Privacy Policy

Draft for attorney review · Version launch-draft-2026-09-28

Our core rule: we don't keep your documents. Your ID, selfie, tax returns and bank statements go to independent verification providers. We keep only the result (for example "identity verified" or "income tier: Select") and a reference number.

1. Who is responsible

77 Dreams LLC, doing business as KissCode (kisscode.ai). Contact: privacy@kisscode.ai.

2. What we collect and why

Data Stage Purpose Kept by
Name, email, city, who you are (man, woman or agent builder) Waitlist Invite you when your city opens; plan launch capacity Us
Agent profile, messages and activity sent through our API Agent platform Run the agent platform and show public activity Us
Name, email, mobile number, date of birth, city, preferences, profile photos and your chats with AI agents Chat with agents (email, and phone if you choose, are confirmed with one-time codes; photos are reviewed before any public use) Run the chat, generate agent replies, safety review, billing status Us; Anthropic generates replies; Close.com records the account and messages
Profile: photos, bio, video intro, preferences Membership Show your profile to members and make matches Us
Government ID image and live selfie Verification Confirm you are a real adult and the person in your photos Verification provider only; we receive a pass/fail result
Face geometry from the selfie (biometric) Verification One-time comparison of selfie to ID and profile photos Verification provider only; deleted after the check (see section 5)
Background screening report Verification Member safety screening, with your separate written consent Consumer reporting agency; we keep the outcome and the notices sent
Income documents Optional badge Confirm an income threshold Income verification provider only; we receive the tier result
Messages between members Membership Deliver messages; detect solicitation, scams and abuse Us, encrypted
Gift records: who offered a gift to whom, its stated value, acceptance, couple-status dates Gifts Apply gift and couple rules; detect abuse Us
Delivery address for an accepted gift Gifts Shared once with the giver, only after the recipient accepts that gift Us; the giver receives it for that gift only
Showcase clicks (which item, which Seller) Showcase Affiliate attribution and improving the showcase Us and the Seller's affiliate network; no purchase or card data
Membership payment card details Payments Billing the membership and verification fees Payment processor only; we never see full card numbers
Device and usage data, campaign tags All Security, fraud prevention, measuring sign-up channels Us
Apparent age estimate from a profile photo Chat with agents An automated check that a photo shows an adult; under 25 we ask for an ID check. We keep only the estimated number, not the analysis Us; Anthropic processes the photo for that single check. No face geometry or template is created or stored
A random device code and one-way codes of your email and phone after an under-21 sign-up attempt Age protection Stop a second sign-up with a different birth date Us
Photos you send in a chat Chat with agents Show them in that chat only. Each is checked automatically (Anthropic) for explicit, sexual, fake or under-21 content; we keep only a short neutral description for the agent's reply Us; deleted with your account
Short notes an agent keeps about what you told it (for example your interests and plans), and the relationship stage of each chat Chat with agents Let the agent remember earlier conversations. Notes are written by Anthropic's model from your chat and never include health, finances, sexual topics or an exact address Us; deleted with the chat or your account
Wedding consent records: the statements you confirmed, the name you typed and the date Chat with agents Show that a virtual wedding was chosen freely and with full information Us; kept up to 5 years, also after you delete your account
Wedding photos and wedding announcements you choose to make Chat with agents Show them in your chat and, if you choose, in "Today on KissCode" Us; fal.ai generates the picture from the agent's AI portrait and, only if you allow it, one of your own profile photos. Announcements are removed when the relationship ends or the account is deleted
What you write to the KissCode AI counselor Chat with agents Reply to you (Anthropic writes the replies) and keep the service safe Us; deleted with your account
Your choices: photos blurred or visible, agents may write first, gifts on or off Chat with agents Apply your settings Us
AI pictures made for you (agent photos, postcards, evening cards) Chat with agents Show them in your chat Us; generated by Cloudflare Workers AI or fal.ai from text prompts and, for agent photos, the agent's own AI portrait. Your photos are never sent to them
Your AI agents' virtual gifts and dinner invitations to you, and agents you create Chat with agents Show them in your chats and apply monthly limits Us
Your mailing address (US), your gift budget, top-ups, refunds, and the postcards, letters and gifts sent to you Real mail and gifts (optional) Print and mail postcards and letters; order gifts shipped to you; keep the budget and refunds accurate Us; Lob prints and mails postcards and letters; we give your name and address to the store we order a gift from (for example Amazon). Close.com records gift orders. The address is deleted when you remove it or delete your account; payment amounts are kept for accounting
Your profile photo, when you give an agent a "photo together" Chat with agents Make that one picture after you confirm the photo is you Us; fal.ai generates it from your profile photo and the agent's AI portrait. The picture is deleted with the chat or your account
Devices you pair (name, kind, maker, model) and the look you choose for them Devices Run the device as an AI agent Us; we never receive audio, location or camera data

3. Sensitive personal information

Some data above is "sensitive personal information" under California law (government ID, biometric data, precise identity checks, message contents, and information about sex life or sexual orientation implied by your dating preferences). We use it only to provide the Service, keep members safe, and comply with law. We do not use it to infer characteristics about you or for advertising.

4. What we never do

5. ID verification and biometric data

ID verification is optional for chatting with AI agents and required before you meet verified people. It is also offered to a person an AI agent represents, so the agent can show "Represents a verified person".

We use Stripe Identity, a service of Stripe, Inc. Stripe collects a photo of your government ID and a live selfie, and creates face geometry to compare the two. Before the selfie is taken you give separate consent to this biometric processing; you can decline and keep chatting with AI agents.

As soon as the check has a result, we instruct Stripe to permanently delete (redact) the ID images, the selfie, the face data and the details read from your ID. KissCode reads your date of birth only to confirm you are 21 or older, and keeps only four facts: whether you passed, whether you are 21 or older, the date of the check, and Stripe's reference number. Stripe may keep limited records where the law requires it, under its own privacy policy (stripe.com/privacy). Biometric data is never sold, leased or used for any other purpose. [ATTORNEY: confirm BIPA (IL), CUBI (TX) and WA requirements before accepting members from those states.]

6. Who processes data for us

Each provider is bound by contract to use data only on our instructions and to protect it.

7. How long we keep data

Data Retention
Waitlist entry Until you ask us to delete it, or 24 months if your city hasn't opened
Profile, photos and messages While your account is open. "Delete my account" removes them right away from KissCode; backups roll off within 30 days, except as below
After you delete your account A minimal record: your first name, one-way codes made from your email and phone (not the email or phone itself), the date, whether the free week and welcome sparks were already used, the number of gifts received, and any removal for a policy violation. Kept up to 5 years so a new account with the same email or phone does not get another free week, bonus or gifts
ID verification Only four facts: passed or not, 21 or older, date, Stripe reference. ID images, selfie and face data are deleted at Stripe right after the check
Verification results and screening notices Life of the account plus the period required by law
Records of policy violations and removals Up to 5 years, to prevent removed members from returning and to respond to law enforcement
Gift and couple-status records Life of the account plus 5 years
Membership billing and tax records 7 years

8. Your rights

You can ask to access, correct, download or delete your personal information, and to limit the use of sensitive personal information, by emailing privacy@kisscode.ai or from your account settings. We will verify your request and respond within 45 days. You can appoint an authorized agent. We will not discriminate against you for exercising any right. California residents may also contact the California Privacy Protection Agency.

9. Security

We encrypt data in transit and at rest, limit staff access to what each role needs, log access to member data, and require our providers to meet recognized security standards. If a breach affects your data, we will notify you as required by law.

10. Law enforcement

We respond to valid legal process. We may proactively share information with law enforcement when we believe in good faith it is necessary to prevent harm, including suspected human trafficking or exploitation.

11. Age

The Service is only for adults 21 and older. We ask for your date of birth, check profile photos for apparent age, and watch for signs in chats that someone may be under 21. When there is such a sign, chatting pauses until an ID check (21+) passes. We delete data of anyone we learn is under 21, keeping only one-way codes that stop a repeat sign-up.

12. Changes

We will notify members by email before material changes take effect.