The controller within the meaning of the General Data Protection Regulation (GDPR) for the processing of personal data in the context of the dating and social media app Link2Wink (L2W) and the associated information website is:
Kay Brilla
Ahornallee 37a
16547 Birkenwerder
Germany
Email: support@link2wink.app
As a sole proprietor, Kay Brilla is solely responsible for the purposes and means of processing personal data.
A data protection officer has not been appointed, as there is no legal obligation to do so pursuant to Art. 37 GDPR.
Link2Wink (L2W) is a contact- and encounter-oriented dating and social media app for adult users. The aim of the platform is to connect individuals in spatial proximity and to enable real-life encounters.
The app is designed for time-limited interactions. Communication content and connections are not permanently archived but are subject to defined deletion and limitation mechanisms (see sections below).
The detection of spatial proximity takes place exclusively via Bluetooth Low Energy (BLE). GPS location, permanent location tracking, or the creation of movement profiles do not take place.
The processing of personal data takes place exclusively in accordance with the General Data Protection Regulation (GDPR) as well as the relevant national data protection laws and in compliance with the principle of data minimization.
Data processing takes place:
The processing serves in particular the following purposes:
The function serves exclusively to generate formulation suggestions based on the content actively entered by the user.
Automatic analysis of chat histories or profile contents of other users does not take place.
Automated decision-making within the meaning of Art. 22 GDPR does not take place.
This privacy policy provides information about:
In the context of using Link2Wink (L2W), the following categories of personal data are processed – depending on the use of the functions:
This data is required for the setup and management of the user account.
Providing additional profile information is voluntary. No information regarding sexual orientation is requested.
Storage takes place in a technically limited, rolling system. For each chat, a maximum of the last 50 messages are stored. Older messages are automatically deleted. Additionally, chats can be automatically deleted in case of inactivity.
The detection of spatial proximity takes place exclusively via Bluetooth Low Energy (BLE). GPS location, permanent location tracking, or the creation of movement profiles do not take place.
These data are used exclusively for the provision of technical functions (e.g., push notifications).
No profile or match data of other users are transmitted in this process.
There is no processing of personal data for advertising, tracking, or profiling purposes.
In particular, no external analysis or tracking services (e.g., Firebase Analytics) are used.
No automated decision-making within the meaning of Art. 22 GDPR takes place.
To use the app, the creation of a personal user account is required.
The following mandatory information is processed during registration:
Registration is only permitted for persons who have reached the age of 18. During registration, users bindingly confirm that they are of legal age.
The date of birth serves:
Subsequent changes to the date of birth are excluded in order to prevent abuse.
With the completion of the registration, a user agreement is concluded. Within the framework of this agreement, users also confirm that they have taken note of the privacy policy.
Legal Basis:
Art. 6(1)(b) GDPR (Performance of the user contract)
Link2Wink is exclusively intended for persons who have reached the age of 18.
The date of birth is processed during registration to ensure compliance with the age limit and to fulfill legal requirements for the protection of minors. Users bindingly confirm their adulthood during registration.
Use of the app by minors is prohibited.
Should there be indications that a user has not yet reached the age of 18, the controller reserves the right to block or delete the user account immediately.
Legal Basis:
Art. 6(1)(b) GDPR (Performance of the user contract)
Art. 6(1)(c) GDPR (Compliance with legal obligations)
Users can voluntarily provide additional information in their profile when using Link2Wink. This includes in particular:
In addition, users can provide further voluntary information for personal description (e.g., physical characteristics, interests, professional background, education, or other self-selected profile information).
This information serves:
With the exception of the date of birth, all profile information can be viewed, changed, or deleted within the app at any time.
Providing this data is voluntary. However, without certain information (e.g., gender or search preferences), the matching function can only be used to a limited extent or not at all.
Users are urged not to publish any special categories of personal data within the meaning of Art. 9 GDPR (e.g., health data, religious beliefs, or political opinions) in their profile.
Legal Basis:
Art. 6(1)(b) GDPR (Performance of the user contract)
Insofar as voluntary information is provided beyond what is strictly necessary for purely contractual fulfillment, processing is based on Art. 6(1)(a) GDPR (Consent).
User profiles are visible to other users exclusively under the following conditions:
There is no permanent public profile display or a freely searchable user directory.
The display of profiles takes place exclusively within the framework of the defined matching logic. GPS location, the creation of movement profiles, or permanent location tracking do not take place.
Matches are automatically deleted if no active use occurs within five days. Upon deletion of a match, the mutual visibility of the profiles is removed, provided there is no active chat.
Chats are additionally subject to a technically limited storage mechanism (rolling message window and automatic deletion in case of inactivity; see section "Communication Data").
Legal Basis:
Art. 6(1)(b) GDPR (Performance of the user contract)
Link2Wink uses Bluetooth Low Energy (BLE) to technically detect spatial proximity between users during an actively started proximity search.
The following applies expressly:
Proximity detection takes place exclusively during a search actively started by the user.
A single search process is technically limited to a maximum of two hours and is then automatically terminated.
During an active search, the operating system may display a visible system notification to inform the user that the nearby search is active.
The specification of country and city is voluntary. This information serves exclusively for rough distance sorting within certain functions (e.g., "NextStage").
Precise location determination does not take place.
During an active proximity search, Link2Wink exclusively processes technical status and session data required for the operation of the function. This includes in particular:
These data serve exclusively to carry out the proximity function as well as the technical stability and security of the platform.
During an active search, background system services of the respective operating system may be used to:
This is done exclusively to:
If an active search is terminated while the app is not actively open (e.g., due to system termination or user action at the operating system level), the search status can technically be updated on the server side.
In this process, only necessary technical status information is processed. There is no processing of profile content, communication content, or movement profiles.
During an active proximity search, a technical identifier (UID) is transmitted via Bluetooth Low Energy. This identifier contains no directly identifying information such as name, profile content, or location data.
The UID serves exclusively for the temporary detection of technical proximity events. Assignment to specific user profiles takes place exclusively on the server side within protected systems.
Permanent external traceability or identifiability of users via Bluetooth communication is not intended.
Legal Basis:
Art. 6(1)(b) GDPR (Performance of the user contract)
The app may provide a so-called hotspot function.
With this function, users can publish locations and time periods where several users are expected to be present and could use the app.
The hotspot function serves exclusively to inform users about potential locations of other users and to facilitate the use of the app in these situations.
The creation of a hotspot is only possible for verified users of the platform.
A hotspot can be created a maximum of seven days in advance.
When creating or joining a hotspot, the following data may be processed:
The internal user identifier is used exclusively for the technical provision of the function as well as for moderation and enforcement of the terms of use.
Hotspots are only visible within the app and only accessible to registered users.
The display is anonymized.
No names or other identifying features of the participating users are displayed.
Other users only see:
Individual participants of a hotspot are not displayed.
Users can join a hotspot or remove their participation.
There are no further interaction possibilities within the hotspot function (e.g., comments or messages).
Hotspots are automatically deleted after the specified time has elapsed.
The associated data is only stored for as long as is necessary for the provision of the function.
Hotspots can be reported via a reporting function if they violate applicable law, the terms of use, or the community guidelines.
In the event of a report, the operator can review the reported hotspot and remove it if necessary.
For this purpose, the internal user identifier (User ID) of the creator can be processed to investigate violations and implement measures (e.g., warning or blocking of a user account) if necessary.
Hotspots are created exclusively by users.
The operator does not organize events, does not act as an organizer, and has no influence on the behavior of users outside the app.
The app merely provides a technical platform through which users can publish potential locations.
When users meet outside the app or interact with each other, this happens exclusively at the own responsibility of the participating users.
The operator assumes no liability for the behavior of users or for events that arise in connection with such encounters.
Users are advised to act prudently when meeting other users and to prefer public places in particular.
The operator verifies neither the identity nor the behavior of users outside the technical functions of the platform and assumes no guarantee for the correctness of user specifications or the actual presence of users at published locations.
Legal Basis:
The processing of the aforementioned data is based on
Art. 6(1)(b) GDPR (Performance of the user contract)
as well as
Art. 6(1)(f) GDPR (Legitimate interest in the provision and secure moderation of the platform).
The app enables private 1:1 communication between users who have a match.
Exclusively text messages and emojis can be sent.
For data minimization, the following technical restrictions apply:
These limitations serve data minimization and the implementation of the deletion concept.
The transmission of messages between the end device and the server is encrypted (TLS/HTTPS).
Message contents are processed and stored on the server side in order to:
End-to-end encryption is currently not used.
Chats are automatically deleted if they are inactive over a longer period of time:
Additionally, chats are deleted:
In the case of reports due to possible violations of the terms of use, affected chat content can be stored for the purpose of review and securing evidence.
Storage generally only takes place for as long as is necessary for the review of the facts, usually up to 30 days.
In justified cases, in particular for the enforcement of terms of use, for abuse and fraud prevention, or for the assertion, exercise, or defense of legal claims, longer storage may occur. In such cases, the storage period can be up to three years (see also Section 14.6).
Legal Bases:
The legitimate interest consists in particular in protecting users from harassment, unlawful content, or abusive use of the platform.
To promote active use of the app, user-related progress and activity values (e.g., "WinkStreaks" or "Checkpoints") may be maintained.
For this purpose, the following data in particular are processed:
These values serve exclusively playful purposes and optional in-app benefits. They have no legal effect and do not lead to automated decisions within the meaning of Art. 22 GDPR.
No automated profiling takes place for the evaluation of personal characteristics or for the creation of personality profiles.
Legal Basis:
Art. 6(1)(b) GDPR (Performance of the user contract)
Participation in photo verification is voluntary.
Within the framework of verification, a photo can be processed to confirm the authenticity of a user profile. Processing takes place exclusively for the purpose of identity confirmation within the platform.
The following takes place:
Verification data is only stored for as long as is necessary for the verification purpose.
Legal Basis:
Art. 6(1)(a) GDPR (Consent)
Services subject to a fee within the app (e.g., subscriptions) are handled exclusively via the respective app platforms:
Payment processing takes place directly via the respective platform. Link2Wink receives no credit card or other payment data from users in this process.
Only the following subscription-related status information is processed:
Technical management and synchronization of the subscription status takes place via the service RevenueCat.
Apple and Google act as independent controllers within the meaning of the GDPR with regard to payment processing.
RevenueCat is used as a technical service provider under a data processing agreement pursuant to Art. 28 GDPR.
Legal Basis:
Art. 6(1)(b) GDPR (Performance of the user contract)
For the technical provision and operation of the app, cloud services are used, in particular services from the Google Firebase and Google Cloud Platform.
These services are used on the basis of data processing agreements pursuant to Art. 28 GDPR.
Productive operation of the central application and storage systems takes place within the European Union (EU region, e.g., europe-west).
Certain supporting services (e.g., authentication, push notifications, or security mechanisms) may be processed within the framework of the global distributed infrastructure of the respective provider.
In the context of technical operation, the following technical metadata can be processed:
This processing serves exclusively:
No use of this data for advertising, tracking, profiling, or analysis purposes takes place.
Insofar as personal data are processed outside the European Union or the European Economic Area, this takes place exclusively in compliance with Art. 44 et seq. GDPR.
Transfer takes place on the basis of suitable guarantees, in particular:
Legal Bases:
The legitimate interest consists in particular in the guarantee of IT security, system stability, and protection against abuse.
Personal data are only stored for as long as is necessary for the respective processing purposes. Subsequently, they are deleted or – insofar as legally permissible – anonymized.
Matches are automatically deleted if no active use occurs within 5 days.
Upon deletion of a match, the mutual visibility of the profiles is removed, provided there is no active chat.
For chats, the storage and deletion mechanisms described in Section 10 apply (rolling message window and automatic deletion in case of inactivity).
Search sessions and associated technical status data are only stored for as long as is technically necessary for the operation of the Bluetooth-based proximity search.
After completion or expiration of the search session, these data are automatically deleted or anonymized.
In the case of reports due to possible violations of legal regulations, terms of use, or community guidelines, affected content (e.g., chat messages, profile pictures, or other reported content) as well as associated user data can be processed and stored.
This serves the review of the facts, enforcement of terms of use, as well as abuse and fraud prevention.
In justified cases, these data can be stored over a longer period of time, in particular for the defense or assertion of legal claims.
Storage generally only takes place for as long as is necessary for the stated purposes and can amount to up to three years in individual cases.
Information about blocked users is stored exclusively for the technical enforcement of the block function and is not used for other purposes.
Login times or use of core functions can be processed insofar as this is required for:
insofar as this is necessary.
After deletion of a user account, personal data are generally deleted, provided no legal retention obligations stand in the way.
Technical backup copies (backups) are automatically overwritten within the framework of regular backup cycles.
There is no storage of personal data beyond the respectively determined periods for purposes of profile formation, ranking, or behavioral evaluation.
Data subjects have in particular the following rights pursuant to Art. 15–21 GDPR within the scope of legal requirements:
The right to request information as to whether and which personal data are processed.
The right to request the immediate correction of incorrect or incomplete personal data.
The right to request the erasure of personal data, provided the legal requirements are met.
The right to request the restriction of processing under certain conditions.
The right to receive personal data processed on the basis of consent or for contractual fulfillment in a structured, commonly used, and machine-readable format or to have it transmitted to another controller.
Insofar as processing is based on consent, it can be withdrawn at any time with effect for the future.
Insofar as processing is based on Art. 6(1)(f) GDPR (legitimate interest), there is a right to object to the processing at any time for reasons arising from the particular situation of the data subject.
Data subjects have the right pursuant to Art. 77 GDPR to lodge a complaint with a data protection supervisory authority, in particular in the Member State of their habitual residence, their place of work, or the place of the alleged violation.
To exercise the aforementioned rights, the data subject can contact the controller at any time (for contact details, see Section "Controller").
Link2Wink uses suitable technical and organizational measures within the meaning of Art. 32 GDPR to protect personal data against loss, manipulation, unauthorized access, or other unauthorized processing.
These include in particular:
Security measures are continuously adapted in line with technological developments.
The controller reserves the right to adapt this privacy policy insofar as this becomes necessary due to legal, technical, or organizational changes.
The current version is available at any time within the app as well as on the associated information website.
The app may optionally provide an AI-supported assistance function ("ILIWIO").
Use of the function is voluntary.
In the context of using ILIWIO, the following data may be processed:
No profile or match data of other users are transmitted in this process.
Processing takes place exclusively for the following purposes:
Permanent storage of ILIWIO conversations for profile formation or behavioral analysis does not take place.
Automated decision-making within the meaning of Art. 22 GDPR does not take place.
Processing takes place via cloud AI services (e.g., Google Cloud / Vertex AI). User entries may be transmitted to servers of these providers insofar as this is required for the provision of the function.
Insofar as processing takes place outside the European Union, this takes place exclusively in compliance with Art. 44 et seq. GDPR and on the basis of suitable guarantees (e.g., EU Standard Contractual Clauses).
Optionally, a text-to-speech function can be used.
Services from Google may also be used for this purpose.
No voice biometrics, biometric identification, or permanent storage of voice patterns take place.
Only the following are stored:
Permanent storage of AI conversations for profile formation does not take place.
The function can be temporarily deactivated for technical, economic, or security-related reasons.
Legal Bases:
The legitimate interest consists in particular in the guarantee of system security, abuse prevention, and cost control.
This privacy policy is drawn up in the German language.
Insofar as translations into other languages are provided, the German version serves as the authoritative and legally binding version.
Status: April 2026 (Version 1.0)