Dating is personal. That is why we collect only what the service cannot work without, and tell you plainly what happens to that data afterwards.
By using Gulun, you confirm that you have read this policy. If you disagree with any part of it, please do not create an account, or delete the one you have.
1Who is responsible for your data
The controller of your personal data (the operator) is [Operator name], address: [address]. The operator runs the Gulun dating service at gulun.ge and in its related apps.
Data is processed in accordance with the Law of Georgia “On Personal Data Protection” of 14 June 2023 and other Georgian legislation. For any questions about your data, write to privacy@gulun.ge.
2What data we collect
What you tell us
- When you sign up: your name or nickname, email address, password (stored only as a hash), gender, date of birth and city.
- In your profile: photos, a few words about yourself, height, interests, what you expect from dating, and any other fields you choose to fill in.
- When you communicate: messages, attachments, reports and requests to support.
- When you pay: purchase details (service, amount, date, status). Your card number and other payment details are entered on the payment provider’s side; we never see or store them.
What is generated as you use the service
- Technical data: IP address, device and browser type, language, time zone, login times.
- Activity in the service: profile views, likes, favourites, opened dialogues, contacts spent and credited, privacy settings.
- Security data: login logs, signals of suspicious activity, moderation results.
Some profile details may indirectly reveal aspects of your private life. We do not require them: apart from the sign-up fields, everything is optional, and you decide what to show in your profile and what to keep to yourself.
3Why we process data and on what legal basis
We use data only for clear purposes and rely on the legal grounds provided by Georgian law:
| Purpose | Legal basis |
|---|---|
| Sign-up, login, running your profile, search and messaging | Performance of our agreement with you |
| Age verification (18+) and manual moderation of profiles and photos | Performance of the agreement; legitimate interest in user safety |
| Protection against fraud, fake profiles, spam and account hijacking | Legitimate interest of the operator and users |
| Tracking contacts and paid services, accepting payments | Performance of the agreement; tax accounting obligations |
| Service emails: email confirmation, password reset, important changes | Performance of the agreement |
| Notifications about new messages and events, service news | Your consent — you can withdraw it in settings or via the link in any email |
| Responding to requests from public authorities | Requirement of Georgian law |
We do not sell personal data, do not share it with advertisers, and do not make decisions that have legal effects for you based solely on automated processing: an account block is always confirmed by a moderator.
4What other users can see
Other members can see your name, age (but not your date of birth), city, public photos and the profile fields you have filled in. Your email, password, IP address and payment history are not visible to anyone except authorised staff of the operator.
Private photos are visible only to people you have given access to, and you can revoke it at any time. Invisible mode and a hidden online status let you use the service without others noticing.
5Who we share data with
To keep the service running, some processing is carried out by our contractors (processors). They act on our instructions, under a contract, and only to the extent needed for their task:
- Hosting provider — the servers that run the website and database.
- Cloud storage — storing and delivering photos.
- Email service — sending service emails and notifications.
- Payment provider — accepting payments in GEL and processing payment data under its own security rules.
Data may also be disclosed to Georgian public authorities where the law requires it, and to protect the rights and safety of users — for example, when investigating fraud.
If a contractor stores data outside Georgia, the transfer is allowed only to countries with an adequate level of data protection, or where safeguards provided by Georgian law are in place (for example, contractual data protection clauses). You can request the current list of contractors at privacy@gulun.ge.
6How long we keep data
| Data | Retention period |
|---|---|
| Profile, photos, messages, settings | While your account is active, then under the deletion rules below |
| Payment records | The period set by Georgian tax and accounting legislation |
| Login logs and technical logs | Up to 12 months |
| Records of violations and blocks | Up to 3 years after the block — so the violator cannot come back under a new name |
| Correspondence with support | Up to 2 years after your last request |
Deleting your account
You can delete your account in your profile settings. Your profile is hidden from search straight away, and you have 30 days to change your mind: just log in again and confirm the restore. After 30 days, the account, profile, photos and conversations are deleted permanently. We keep only the information we are required to keep by law (such as payment records) and records of violations — for the periods in the table above.
7Your rights
Under the Law of Georgia “On Personal Data Protection”, you have the right to:
- find out whether we process your data, which data exactly, for what purpose and who it has been shared with;
- get a copy of your data, including in a machine-readable format where technically possible;
- correct inaccurate or incomplete information — most of it you can change in your profile yourself;
- request that your data be deleted or destroyed, and that its processing be restricted (blocked);
- withdraw your consent at any time where processing is based on it; this does not affect the lawfulness of processing before the withdrawal;
- object to processing based on legitimate interest;
- complain about our actions to the Personal Data Protection Service of Georgia or to a court.
To exercise a right, write to privacy@gulun.ge from the email linked to your account. We may ask you to confirm your identity so that we do not disclose data to someone else. We respond within the time limits set by law — as a rule, no later than 10 working days.
9How we protect data
The connection to the website is encrypted (HTTPS), passwords are stored only as hashes, and staff access to data is limited to what their work requires and is logged. Photos are moderated before they are published.
If an incident occurs that threatens your rights, we will notify the Personal Data Protection Service of Georgia within the time limit set by law, and let you know if the risk to you is high.
10Adults only
Gulun is intended for people aged 18 and over. We do not knowingly collect data from minors. If we find that a profile was created by someone under 18, it will be blocked and the data deleted. You can report such a profile with the “Report” button or at support@gulun.ge.
11Changes to this policy
We update this policy when the service or the law changes. The current version is always on this page, and the date at the top shows when it took effect. We will let you know about significant changes by email or with a notification in the service.