Privacy Policy

This Privacy Policy explains how HotReply ("we", "our", "us") collects, uses, stores, and protects your personal data when you use the HotReply mobile application (the "App"). HotReply is an AI-powered dating copilot that helps you draft messages on dating apps. This policy is written in compliance with the EU General Data Protection Regulation (GDPR) and the EU AI Act (Regulation 2024/1689).

Account Information

• Email address (for account creation and authentication)
• Hashed password (we never store passwords in plaintext)

Profile Information

• User Identity: first name, age, occupation, bio, interests, personality traits, gender (optional — female / male / unspecified)
• Voice Profile: your writing-style preferences (tone, message length, emoji usage, writing samples)

Usage Information

• Conversation text: messages you paste or type to generate replies
• Generated replies: AI-generated reply variants (safe / bold / funny)
• Match profile data (Premium): profile information extracted by AI from screenshots you upload (name, age, bio, photo descriptions, interests, location, vibe, gender)
• Screenshots (Premium, transient): images you upload for profile extraction — see Section 7 for retention
• Subscription data: subscription status, billing period, RevenueCat ID (no payment-card data — that is processed exclusively by Google Play)
• Technical data: IP address, device identifier, timestamps, app version (for security and error analysis)

• To provide and operate the App and its AI-powered messaging features
• To generate personalized reply suggestions based on your Voice Profile and conversation context
• To extract structured profile data from screenshots you voluntarily upload (Premium feature)
• To authenticate your account and manage your subscription
• To enforce free-tier usage limits (3 generations / day) and prevent abuse
• To respond to your support requests and inquiries
• To comply with legal obligations and respond to lawful requests

We implement appropriate technical and organizational measures under Art. 32 GDPR to protect your personal data against unauthorized access, alteration, disclosure, or destruction:

• Transport encryption (HTTPS / TLS) for all communication between the App and our servers
• Encryption at rest in the database
• EU hosting (Supabase, Frankfurt, Germany)
• Database-level access control (Row-Level Security, IDOR protection, atomic counters)
• Prompt-injection protection on AI interactions (sandbox delimiters for untrusted inputs)
• Regular security audits and dependency updates

We share data with carefully selected processors that operate under Data Processing Agreements (Art. 28 GDPR):

Supabase (Auth, Database, Storage)

• Provider: Supabase Inc. (USA, with EU hosting infrastructure)
• Purpose: authentication, PostgreSQL database, temporary screenshot storage
• Data location: Frankfurt, Germany (EU region)
• Privacy policy: supabase.com/privacy

OpenAI (AI Processing)

• Provider: OpenAI, L.L.C. (USA)
• Purpose: processing conversation text (GPT-4o) for reply generation; processing screenshots (GPT-4o Vision) for profile extraction
• Important: OpenAI contractually confirms that API inputs are not used to train models (OpenAI Business Data Processing Addendum)
• Data location: USA
• Privacy policy: openai.com/policies/privacy-policy

RevenueCat (Subscription Management)

• Provider: RevenueCat, Inc. (USA)
• Purpose: subscription status management, purchase validation, billing cycles
• Data location: USA
• Privacy policy: revenuecat.com/privacy

Google Play (App Distribution and Payments)

• Provider: Google Ireland Limited (EU) / Google LLC (USA)
• Purpose: App distribution, in-app-purchase processing, payment handling
• Privacy policy: policies.google.com/privacy

We do not share data with third parties for marketing or advertising purposes.

We do not sell, trade, or rent your personal information to third parties. We share data only in the following circumstances:

• With your explicit consent
• To comply with legal obligations or court orders
• To protect our rights, property, or safety, or that of our users
• In connection with a business transfer or merger (with prior notice)
• With service providers listed in Section 4, under strict confidentiality and Art. 28 GDPR processing agreements

Under the GDPR you have the following rights regarding your personal data:

• Access (Art. 15): request a copy of the personal data we hold about you
• Rectification (Art. 16): request correction of inaccurate or incomplete data
• Erasure (Art. 17 — "right to be forgotten"): request deletion of your personal data, subject to legal retention obligations
• Restriction (Art. 18): request restriction of processing under specific conditions
• Portability (Art. 20): receive your data in a structured, machine-readable format, or have it transferred to another controller
• Objection (Art. 21): object to processing based on legitimate interests at any time
• Withdrawal of consent: withdraw consent at any time, without affecting the lawfulness of processing prior to withdrawal
• Complaint: lodge a complaint with your national supervisory authority (Art. 77)

To exercise these rights, write to privacy@hotreply.app.

We retain personal data only as long as necessary for the purposes described:

• Account, User Identity, Voice Profile: until you delete your account
• Conversations and generated replies: until you delete them, or until you delete your account
• Match profile data (extracted text): as part of the relevant conversation — until that conversation is deleted
• Screenshots (image files): processed in memory only and removed immediately after AI analysis completes. We do not persist uploaded images.
• Subscription data: for the duration of the active subscription, then for the period required by accounting / tax obligations
• Technical log data (security, rate limiting): maximum 30 days

HotReply uses artificial intelligence to generate message suggestions and to analyse profile screenshots:

• Models: GPT-4o and GPT-4o-mini (OpenAI)
• Purpose: generating reply suggestions based on conversation context; extracting information about your match from pasted bio or screenshots
• No training on your data: the OpenAI API does not use your data to train models (OpenAI Business Data Processing Addendum)
• User control: every generated suggestion is just that — a suggestion. You decide what to send. You can edit or reject any suggestion.
• Labelling: AI-generated content is marked with an "AI" label and a verification note in line with Art. 50(4) of EU Regulation 2024/1689

HotReply does not subject you to any automated decision-making that produces legal effects or similarly significant impact. The AI only generates text suggestions — every decision (sending a message, interacting with a match) is made by you.

The 3-generations-per-day limit on free accounts is a hard service rule, not profiling.

Some of the processors listed in Section 4 (OpenAI, RevenueCat, parent companies of Supabase and Google) process data in the United States. Such transfers are made on the basis of:

• Standard Contractual Clauses (SCCs) under Art. 46(2)(c) GDPR (Commission Implementing Decision (EU) 2021/914), and / or
• EU–US Data Privacy Framework (DPF) where the relevant provider is certified under the European Commission's adequacy decision of 10 July 2023

On request, we provide a copy of the safeguards agreed with each processor: privacy@hotreply.app.

HotReply is intended exclusively for users 18 years of age or older. We do not knowingly collect personal data from minors. The App enforces an age confirmation gate at first launch.

If you become aware that a person under 18 has provided us with personal data, contact us at privacy@hotreply.app and we will promptly delete that data.

HotReply is a mobile application and does not use website cookies. The App stores authentication tokens securely on the device using the operating-system keychain (Expo SecureStore). This storage is essential for keeping you signed in and is not used for tracking or advertising.

How to request deletion. Send an email from the address registered with HotReply to support@hotreply.app with the subject "Account deletion". We confirm receipt within 48 hours and complete deletion within 30 days (Art. 12(3) GDPR). If your identity is unclear we may ask for additional confirmation, solely to protect your data against unauthorised deletion (Art. 12(6) GDPR).

What we erase: account credentials (email, hashed password, UUID), User Identity, Voice Profile, all conversations (messages, threads, AI variants, match-profile data), subscription status (locally and on RevenueCat), and anonymised rate-limit / screenshot-extraction logs.

What we retain and why: anonymised consent records (GDPR compliance evidence); deletion-request history (record of fulfilling the right to be forgotten); AI generation and moderation logs containing only a 16-character cryptographic hash of content (AI Act Art. 50 and Google Play AI-Generated Content Policy evidence, retained 24 months from your last activity); subscription billing records (accounting and tax obligations, typically 5 years). Encrypted database backups may still contain your data for up to 30 days after deletion and are automatically overwritten thereafter.

You can withdraw a deletion request only before processing begins (usually within 24 hours of submission). Once deletion has started the operation is irreversible.

We may update this Privacy Policy from time to time to reflect legal, technical, or operational changes. Material changes will be communicated through the App or by email at least 30 days before they take effect. The current version is always available at this URL and in the App under Settings → Privacy Policy.

For privacy-related inquiries or to exercise your GDPR rights, contact us at:

HotReply
Email: privacy@hotreply.app
General support: support@hotreply.app