Privacy Policy

Effective date: 26 June 2026 · Last updated: 26 June 2026

Primal is a video-only dating app. This policy explains what personal data we collect, why, who we share it with, how long we keep it, and the rights you have over it.

Primal is operated by [COMPANY LEGAL NAME], registered at [REGISTERED ADDRESS], company no. [REGISTRATION NUMBER] ("Primal", "we", "us"). We are the data controller for the personal data described here. Questions: privacy@primal.dating.

1. Who this applies to & age requirement

Primal is strictly for adults. You must be at least 18 years old to create an account or use the service. We do not knowingly collect data from anyone under 18; if we learn that an account belongs to a minor, we will delete it. See also our Terms of Service.

2. The personal data we collect

2.1 Data you give us

2.2 Data we collect automatically

2.3 Data from other sources

3. Sensitive data (special categories)

Primal is a dating service. The fact that you use it, together with the gender you enter and the people you choose to match with, may reveal or imply information about your sex life or sexual orientation; your videos may also reveal characteristics such as racial or ethnic origin or health. Privacy laws around the world give this kind of data extra protection — under different names and conditions:

You give this consent by choosing to create a profile and use the matching features, and you can withdraw it at any time by deleting your account, which stops further processing (see §9).

4. Why we use your data and our legal bases

Purpose Legal basis (GDPR Art. 6 / 9)
Create your account and verify your phone number Performance of a contract
Operate matching, messaging, and the feed (incl. processing special-category data) Contract + explicit consent (Art. 9(2)(a))
Show approximate location/distance Contract + consent (device permission)
Keep the service safe — content moderation, fraud and abuse prevention (incl. optional number checks) Legitimate interests; legal obligation
Respond to your requests and provide support Contract; legitimate interests
Comply with law and respond to lawful requests Legal obligation
Send service messages and (optional) marketing Legitimate interests; consent for marketing

The "legal basis" column follows the GDPR / UK GDPR model. Brazil's LGPD uses the same approach (Art. 7 — contract, consent, legitimate interests, legal/regulatory obligation; Art. 11 — consent for sensitive data), so the bases above map directly. Laws that do not require a named legal basis — such as California's CCPA/CPRA, other U.S. state laws, Canada's PIPEDA, and Australia's Privacy Act — instead rely on giving you notice, limiting use to the purposes described here, and obtaining your consent where required (always for sensitive data). Either way, we process your data only for the purposes above and honour the rights in §9.

5. Content moderation & safety

To protect users, we review certain content. Your free-text "opening line" is screened by an automated content-moderation service before it is shown to others. Videos and reported content may be reviewed (automatically and/or by trained staff) to enforce our Terms and applicable law. We may suspend or remove content or accounts that break the rules. Some of this involves automated processing; you can contact us to contest a decision.

6. Who we share data with

We do not sell your personal data. We share it only with service providers who process it on our behalf under contract ("processors"), and only as needed to run Primal:

Provider Purpose Data involved
BulkGate Sending SMS verification codes Phone number, code
Cloudflare (R2 storage & network) Storing and delivering videos; DNS Videos, technical data
Qencode Video transcoding Profile videos
Google Firebase (Cloud Messaging) Push notifications Push token, device data
Fly.io Application hosting (EU region) All data, in transit/at processing
CockroachDB / database hosting Storing account & profile data Account and profile data
OpenStreetMap / Nominatim Turning coordinates into an area name Approximate coordinates
Anthropic Automated moderation of opening-line text Opening-line text
Apple App Store / Google Play Distribution, purchases, subscriptions Purchase confirmations
Number-intelligence / anti-fraud vendors (only if/when enabled) Blocking disposable / fraudulent numbers Phone number, risk signals

We may also disclose data: (a) to law-enforcement, regulators, or courts when required by law or to protect users' safety; (b) to professional advisers; and (c) to a buyer or successor in connection with a merger, acquisition, or sale of assets.

7. International transfers

Primal is offered worldwide and some of our providers are located outside your country, including outside the European Economic Area (e.g. in the United States). Where we transfer personal data internationally, we rely on appropriate safeguards such as the European Commission's Standard Contractual Clauses, the UK International Data Transfer Agreement/Addendum, or an adequacy decision. You can request a copy of the relevant safeguards using the contact details below.

8. How long we keep data

9. Your rights

Depending on where you live, you have some or all of the following rights. To exercise any of them, contact privacy@primal.dating; we will respond within the time limits set by applicable law and may need to verify your identity.

9.1 If you are in the EEA, UK, or Switzerland (GDPR / UK GDPR)

Supervisory authority by EU/EEA country:

9.2 If you are in California (CCPA/CPRA)

9.3 If you are in Brazil (LGPD)

Under Brazil's Lei Geral de Proteção de Dados (LGPD) you can confirm whether we process your data and access it; correct incomplete or inaccurate data; request anonymisation, blocking, or deletion; request portability; obtain information about with whom we share data; and withdraw consent. The supervisory authority is the Autoridade Nacional de Proteção de Dados (ANPD).

9.4 If you are in Canada (PIPEDA)

Under PIPEDA (and applicable provincial laws such as Québec's Law 25) you can access the personal information we hold about you and request corrections, and you can complain to the Office of the Privacy Commissioner of Canada (OPC).

9.5 If you are in Australia

Under the Privacy Act 1988 and the Australian Privacy Principles you can access and seek correction of your personal information and complain to the Office of the Australian Information Commissioner (OAIC).

9.6 If you are in another U.S. state

If your state has a consumer-privacy law (for example Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, and others as they take effect) you generally have the right to access, delete, and correct your data, to obtain a copy, and to opt out of the "sale" of, "targeted advertising" with, or certain profiling of your data. As noted above, we do not sell your data or use it for cross-context targeted advertising. Where the law allows, you may appeal a decision on your request.

9.7 Everywhere else

Wherever you live, contact us at privacy@primal.dating and we will honour the data-protection rights your local law gives you.

10. Security

We use technical and organisational measures to protect your data — including encryption in transit, access controls, signed/authorised video delivery, and limiting who can access data. No system is perfectly secure, but we work to protect your information and will notify you and the relevant authorities of a breach where the law requires.

11. Automated decision-making

We use automated processing to recommend potential matches and to moderate content. These do not produce legal or similarly significant effects on you without human involvement; you can contact us to query a moderation outcome.

12. The website

This website loads fonts from Google Fonts, which may receive your IP address. The Primal app itself does not use third-party advertising trackers.

13. Children

Primal is not directed to, and may not be used by, anyone under 18. We do not knowingly process children's data. If you believe a minor is using Primal, contact privacy@primal.dating and we will act promptly.

14. Changes to this policy

We may update this policy. If we make material changes, we will notify you in the app or by other reasonable means and update the "Last updated" date above.

15. Contact us

Controller: [COMPANY LEGAL NAME], [REGISTERED ADDRESS]
Privacy enquiries & rights requests: privacy@primal.dating
Data Protection Officer (if appointed): [DPO NAME / EMAIL]
EU/UK representative (if applicable, Art. 27): [REPRESENTATIVE DETAILS]