TRIEZZO PRIVACY POLICY

1. Introduction

At Triezzo, we value your privacy with the same care we put into fostering human connections. This Policy explains how we collect, use, and protect your personal data when you use our mobile app or the website triezzo.com.

Controller:

Techrealm Ltd (commercial brand: Triezzo)
Efesou, 9, Paralimni, 5280, Famagusta, Cyprus
TIN / VAT: 60061983B
📧 support@triezzo.com
Techrealm Ltd acts as the data controller in accordance with the EU General Data Protection Regulation (GDPR – EU 2016/679) and Cyprus national law.

For residents of the United States, additional information about your privacy rights is available in our U.S. Privacy Notice. For information about copyright and content takedown procedures, see our Copyright & DMCA Policy.

2. Data we collect

We collect only what we need to provide a safe, personalized, and functional service.

a) Registration & account data

• Name and surname (if you provide them)
• Date of birth
• Email address
• Profile photo and any other images you upload
• Gender, gender identity where provided, and connection interests
• Language and country
• Sign-in identifiers (Apple, Google, or email)

b) Usage & behavior data

• Activity in the app (plans viewed, likes, chats, etc.)
• Visibility and configuration preferences
• IP address, device type, OS, and app version
• Precise location data, only while the app is open (when you allow it)

c) Special / sensitive data (optional)

To personalize your experience, you may voluntarily share information related to your interests, sexual orientation, gender identity, religion, or body-related information (such as height, weight, or body type). These data are processed only if you enter them, and you can modify or delete them at any time. Some of this information may constitute special category data under Art. 9 GDPR, such as sexual orientation, religious beliefs, health-related information, or biometric data where applicable. Where special category data are involved, we process them only on the basis of your explicit consent.

d) Payments & subscriptions

• Purchases and subscriptions in the app (via Apple IAP, Google Play Billing, or Stripe)
• Payment methods processed via Stripe (Triezzo does not store card details)
• History of payments, refunds, and invoicing
• For organizers: Stripe may also process identity, business, tax, bank account, and verification information required for KYC/KYB compliance and payouts via Stripe Connect.

e) Events & activities

• Enrolments in plans or events
• Attendance and ticket validation
• Interactions within an event (e.g., messages or "likes" after sharing a plan)
• For events organized by Triezzo, we may request additional data required for management (contact, emergency info, logistical preferences, etc.)

f) AI & smart assistance

Triezzo offers an optional AI assistant (Triezzo AI) available in two contexts:

• Within chats between matches, where the AI may suggest ideas, topics, or compatibility signals at your request.
• Within the support and help chat, where it can answer questions about the platform, its policies, or how to use its features.

Use is voluntary and requires your express consent at first use. When you use Triezzo AI within a match conversation, we may send to the AI provider the conversation context, your internal user ID, your name, and the other participant's internal user ID and name, so the AI can distinguish who is speaking and generate a relevant response based on the conversation.

When you use Triezzo AI within the support or help chat, we may send your message, your internal user ID, your name, and relevant account or support context needed to answer your request.

The messages and conversation context processed by the AI may contain personal data, including personal data you or the other participant include in the conversation. We recommend that you do not include unnecessary sensitive information about yourself or others in your AI interactions.

Messages and related context are processed to generate the requested reply and to display your AI conversation history within Triezzo. They are not used to train models and are not used for purposes beyond conversational assistance, support, safety, abuse prevention, and legal compliance within Triezzo. Processing is carried out via OpenAI under a data processing agreement and Standard Contractual Clauses (SCCs).

g) Identity verification

Triezzo offers an optional profile verification feature. When you choose to verify your identity:

• You will be guided through a visual test using your device camera (poses or gestures). The images captured during this process are transmitted to our backend and to AWS Rekognition for temporary comparison against your existing profile photos.
• Triezzo does not store biometric templates, face vectors, or facial embeddings. Images captured during the verification test are used temporarily to compare your face with your profile photos and are discarded immediately after processing.
• Depending on applicable law, this may involve the temporary processing of facial data for verification purposes. This processing is optional and based on your explicit consent.
• Only the verification result (verified / not verified) and a reference to which profile photos passed the match are retained. If you delete those profile photos or your account, the verification record is removed automatically.

This processing is based on your explicit consent, given before starting the verification process. You may choose not to verify your profile; verification is entirely optional.

h) Content moderation

To keep Triezzo safe and compliant with our Community Guidelines and legal obligations, we automatically analyze content you submit:

• Images (profile photos, plan images) are analyzed by AWS Rekognition to detect illegal, sexually explicit, or otherwise prohibited content.
• Texts (plan names, descriptions, profile bios) are analyzed using a combination of automated keyword filters and OpenAI's moderation API to detect prohibited content.
• Moderation analysis occurs at the moment of upload or submission. A moderation log is retained for platform security and legal compliance purposes for as long as necessary to fulfill those purposes, and is subject to periodic automated deletion.
• Where automated moderation leads to content removal or account restrictions, you may request human review by contacting support@triezzo.com, unless the content is clearly illegal or abusive.

This processing is based on our legitimate interest in maintaining a safe platform (Art. 6.1.f GDPR) and, where applicable, our legal obligations to act against illegal content (Art. 6.1.c GDPR). It applies to all users and does not require separate consent.

i) Device permissions

• Camera: we request access to your camera to upload profile photos, plan images, and to complete the optional identity verification process. Camera access is only used when you actively initiate one of these actions.
• Precise location (when in use): we request access to your precise location while the app is open to show you nearby plans, events, and people, and to calculate distances within your selected radius. Location is never accessed in the background.
• Notifications: we may request permission to send you alerts about messages, plans, bookings, relevant changes, or security notices.

You can withdraw these permissions at any time from your device settings. Some Triezzo features may stop working if you disable permissions required for their operation.

Our website may use strictly necessary cookies and, subject to your consent where required, analytics or preference cookies. More information is available in our Cookie Policy.

3. Purposes of processing

We use your data to:

1. Provide the core service

Create and maintain your account, enable app access, participation in plans, and user-to-user communication.

2. Payments & subscriptions

Manage charges, renewals, refunds, and invoicing (via Stripe Connect, Apple IAP, and Google Play Billing).

3. Security, moderation & compliance

Detect and prevent fraud, impersonation, or inappropriate behavior. Automatically moderate images and texts to prevent illegal, sexually explicit, or prohibited content. Verify user identity on an optional basis.

4. Communication & support

Respond to questions, incidents, or support requests.

5. Personalization

Show plans or people compatible with your interests, location, or activity.

6. Events organized by Triezzo

Handle enrolments, attendance, communications, and refunds when Triezzo is the organizer.

7. AI assistant (Triezzo AI)

Provide optional conversational assistance within matches and support, as described in section 2f. Processing relies on your express consent at first use.

8. Legal obligations

Invoicing, tax verification, DAC7 reporting, audits, or cooperation with authorities.

4. Legal bases

5. Where your data are stored

Triezzo's primary infrastructure is hosted on Amazon Web Services (AWS) in Ireland (EU), so your data are stored within the EEA.

Some specific features use providers with servers outside the EEA. In such cases, Triezzo implements the European Commission's Standard Contractual Clauses (SCCs) and additional safeguards:

• AWS Rekognition — processes images for content moderation and optional identity verification. Images are processed temporarily for these purposes and are not stored after processing. Located in the EEA / US (SCCs in place where applicable).
• OpenAI — processes text content, support chat content, conversation context, internal user IDs, and names where necessary to provide AI assistant responses and content moderation. Messages and related context are processed to generate the requested response and to display your AI conversation history within Triezzo. They are not used for model training. Located in the US (SCCs in place).
• Google (Firebase) — provides crash reporting (Crashlytics), usage analytics (Firebase Analytics), and push notifications (FCM). Configured to minimize personal data collection. Located in the EEA / US (SCCs in place).
• Sentry — processes error logs and crash diagnostics for the app and web platform. Configured to minimize personal data; some technical identifiers may be processed for diagnostics and security. Located in the EEA / US (SCCs in place).

6. Sharing your data

Triezzo does not sell or transfer your personal data for commercial purposes. We share data only when necessary to provide the service.

7. Data retention

We retain your data while your account is active or as needed to provide the service.

You can delete your account from the app by opening your profile through the profile picture in the top-right corner, going to General Settings, and selecting Delete account at the bottom of the screen. You can also visit our Delete Account page.

8. Your rights

You have the right to access, rectify, erase ("right to be forgotten"), restrict or object to processing, data portability, and to withdraw consent at any time.

You can withdraw consent for optional features such as AI assistance, sensitive profile fields, or identity verification at any time through the app settings where available or by contacting us. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

To exercise your rights, email support@triezzo.com with the subject "Data Protection". We will respond within 30 days.

You may also lodge a complaint with the Office of the Commissioner for Personal Data Protection (Cyprus).

9. Information security

We apply appropriate technical and organizational measures:

• HTTPS/TLS encryption in transit
• Encryption at rest on AWS
• Role-based access control
• Internal logging and audits
• Automated content moderation to detect harmful or illegal content

If we detect a security incident affecting your data, we will notify you in accordance with the GDPR.

10. Minors

Triezzo is intended only for users aged 18+. If we detect a minor's account, it will be deleted immediately.

11. Communications & notifications

We may send:

• Service-necessary communications (confirmations, changes, security alerts).
• Promotional communications only if you have given consent.

You can manage preferences in Settings → Notifications.

12. International transfers

When services outside the EEA are used, we ensure compliance with the European Commission's SCCs and, where appropriate, conduct a Transfer Impact Assessment (TIA). A list of key recipients and service providers is available in section 6 above.

13. Changes to this Policy

We may update this Policy to reflect legal or technical changes. If the change is significant, we will notify you in-app or by email before it takes effect.

The current version is always available at triezzo.com/en/legal/privacy-policy.

14. Contact

For any privacy question:
📧 support@triezzo.com
Subject: "Privacy – Information Request"
Supervisory Authority: Office of the Commissioner for Personal Data Protection – Cyprus

15. In short

We believe trust is built through transparency. Your data belong to you; our responsibility is to protect them and use only what's necessary to deliver a safe, human, and meaningful experience.

Thank you for trusting Triezzo 💜

Version 1.6 — June 2026