Effective date: 29 May 2026
Last updated: 29 May 2026
Beta Release Notice — v1.x.x
This Privacy Policy applies to Mingle v1.x.x, which constitutes the beta phase of the Service. By creating an account during the beta period, you acknowledge that you are accessing pre-release software. Beta software may be subject to defects, unannounced changes, service interruptions, or data loss inherent to active development. Mingle's legal obligations under the GDPR and all applicable data protection law apply in full during the beta period; however, beta users accept the inherent technical risks associated with using software that is still under active development.
This Privacy Policy explains how Mingle collects, uses, stores, and shares information about you when you use the Mingle platform, including the website at mingle.webagab.fr and any associated mobile applications (collectively, the "Service").
This policy covers all personal data processed in connection with creating and managing an account and professional profile; publishing and managing travel itineraries; discovering and connecting with other members; coordinating in-person meetings; and any communications between you and Mingle.
What Mingle does not do. Mingle does not use GPS-based location tracking — location information is based solely on what you manually enter. Mingle does not collect IP-based geolocation, use advertising cookies, or share data with advertising networks or data brokers. There is no user-to-user messaging within the current Service.
Supplementary notices. If you are a California resident, the California Privacy Notice Addendum supplements this policy. In the event of any conflict between that notice and this policy with respect to California residents, the California notice controls.
This policy should be read alongside Mingle's Terms of Use.
The data controller responsible for your personal data under the GDPR and other applicable data protection laws is:
Gabriel Gostiaux
Auto-entrepreneur (sole trader), registered under French law
SIRET: [YOUR SIRET NUMBER]
Registered address: Bd de Constance, 77300 Fontainebleau, France
Privacy contact email: gabriel@webagab.fr
Website: mingle.webagab.fr
Mingle does not have a designated Data Protection Officer (DPO), as the scale of data processing does not require one under GDPR Article 37 at this stage.
| Data | How collected |
|---|---|
| Email address | Provided at registration |
| Password | Provided at registration — stored as an irreversible hash (bcrypt/Argon2 via Better Auth); the plain-text password is never stored or logged |
| Full name, first name, last name | Provided at registration and in profile settings |
| One-time password (OTP) codes | Generated by Mingle during email verification and login; deleted nightly after expiry |
All location information is user-inputted only. No GPS data, IP-based geolocation, or device location is collected or used at any point.
| Data | How collected |
|---|---|
| City, country, and state of residence | Manually entered by user |
| Company, profession, industry | Manually entered by user |
| Biography, headline | Manually entered by user |
| Languages, interests, "looking for", "can help with" | Manually entered by user |
| LinkedIn URL, personal website URL, Twitter URL, Instagram URL | Optionally provided by user |
| Profile photo (avatar), banner image | Uploaded by user |
| Data | How collected |
|---|---|
| Trip destination (city, country) | Manually entered by user |
| Trip dates (departure date, return date) | Manually entered by user |
| Trip notes | Optionally entered by user |
| Trip visibility setting (public / private / hidden) | Set by user |
| Match records (overlap between two users' itineraries) | Generated automatically by the matching algorithm from trip data |
| Meeting request metadata (status, proposed timeslots) | Generated when users coordinate in-person meetings |
| Connection records (accepted connection requests) | Generated when a connection request is accepted |
| Data | How collected | Purpose |
|---|---|---|
| Session token | Generated server-side upon login | Maintaining authenticated sessions (stored in httpOnly, Secure cookie) |
| Browser and device user-agent string | Provided automatically by browser or device | Session management and security |
| OTP verification codes | Generated by Mingle | Email verification and login; deleted nightly after expiry |
| Database audit logs (pgaudit) | Generated automatically at database level | Security audit trail — detecting unauthorised data access |
| Infrastructure-level logs (network ingress) | Generated automatically by OVH hosting infrastructure | Security, abuse prevention, and operational continuity |
Infrastructure-level logs (which may include IP addresses at the network ingress layer) are managed by OVH SAS as part of standard hosting operations. They are not stored in Mingle's application database and are not used for profiling.
| Data | How collected |
|---|---|
| Page views and navigation paths (anonymised) | Collected by Mingle's self-hosted Matomo instance in cookieless mode |
Mingle uses Matomo configured with disableCookies: true. No cookies are set by Matomo. No personal identifiers are transmitted or stored. This configuration is exempt from the requirement for a cookie consent banner under CNIL guidelines. Matomo is self-hosted on Mingle's own infrastructure. No analytics data is shared with any third party.
When a user is reported through the in-app reporting feature, Mingle creates a report record containing: the reporting user's account identifier and display name (snapshotted at the time of the report); the reported user's account identifier and display name (snapshotted at the time of the report); the reason or description text provided by the reporting user; and a resolution status updated by Mingle following manual review.
Report records are retained indefinitely, including after either account is deleted, under GDPR Article 17(3)(e) (establishment, exercise, or defence of legal claims) and on the basis of Mingle's legitimate interest in preventing repeat abuse (GDPR Article 6(1)(f)).
When you contact Mingle's support team, Mingle may collect and retain the content of your messages, your email address, and any information you choose to include in your communication, solely for the purpose of responding to your enquiry and maintaining a record of the interaction.
Mingle does not intentionally collect special category data within the meaning of GDPR Article 9. Some profile fields (such as "interests" and "bio") are free-text and entirely user-controlled. If you voluntarily include information that could be classified as special category data in a free-text field, you do so at your own initiative. Mingle does not process such incidental disclosures for any purpose beyond displaying your profile in accordance with your visibility settings.
Mingle collects personal data from the following sources:
Mingle does not receive personal data from third-party data brokers, advertising networks, or social media platforms. Google OAuth has been removed from the authentication stack — no data is received from Google or any other OAuth provider.
Purpose: Register your account, verify your email address, and authenticate you on subsequent logins, including via OTP codes and passkeys (FIDO2/WebAuthn).
Legal basis: Performance of a contract — GDPR Article 6(1)(b).
Data used: Email address, password (hashed), full name, OTP codes, session token, device user-agent.
Purpose: Run the travel overlap matching algorithm; display your profile to matched users in accordance with your visibility settings; enable connection requests and in-person meeting coordination.
Legal basis: Performance of a contract — GDPR Article 6(1)(b).
Data used: All profile data (Section 3.2), travel and matching data (Section 3.3).
Purpose: Allow users to report harmful or inappropriate behaviour; investigate reports; restrict or remove accounts that violate the Terms of Use; maintain the integrity and safety of the community.
Legal basis: Legitimate interests — GDPR Article 6(1)(f).
Data used: Profile identifiers and display names (snapshotted at report time), report records, relevant usage or technical data as necessary for the investigation.
Mingle relies exclusively on user reports for moderation. Mingle does not automatically scan, filter, or moderate content with algorithms.
Purpose: Understand how users navigate the platform; identify technical issues; improve existing features and plan new ones.
Legal basis: Legitimate interests — GDPR Article 6(1)(f). Analytics data is anonymised and cookieless (Matomo); no personal identifiers are processed.
Data used: Anonymised page views and navigation paths (Section 3.5).
AI and machine learning: Mingle does not currently use personal data to train machine learning or AI models beyond what is strictly necessary to operate the matching algorithm (which considers only travel dates and destinations). If this changes, this policy will be updated and users will be notified.
Purpose: Send transactional and service notifications (account verification emails, OTP codes, policy change notices); respond to support enquiries.
Legal basis: Performance of a contract — GDPR Article 6(1)(b) for essential service communications. Legitimate interests — GDPR Article 6(1)(f) for optional product updates, with opt-out available.
Data used: Email address, account status, support interaction data.
Purpose: Comply with applicable laws, regulations, court orders, and lawful requests from public authorities; establish, exercise, or defend legal claims; protect the rights and safety of Mingle, its users, and third parties.
Legal basis: Legal obligation — GDPR Article 6(1)(c); or legitimate interests — GDPR Article 6(1)(f).
Data used: Any data categories necessary in the given context.
Purpose: Process payments for paid subscription tiers when introduced.
Legal basis: Performance of a contract — GDPR Article 6(1)(b).
Data used: Name, email address, and billing details as required by the applicable Merchant of Record service. Payment card data is not processed or stored by Mingle.
This purpose is not currently active. Payments will be handled exclusively by a third-party Merchant of Record service (see Section 7.2). This policy will be updated, and users will be notified, when paid tiers are activated.
Mingle sets one strictly necessary cookie: a server-side session authentication cookie (httpOnly, Secure, SameSite=Lax). This cookie contains your session token and is required to maintain your authenticated session. It is set upon login and deleted when your session expires or when you log out. It does not track your behaviour across third-party websites and is not used for advertising or profiling. Strictly necessary cookies are exempt from consent requirements under the ePrivacy Directive.
Mingle uses a self-hosted instance of Matomo Analytics, configured with disableCookies: true. Matomo therefore sets no cookies and collects no personal identifiers. The anonymised data it collects is stored exclusively on Mingle's own infrastructure and is not shared with any third party. This configuration is CNIL-compliant and exempt from the cookie consent banner requirement under CNIL deliberation No. 2020-091.
Mingle does not use advertising cookies, tracking pixels, or third-party analytics cookies. Mingle does not work with advertising networks, data brokers, or any party that tracks you across websites for advertising purposes. No third-party JavaScript tracking code is loaded on Mingle's pages.
When you use the Service, other users will see information from your profile in accordance with your chosen visibility settings. Users with an overlapping travel itinerary will see your display name, profile photo, city, profession, company, bio, interests, headline, languages, and social profile links — to the extent you have completed these fields and your trip visibility setting permits discovery. Meeting request status is visible only to the two users involved. You control what information appears in your profile and may update or remove it at any time through account settings.
Mingle shares personal data with the following data processors, who act only on Mingle's instructions under written data processing agreements:
| Processor | Role | Location | DPA |
|---|---|---|---|
| OVH SAS | Cloud hosting infrastructure — Kubernetes cluster, PostgreSQL database, Redis, storage volumes | EU — France (Strasbourg and Gravelines) | OVH DPA |
| OVH SAS | SMTP relay — transactional email delivery (OTP codes, account notifications) | EU — France | Same OVH DPA as above |
| Matomo (self-hosted) | Analytics — anonymised navigation data only (cookieless, no personal identifiers) | EU — Mingle's own infrastructure | Self-hosted: Mingle is both controller and processor; no third-party sharing |
| Merchant of Record (future) | Payment processing — Stripe, Paddle, or Dodo Payments (see Terms of Use Section 11) | EU and/or worldwide — disclosed at checkout | Each provider publishes its own DPA; will be linked at the point of activation |
No other third parties receive personal data. Google OAuth has been removed from the authentication stack. Mingle does not use third-party advertising, analytics, or marketing platforms.
Mingle may disclose personal data to courts, law enforcement authorities, regulators, or other public bodies where required to do so by applicable law, court order, or other legal process, or where Mingle reasonably believes such disclosure is necessary to protect the rights, property, or safety of Mingle, its users, or the public.
In the event of a merger, acquisition, restructuring, or sale of all or substantially all of Mingle's assets, personal data may be transferred to the acquiring entity. Mingle will notify affected users before their data is transferred or becomes subject to a materially different privacy policy.
All personal data collected and processed by Mingle is stored on OVH SAS infrastructure located in France (data centres in Strasbourg and Gravelines). No personal data is transferred outside the European Economic Area in the current configuration.
When paid subscriptions are activated and a Merchant of Record service is used, billing-related data may be processed by that MoR's infrastructure, which may be located outside the EEA. Where such transfers occur, they will be governed by Standard Contractual Clauses or another approved transfer mechanism, and will be disclosed at the point of payment.
Mingle retains personal data only for as long as necessary for the purposes described in this policy or as required by applicable law.
| Data category | Retention period | Trigger for deletion |
|---|---|---|
| Account and profile data | Until account deletion | User-initiated account deletion or admin action |
| Trip data (destination, dates, notes, visibility setting) | Until account deletion | Cascade-deleted from your account upon deletion |
| Match and travel overlap records | Deleted from your account upon deletion; fully removed from the Service only once all users involved in the overlap have deleted their accounts | Partial deletion upon your account deletion; complete deletion when the last involved user's account is deleted |
| Meeting request records | Deleted from your account upon deletion; fully removed from the Service only once all users involved in the meeting have deleted their accounts | Same as match records above |
| Connection records | Deleted from your account upon deletion; the corresponding record on the other user's side is removed simultaneously | Cascade-deleted on both sides upon either user's account deletion |
| Session tokens | Deleted nightly after session expiry | Automated nightly purge job |
| OTP verification codes | Deleted nightly after expiry | Automated nightly purge job |
| Beta invitation links | Indefinitely | Retained as access control records for the beta programme; not deleted upon account deletion |
| Safety and moderation report records | Indefinitely — including after account deletion | Not deleted; retained under GDPR Art. 17(3)(e) (legal claims) and Art. 6(1)(f) (abuse prevention) |
| Database audit logs (pgaudit) | Duration of pod lifecycle (currently ephemeral) | Pod restart or rolling update |
| Database backups (daily encrypted snapshots) | 7 days rolling | Automated overwrite by the daily backup rotation |
| Support communication data | Duration of the interaction plus a reasonable administrative period | Reviewed on a case-by-case basis |
Match and meeting records — shared data. Because match, travel overlap, and meeting records involve more than one user, deleting your account removes your copy immediately but does not remove the record from the other user's account. The shared record is fully deleted from the Service only once all users involved have deleted their accounts.
Report records and erasure requests. Report records in which you appear — as reporter or as reported party — are exempt from the right to erasure under GDPR Article 17(3)(e) and will be retained indefinitely. Deleting your account does not remove these records.
Beta invitation links. Invitation links issued during the beta programme are retained indefinitely as access control and audit records. They are not cascade-deleted upon account deletion.
| Measure | Description |
|---|---|
| Encryption in transit | TLS 1.2+ on all connections — application layer, PostgreSQL database, and Redis |
| Encryption at rest | LUKS-encrypted storage volumes (csi-cinder-high-speed-gen2-luks) on OVH infrastructure |
| Access control | Separate database roles for runtime (mimap_app) and migrations (mimap_migrator); principle of least privilege enforced |
| Row-Level Security (RLS) | Enforced at the PostgreSQL database level for trip and user data |
| Audit logging | PostgreSQL pgaudit extension logging all write operations and DDL commands |
| Password storage | Passwords stored as irreversible hashes using bcrypt/Argon2 via Better Auth; plain-text passwords are never stored, logged, or transmitted |
| Authentication | Email/password with OTP email verification; support for passkeys (FIDO2/WebAuthn) |
| Session security | Session tokens stored in httpOnly, Secure, SameSite=Lax cookies — not accessible to JavaScript |
| Network isolation | Kubernetes NetworkPolicy restricting pod-to-pod communication to authorised services only |
| Automated backups | Daily encrypted database snapshots with 7-day rolling retention |
In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, Mingle will notify the CNIL within 72 hours as required by GDPR Article 33, and will inform affected users without undue delay where required by GDPR Article 34.
You have the right to request confirmation of whether Mingle processes personal data about you, and if so, to receive a copy of that data and information about how it is processed.
You have the right to request correction of inaccurate or incomplete personal data. Most profile information can be updated directly at any time through account settings.
You have the right to request deletion of your personal data. You can exercise this right directly by deleting your account through account settings, which triggers immediate cascade deletion of your profile, trip, match, meeting request, and connection data.
You have the right to request that Mingle restrict the processing of your personal data in certain circumstances, for example, while the accuracy of data is contested.
You have the right to receive personal data you have provided to Mingle in a structured, commonly used, machine-readable format. An automated data export feature has not yet been implemented. In the meantime, you may request a copy of your data by contacting Mingle at gabriel@webagab.fr. Mingle will provide it within one month.
You have the right to object to processing based on legitimate interests (GDPR Article 6(1)(f)), which applies to the safety/moderation processing (Section 5.3) and analytics processing (Section 5.4). Upon receipt of a valid objection, Mingle will cease such processing unless it can demonstrate compelling legitimate grounds or where processing is necessary for the establishment, exercise, or defence of legal claims.
None of Mingle's current data processing activities rely on consent as the legal basis. The legal bases used are contract performance (Article 6(1)(b)) and legitimate interests (Article 6(1)(f)). There is accordingly no consent to withdraw.
If you believe that Mingle has not complied with its obligations under the GDPR, you have the right to lodge a complaint with the relevant supervisory authority. In France, this is the CNIL: cnil.fr/fr/plaintes. If you are resident in another EU member state, you may lodge a complaint with the supervisory authority in your country of residence.
To exercise any of the rights described above (other than account deletion and profile correction, which are available directly in account settings), please contact Mingle at gabriel@webagab.fr. Mingle will respond within one month of receipt. Mingle may request proof of identity before processing a rights request.
The Service is intended for users aged 18 years and over. Mingle does not knowingly collect personal data from individuals under the age of 18. If Mingle becomes aware that it has collected data from a user under 18, that account will be suspended and the associated data deleted without delay. If you believe that a minor has registered on the Service, please contact Mingle at gabriel@webagab.fr.
Mingle provides tools to help you find and connect with other members but does not organise, supervise, or control offline meetings. Any decision to meet another user in person is made entirely at your own discretion and risk. Mingle is not responsible for events, behaviour, or incidents that occur during or following offline interactions between users, subject to mandatory law. For guidance on safe meeting practices, see Section 8 of the Terms of Use.
Mingle's data processing is designed to comply with Regulation (EU) 2016/679 (GDPR). The legal bases for each processing activity are described in Section 5. The data controller is identified in Section 2. Your rights are described in Section 11.
UK residents. Mingle's processing is also consistent with the UK GDPR. Your right to lodge a complaint with the UK supervisory authority is preserved: Information Commissioner's Office (ICO) at ico.org.uk/make-a-complaint.
If you are a California resident, please refer to the California Privacy Notice Addendum for additional information about your rights under the CCPA/CPRA. Mingle does not sell or share personal information as those terms are defined under the CCPA/CPRA.
Mingle may update this Privacy Policy from time to time to reflect changes in the Service, applicable law, or data processing practices. When material changes are made, Mingle will update the "Last updated" date, notify you via in-app notification and/or email, and apply a reasonable notice period. The current version is always available at mingle.webagab.fr/legal/privacy.
For all privacy-related enquiries, GDPR rights requests, or questions about this policy:
Gabriel Gostiaux
Auto-entrepreneur
Bd de Constance, 77300 Fontainebleau, France
Email: gabriel@webagab.fr
Website: mingle.webagab.fr
CNIL: cnil.fr/fr/plaintes
This Privacy Policy is governed by French law and the General Data Protection Regulation (EU) 2016/679. Current version always available at mingle.webagab.fr/legal/privacy.