Template notice. This policy is drafted to be honest and structurally complete, but it is not legal advice. Have a qualified privacy lawyer in each market review it before launch.
The short version. We collect the profile you write, who you like, and what you send. We never ask for a photo. We do not sell your data and we do not run ads. Your face - if you verify - is never stored or published; only a non-reversible signature is. You can export or delete everything from Settings, at any time.
Tim Veles, Cottbusser Straße 13, 16227 Eberswalde, Germany, is the data controller - a private individual, not a company. Contact: mail@tveles.com.
No Data Protection Officer has been appointed. Art. 37 GDPR requires one only for large-scale processing or public bodies; a closed test with a handful of invited people is neither. Data-protection questions go to the address above and are answered by Tim personally. An officer will be appointed before the service grows into the threshold.
If Without is ever taken over by a company, the controller changes. You will be told before that happens, not after.
| Category | What it is | Why |
|---|---|---|
| Account | Email address; optional phone number or Telegram handle if you choose those notifications | To create your account, sign you in and reach you |
| Profile | First name, age, city, your card line, your story, prompts, interests, and optional details you choose (gender, orientation, height, lifestyle, etc.) | To show you to other people and to match you |
| Voice | Your optional voice intro and voice notes (max 30 seconds) | To let people hear you if you want them to |
| Activity | Likes, passes, matches, messages, reports and blocks | To run the service and keep it safe |
| Verification | A non-reversible mathematical signature derived from a liveness check | To confirm you are a real person and detect duplicates and fraud |
| Location | The city you type in, and its approximate coordinates | To show people near you. We do not track your live GPS location. |
| Technical | Device type, browser, IP address, crash and security logs | To keep the service working and to detect abuse |
Some profile fields are special-category data. They are always optional, always marked, and we ask for them only because a dating service is useless without them. You can leave every one blank.
A member can share your profile with a friend to ask their advice before writing to you. We'd rather explain this plainly than bury it.
People already do this. They screenshot a profile and send it to a friend captioned "thoughts??". That happens on every dating app, with no consent, no limit, no expiry and no way for you to opt out. We can't stop screenshots. We can offer a governed version alongside them - one you control.
A reduced profile: your first name, age, city, your goal, your story, your prompts, interests, languages, what you're looking for, relationship and family answers, work, education, height, and whether you're verified.
A guest never receives:
This isn't hidden at the last moment by the app - those fields are not sent by the database at all, so no bug in the interface can reveal them. A friend doesn't need to know your cannabis use to say "yes, message her".
A guest signs in with an email and sees only the profiles explicitly shared with them. A guest cannot browse, search, swipe, message members, or be discovered. They can reply to the person who asked them, with a verdict and a comment. If a guest later wants to date, they make a normal account - the guest account is not a preview of the app.
Legal basis: consent under GDPR Art. 6(1)(a), which is why the switch exists and why turning it off retroactively closes live links. Special-category data is excluded from the share entirely, so no Art. 9 consent is sought or relied on for it.
Two things on this site collect data from people who are not members, and they are the only two. You can ask for an invite code at request-invite.html if you want in now, or join the waiting list on the home page if you only want to hear when it opens. Both write to the same list and are described together here.
| What | Why | Legal basis |
|---|---|---|
| Your email address | To answer you: a code if a place opens up, or a plain no. On the waiting list, to tell you when it opens. | Art. 6(1)(b) - steps taken at your request before any contract |
| Your optional note | Only what you choose to write. Please do not put anything sensitive in it. | Art. 6(1)(b), same purpose |
| IP address and browser | Abuse prevention on a form that is open to the whole internet | Art. 6(1)(f) - our legitimate interest in not having the list filled by bots |
| Follow-up questions by email | Only if you tick that box. Lets us ask a question or two to judge whether you fit the current test group. | Art. 6(1)(a) - your consent, separate and optional |
| One message when we open | Only if you tick that box. A single email saying it is live, and then nothing further. | Art. 6(1)(a) - your consent, separate and optional |
| Our newsletter | Only if you tick that box. Occasional email about how the project is going. You can leave at any time from a link in every message. | Art. 6(1)(a) - your consent, separate and optional |
Every box is separate, and none of them is a condition. You can join the list and tick nothing: we then answer your request, or send you the one launch message if that is what you asked for, and that is all. Ticking one box never implies another. Nothing is pre-ticked.
We confirm your address before sending you anything (double opt-in). If you ask for the launch message or the newsletter, we send one email asking you to confirm it was really you. Until you click that link, we send you nothing else and the consent does not count. This protects you from being signed up by somebody typing your address into our form.
What we store as the record of your consent: the time you ticked, the time you confirmed, the IP address both times, and the exact sentence you agreed to in the language you actually read it in. We keep our own copy of that wording on the server, so the record cannot be quietly rewritten later - not by us and not by anyone filling in the form.
Leaving. Every newsletter carries a one-click unsubscribe link that works without logging in or replying to anything. You can also withdraw any consent by writing to privacy@without.photos. It takes effect immediately and does not make anything we did beforehand unlawful.
What we still do not do with it. No profiling, no advertising, no passing it to anyone else, no selling it, and no automated decision about whether you get in - a person reads every request. We do not use the waiting list to work out anything about you beyond that you are interested. Joining is not signing up: it creates no account and grants no access.
How long. An invite request is kept until it is settled and then deleted: within 30 days of sending you a code, and within 30 days of a decline. Requests we never get to are deleted after 12 months at the latest. A waiting-list entry is deleted once we have sent the launch message, unless you also asked for the newsletter - then we keep the address until you unsubscribe. An address that never confirms is deleted after 30 days. If we cannot offer you a place we tell you and delete your address; we do not keep it quietly against a future round.
Where a processor operates outside the EEA/UK, transfers are covered by Standard Contractual Clauses or an adequacy decision. We store data in the EU where we reasonably can.
You can access, correct, export, restrict, object to processing, and delete your data. Two of these are one tap:
For anything else, write to privacy@without.photos; we respond within 30 days. You may also complain to your local data protection authority. California residents have equivalent rights under the CCPA/CPRA, including the right to know and to delete; we do not sell or share personal information as those terms are defined.
We keep this deliberately small.
| Type | Purpose | Consent? |
|---|---|---|
| Strictly necessary | Sign-in session, security, your settings and draft profile stored on your own device | Not required |
| Functional | Remembering language, theme, units | Not required |
| Analytics | Aggregate, privacy-friendly usage counts | Asked, and you can decline |
| Advertising | None. We do not use advertising or tracking cookies. | - |
A dating profile is unavoidably personal. Some of what you may choose to tell us is special category data under GDPR Art. 9, and some of it counts as regulated consumer health data under US state laws such as the Washington My Health My Data Act, the Nevada consumer health law, and comparable rules elsewhere.
In our case that can include:
How we treat it:
Where state law grants you a specific right to have consumer health data deleted, you can exercise it yourself in Settings → Download my data / Delete account, or by writing to privacy@without.photos. We confirm deletion in writing.
For California residents (CCPA/CPRA) and equivalents, a plain summary of what we take and why:
We do not sell or share personal information as those terms are defined by the CCPA/CPRA, and we never have. We do not use sensitive personal information for any purpose beyond providing the service you asked for, so no limitation right is triggered - but you may still exercise every right below.
You do not need to email anyone or fill in a form to exercise these. They are buttons in the app.
Authorised agents may act for you with written proof. We may need to confirm your identity via your registered email before acting on a request.
Without is strictly 18+. We do not knowingly collect data from anyone under 18. If we learn an account belongs to a minor we delete it immediately. Report a suspected minor to privacy@without.photos.
Our match score ranks and explains suggestions. It is not a decision with legal effect, and it never restricts your access to the service. You can see exactly why a score is what it is on every profile, and change it by editing your interests.
If we change this policy materially we will tell you in the app before it takes effect. The date at the top always shows the current version.
Tim Veles, Cottbusser Straße 13, 16227 Eberswalde, Germany
Privacy, data protection and safety: mail@tveles.com