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    A smartphone displaying a dating application user interface alongside a glowing digital padlock representing cybersecurity.
    A smartphone displaying a dating application user interface alongside a glowing digital padlock representing cybersecurity.
    Regulatory Monitor

    Raw Dating's Encryption Lie: A Case Study in Regulatory Failure

    ByDII Regulatory Monitor··6 min read

    Key Points

    • Raw Dating exposed precise GPS coordinates, birth dates, and sexual preferences of over 500,000 users through an unsecured API for approximately 18 months.
    • Raw Dating advertised end-to-end encrypted messaging to users but never actually implemented the security features on its platform.
    • Security researcher Ulysses Saicha discovered an Insecure Direct Object Reference vulnerability that allowed unauthenticated access to the entire Raw Dating database.
    • Raw Dating co-founder Brock Shinen confirmed the platform patched the API vulnerability shortly after notification, before Raw Dating shut down in January 2025.

    A dating app that promised end-to-end encrypted messaging left users' GPS coordinates, birth dates, and sexual preferences accessible to anyone with basic web skills for potentially years. The kicker? Raw Dating never actually implemented the encryption it advertised.

    The breach, disclosed by security researcher Ulysses Saicha, exploited what's known as an Insecure Direct Object Reference vulnerability—essentially the web security equivalent of leaving every filing cabinet in the office unlocked with labels on the front. Anyone who accessed Raw's API could sequentially request user profiles without authentication, downloading precise geolocation data, profile photos, sexual orientation, and relationship preferences for the app's entire userbase.

    Person using dating app on smartphone
    Person using dating app on smartphone
    The DII Take

    This isn't a story about sophisticated hackers or zero-day exploits. It's about an app collecting the most sensitive combination of data imaginable—sexuality, precise location, and identity—whilst either lying about security measures or being too technically incompetent to understand what they'd promised. For an industry already facing existential trust issues and tightening regulatory scrutiny, Raw's failure is a gift to legislators arguing that dating platforms cannot self-regulate.

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    The encryption claim alone should trigger enforcement action, but with the company now defunct, affected users have little recourse beyond watching their data circulate indefinitely.

    Entry-level failures with expert-level consequences

    IDOR vulnerabilities rank among the most basic security failures in web development. The Open Web Application Security Project lists them in its top ten most critical risks, alongside SQL injection and cross-site scripting. Preventing them requires implementing proper authentication checks—verifying that User A requesting Profile B actually has permission to view it.

    That Raw's engineers either didn't know to implement these checks or chose not to raises uncomfortable questions about the company's technical foundations. The app operated for approximately 18 months before shutting down. During that period, according to Saicha's disclosure, any technically literate person could have harvested the entire user database.

    Raw co-founder Brock Shinen told TechCrunch the company 'patched the issue shortly after being notified' and had 'additional safeguards in place'. Neither claim offers much comfort. The timeline remains unclear—when was the vulnerability introduced, when was it disclosed, and was there any evidence of exploitation before the patch?

    The 'additional safeguards' assertion deserves particular scepticism given that Raw apparently advertised encryption it never implemented. Either the company deliberately misled users about a core security feature, or leadership didn't understand their own product's technical specifications. Neither scenario inspires confidence in whatever safeguards supposedly existed.

    Security and privacy concerns on mobile device
    Security and privacy concerns on mobile device

    Location data and the stalker problem

    Dating apps inevitably collect sensitive information. Sexual preferences, relationship history, private messages—all standard. But Raw's exposure of precise GPS coordinates elevates the risk considerably.

    Most mainstream platforms obscure exact locations, showing approximate distance ('2 miles away') rather than coordinates accurate to within metres. This design choice reflects basic threat modelling: dating apps serve users actively seeking to meet strangers, including some users with abusive ex-partners, LGBTQ+ individuals in hostile environments, or high-profile people requiring discretion.

    Precise location data transforms speculative risk into concrete danger. A hostile actor with access to Raw's API could have identified users by sexual orientation, tracked their exact movements, and correlated location patterns to identify home addresses or workplaces.

    The exposure is particularly egregious given Raw's apparent positioning as a privacy-conscious alternative. Users who specifically chose the platform based on encryption promises were systematically placed at greater risk than if they'd used a mainstream app with proper security infrastructure.

    Regulatory implications and the compliance gap

    Raw's failure arrives as dating platforms face intensifying regulatory scrutiny. Match Group (MTCH) disclosed $625,000 in fines related to a 2024 Irish Data Protection Commission investigation into Tinder's data handling. Grindr (GRND) paid €5.5M in 2023 for GDPR violations related to sharing users' HIV status and location data with advertising partners.

    Those enforcement actions targeted platforms with hundreds of engineers and dedicated compliance teams. Raw appears to have operated without basic security competence, let alone a meaningful privacy programme.

    The UK's Online Safety Act, which came into force in stages throughout 2024, requires dating platforms to conduct risk assessments addressing content-based and user-safety harms, including location exposure risks. Ofcom's draft codes of practice, published in November 2024, specifically mention dating apps as high-risk services requiring enhanced protections. The EU's Digital Services Act imposes similar obligations on platforms accessible to European users.

    Raw's closure conveniently pre-empts enforcement, but regulators should take note of the compliance gap. Platforms can launch, collect sensitive data from hundreds of thousands of users, operate with negligent security practices, and fold before accountability arrives. The barrier to entry for launching a dating app remains low; the barrier to launching one safely evidently remains lower than it should be.

    Data protection and cybersecurity concept
    Data protection and cybersecurity concept

    What happens to the data

    The immediate vulnerability may be patched, but the data exposure persists. Saicha disclosed the flaw responsibly, but nothing prevents others from having discovered it independently during Raw's 18-month operation. Any downloaded datasets remain in circulation indefinitely.

    For affected users, recourse is limited. They can't demand deletion from a defunct company. They can't sue an entity that's already closed. They can't even confirm whether their specific data was accessed, since Raw apparently lacked the logging infrastructure to know.

    The incident should prompt uncomfortable questions for app store operators. Apple and Google both require privacy disclosures and review apps for policy compliance before approval. Raw clearly violated its own privacy promises, yet remained available on both platforms until voluntarily shutting down.

    Dating app operators—particularly smaller platforms attempting to differentiate on privacy—should recognise that marketing encryption you haven't implemented isn't just negligence. It's potential grounds for enforcement action under consumer protection law, GDPR's accountability principle, and the advertising standards frameworks in most jurisdictions. The industry's trust deficit is real, and incidents like Raw's confirm that some platforms genuinely cannot be trusted with the data they collect.

    Key Takeaways

    • Niche dating app operators attempting to differentiate on privacy features face severe consumer protection and General Data Protection Regulation enforcement risks if advertised security measures are omitted.
    • Compliance teams and investors must enforce mandatory pre-launch security audits as regulators like Ofcom and the Irish Data Protection Commission intensify oversight of dating platforms.

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    DII Regulatory Monitor

    Policy & Regulation Desk

    The DII Regulatory Monitor tracks legislation, enforcement action, safety rules and compliance across dating industry markets.

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