Privacy Policy
Last Updated: February 25, 2026
1. Introduction and Scope
This Privacy Policy ("Policy") sets forth the rules regarding the collection, processing, protection, and sharing of personal data of all Members, Users, and Independent Broadcasters (Hosts) who use the MinglePub ("Platform", "We", "Us" or "Our") mobile application and the www.minglepub.com website. By using our Platform, you explicitly accept the data processing practices described in this Policy.
We are committed to full compliance with applicable international and local legislation, including but not limited to the European Union General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), and Turkish Personal Data Protection Law No. 6698 (KVKK).
2. Data We Collect
We collect and process various types of data while providing and improving our Platform:
- Registration and Profile Data: Email address, phone number (for SMS verification), age/date of birth, gender, selected language, profile photos, and interests.
- Connection and Device Data: Your IP address, device identifiers (IMEI, Advertising ID / IDFA), operating system information, browser type, application crash logs, and network connection data (required for WebRTC matching and network quality assessment).
- Communication Content: Email correspondence with our customer support services (help center) and text-based (written) chat logs within the Platform.
- Financial Data: VIP membership or in-app diamond/token purchase transactions are processed directly through third-party payment providers (App Store, Google Play, Whop, etc.). We do not directly store your full credit card numbers; however, we retain token and digital receipt data related to your purchase history for authorization verification and fraud prevention purposes.
- Identity Verification Data: For Independent Broadcasters (Hosts), we collect a live selfie photograph and a self-declared date of birth as part of our identity verification ("KYC") process. This data is reviewed manually by our internal team, stored in access-restricted storage, and is never publicly displayed on the Platform or shared with other Users.
- Host Payout Data: Independent Broadcasters (Hosts) who request a withdrawal provide banking details (IBAN, account holder name) or a cryptocurrency wallet address. This data is stored with restricted access and used solely to process payments owed to the Broadcaster.
3. Live Video Chats and AI Moderation
Real-time video matches, the core service of MinglePub, are transmitted using high-standard security protocols (WebRTC/LiveKit infrastructure). The content of your video and voice calls is never recorded or stored on our servers in mp4 or similar permanent video formats during the standard chat flow.
AI-Based Moderation Exception: To ensure Platform safety and detect violations of our Terms of Use (strict rules: nudity, sexual content, violence, bullying, illegal substance use, endangering children, etc.), automatic "frame-by-frame visual analysis" may be performed by the system during matches. These analyses are processed by artificial intelligence within milliseconds in RAM and are immediately and permanently deleted from hardware (memory) if no rule violation is detected. In cases where a violation is detected, the relevant frame is retained in our encrypted logs for a limited period (throughout the appeal process or until handed over to legal authorities) as legal evidence and justification for account suspension.
4. Cookies and Tracking Technologies
Cookies and SDK (Software Development Kit)-like tracking technologies are used on our website or certain sections of our application to evaluate platform performance, collect analytical data, and keep your login session active. By using the Platform, you consent to the placement of necessary and performance cookies on your device. You can always manage your cookie or advertising tracking permissions through your browser or operating system (iOS/Android) settings.
5. Purposes of Data Usage
We use the data we collect for the following purposes:
- To ensure the basic operation of services; matching users with each other within seconds with low latency (ping) across 190+ countries.
- To test the technical operation and stability of the system and minimize error rates (bugs).
- To detect violations of our Terms of Service, prevent fraud and spam activities. To actively protect the safety of the existing user community (including AI moderation).
- To resolve customer support (helpdesk) issues and promptly fulfill our legal obligations (criminal investigations, Interpol/NCMEC reports, etc.).
6. Data Sharing with Third Parties and International Transfers
Your personal data will under no circumstances be SOLD to third parties for the purpose of commercial gain, marketing, personalized direct advertising, or data brokering.
- Service Providers and International Transfers: MinglePub is a global platform. Our database and server services are hosted in international high-security infrastructure centers (e.g., US or European Union-based AWS, Google Cloud, Supabase clusters). By using the Platform, you acknowledge that your data is transferred to these secure servers outside your country (e.g., Turkey) due to technical necessity (in compliance with GDPR Standard Contractual Clauses or KVKK Explicit Consent requirements).
- Legal Obligations: In cases requested by relevant law enforcement or legal authorities through a valid court order or official notice (especially in cases of child sexual exploitation, terrorist acts, or emergency situations that minimally threaten individuals' safety), IP records and available encrypted data may be shared with official authorities.
7. Data Retention Period
We retain your personal data as long as your account is active or as long as we have a legitimate, legal purpose for providing our services to you (e.g., legal defense, fraud prevention, or financial auditing). When you delete your account yourself, all personally identifiable data in our database (profile photo, email, etc.) is permanently destroyed or irreversibly anonymized within the shortest technical window (typically within 30 days). However, device/IP identifiers of users banned from our servers due to sexual content, bullying, or illegal activity continue to be maintained in "Blacklist" records to prevent these individuals from re-entering the platform.
8. User Rights (KVKK / GDPR / CCPA Rights)
As a data subject, you have the following rights according to the legislation in your region:
- Learning which data is processed about you and requesting access to (export of) such data.
- Requesting correction of incomplete or incorrectly processed data.
- "Right to be Forgotten" / Deletion: The right to request deletion of your profile. (The "Delete Account" button in the app's settings tab automatically initiates the process).
- The right to object to automated decision-making (AI analysis) methods. (However, as this objection would conflict with the Platform's fundamental requirement of AI camera moderation, it may require you to leave the application entirely).
9. Children's Privacy
MinglePub services are exclusively for individuals aged 18 and over. We do not intentionally or knowingly collect information from individuals under 18 (minors). If we detect through our system or through a report that a user under 18 is on the platform, that account and associated data are immediately and permanently removed from the database.
AI-Powered Live Voice Translation
During video calls between members who speak different languages, MinglePub provides real-time AI voice translation. When this feature is active, call audio is streamed to Google's Gemini API for processing, which generates translated speech and text transcripts in real time. Audio processed for translation is handled under Google's API terms and may be used by Google to improve its services. MinglePub does not permanently store call audio or translation transcripts on its servers.
Translation is automatically disabled when both participants share a language. During a call you can switch to translation-only mode or turn translation off entirely at any time using the in-call translation button. By keeping translation enabled during a call, you consent to this processing of your voice audio.
10. Contact
For all legal notifications including your views on our privacy policy, data access, data correction, or complete deletion (right to be forgotten) requests, you can contact our Data Controller team:
Privacy Unit (DPO) Email: support@minglepub.com