1. Introduction and Data Controller
This Privacy Policy explains how Zereshk Society ("we", "us", "our") collects, uses, stores, and protects your personal data in accordance with the General Data Protection Regulation (EU) 2016/679 ("GDPR"), the German Federal Data Protection Act (Bundesdatenschutzgesetz, "BDSG"), and other applicable data protection legislation.
Data Controller:
Zereshk Society
Berlin, Germany
Email: hello@zereshksociety.com
Website: www.zereshksociety.com
2. Categories of Personal Data
We collect and process the following categories of personal data:
2.1 Identity Data
- First name and last name
- Date of birth
- Nationality and heritage
- Profile photograph
2.2 Contact Data
- Email address
- Telephone number
- Current city of residence
2.3 Professional Data
- Profession and job title
- Company name (optional)
- Industry sector
- Income range
- Education level
- CV/Resume (optional)
2.4 Social Media Data
- LinkedIn profile URL (optional)
- Instagram handle (optional)
- Twitter/X handle (optional)
2.5 Special Categories of Personal Data (Article 9 GDPR)
With your explicit consent, we process the following special categories of personal data:
- Ethnic origin/heritage information
- Sexual orientation and relationship preferences
- Family status (marriage history, children)
2.6 Application and Profile Data
- Personal biography/essay
- Partner preferences and relationship goals
- Referral information
- How you heard about us
3. Legal Basis for Processing
We process your personal data on the following legal bases pursuant to Article 6(1) GDPR:
| Purpose | Legal Basis | GDPR Article |
|---|---|---|
| Application processing | Contract performance | Art. 6(1)(b) |
| Matchmaking services | Contract performance | Art. 6(1)(b) |
| AI profile analysis | Explicit consent | Art. 6(1)(a) |
| Special category data | Explicit consent | Art. 9(2)(a) |
| Marketing communications | Consent | Art. 6(1)(a) |
| Legal compliance | Legal obligation | Art. 6(1)(c) |
4. Automated Decision-Making and AI Processing
4.1 AI Profile Analysis
We use artificial intelligence systems to analyse your profile for compatibility matching purposes. This processing involves:
- Analysis of profile information to generate compatibility scores
- Pattern recognition to identify potential matches
- Automated pre-screening of applications
4.2 Human Oversight
No decision regarding your membership or matches is made solely by automated means. All AI-generated analyses are reviewed by our human curation team before any decision is made. You have the right to request human intervention pursuant to Article 22(3) GDPR.
4.3 Right to Object
You have the right to object to automated processing at any time. To exercise this right, please contact us at hello@zereshksociety.com. We will then process your application using exclusively manual review methods.
5. Data Retention
We retain personal data only for as long as necessary for the purposes for which it was collected:
- Unsuccessful applications: Data is deleted within 6 months of rejection, unless you consent to remain in our database for future consideration.
- Active members: Data is retained for the duration of membership plus 3 years for legitimate business purposes.
- Former members: Data is retained for 3 years after termination of membership, unless longer retention is required by law.
- Legal records: Data required for legal compliance (invoices, contracts) is retained for 10 years pursuant to German commercial law (HGB).
6. Data Recipients and Transfers
6.1 Categories of Recipients
Your personal data may be shared with:
- Service providers: IT infrastructure, email services, form processing (bound by data processing agreements)
- Other members: Limited profile information shared for matchmaking purposes (with your consent)
- Professional advisors: Legal counsel, accountants (bound by professional confidentiality)
- Authorities: Where required by law or court order
6.2 International Transfers
Some of our service providers may be located outside the European Economic Area (EEA). Where this is the case, we ensure appropriate safeguards are in place, including:
- EU adequacy decisions
- Standard contractual clauses (SCCs) approved by the European Commission
- Binding corporate rules where applicable
7. Your Rights under GDPR
Under the GDPR, you have the following rights with respect to your personal data:
- Right of access (Art. 15): You may request a copy of your personal data and information about how it is processed.
- Right to rectification (Art. 16): You may request correction of inaccurate or incomplete data.
- Right to erasure (Art. 17): You may request deletion of your data ("right to be forgotten") under certain circumstances.
- Right to restriction (Art. 18): You may request limitation of processing under certain circumstances.
- Right to data portability (Art. 20): You may request your data in a structured, machine-readable format.
- Right to object (Art. 21): You may object to processing based on legitimate interests or for direct marketing.
- Right to withdraw consent (Art. 7): You may withdraw consent at any time without affecting the lawfulness of prior processing.
To exercise any of these rights, please contact us at hello@zereshksociety.com. We will respond to your request within one month as required by law.
8. Data Security
We implement appropriate technical and organisational measures to protect your personal data, including:
- Encryption of data in transit and at rest
- Access controls and authentication measures
- Regular security assessments and audits
- Employee training on data protection
- Incident response and breach notification procedures
9. Data Breach Notification
In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify the competent supervisory authority within 72 hours as required by Article 33 GDPR. Where the breach is likely to result in a high risk to your rights and freedoms, we will also notify you directly without undue delay pursuant to Article 34 GDPR.
10. Cookies and Tracking Technologies
Our website uses cookies and similar technologies. Essential cookies are used to enable basic functionality and are processed based on our legitimate interest. Non-essential cookies (analytics, marketing) are only used with your explicit consent. You can manage your cookie preferences through your browser settings or our cookie consent tool.
11. Children's Data
Our services are not directed at individuals under 18 years of age. We do not knowingly collect personal data from minors. If we become aware that we have collected data from a minor, we will delete it immediately.
12. Supervisory Authority
You have the right to lodge a complaint with a data protection supervisory authority. The competent authority for complaints in Germany is:
Berliner Beauftragte für Datenschutz und Informationsfreiheit
Friedrichstr. 219
10969 Berlin
Email: mailbox@datenschutz-berlin.de
Website: www.datenschutz-berlin.de
13. Changes to This Policy
We may update this Privacy Policy from time to time. Material changes will be communicated to you via email or prominent notice on our website at least 30 days before taking effect. We encourage you to review this Policy periodically.
14. Contact Us
For any questions about this Privacy Policy or your personal data, please contact our data protection team:
Zereshk Society
Data Protection Enquiries
Email: hello@zereshksociety.com
Website: www.zereshksociety.com
Berlin, Germany