail: support@social-spot.kz
Website: https://social-spot.kz