Privacy Policy

1. About this Privacy Policy

Luvliy is a mobile application designed to help couples stay connected, preserve shared memories, exchange private experiences, and manage parts of their relationship together.

This Privacy Policy explains what personal data Luvliy processes, why it is processed, how it may be shared, how long it may be retained, and the rights available to you. It is intended to support compliance with applicable privacy laws, including the General Data Protection Regulation (GDPR) where it applies.

2. Data Controller

Sertaç Özküçükparlak is the data controller responsible for personal data processed through Luvliy.

Address: Tevfikbey SK. No: 20, Kadıköy - İstanbul

Privacy contact: sertacokp@gmail.com

If an EU representative is required under applicable law before Luvliy is offered to users in the European Economic Area, the representative details will be added to this Policy.

3. Personal Data We Process

We process information that is necessary to provide, operate, secure, and improve Luvliy. Depending on the features you use, this may include the categories below.

• Account and profile information, such as your email address, first name, country, city, profile photo, account identifier, and account timestamps.
• Partner and relationship information, such as connection records, invitation information, relationship start date, relationship milestones, disconnection history, archived relationship status, and reconnection history.
• Memories and user-generated content, including photos, videos, titles, notes, dates, milestones, and information about who created or approved shared content.
• Surprises and couple interactions, including Love Puzzle, Secret Code, Time Capsule, messages, media, questions, hints, delivery or unlock dates, and completion status.
• Reunion information that you choose to provide, such as destination, date and time, traveller information, and flight number.
• Quick Sends and interaction information, including sender, recipient, interaction type, and timestamp.
• Notification information, including push notification token, device platform, notification preferences, and notification delivery or processing status.
• Subscription and purchase metadata, such as plan, billing platform, product identifier, subscription status, entitlement identifiers, trial eligibility, and subscription period. Luvliy does not receive your full payment-card details.
• Support information, including support category, messages, request status, and information you voluntarily include in a support request.
• Limited technical and security information that Luvliy or its infrastructure providers may receive, such as IP address, request timestamps, device or platform information, app version, error information, and authentication or security logs.

4. Information Shared With Your Partner

Luvliy is built around a private connection between two users. When you connect with a partner, information and content that you create through shared couple features may be visible to that connected partner.

This may include relationship information, Memories, Milestones, Surprises, Reunion information, Quick Sends, and other shared couple content. You should only upload or share information and media that you have the right to use and share.

5. Disconnecting, Archiving, and Reconnecting

Disconnecting a partner does not delete either personal account. When a relationship is disconnected, the shared relationship history may be moved to a read-only archive that remains separate from any future relationship.

While the archive exists, both former partners may continue to access the archived shared history. If the same two users reconnect before the archive is deleted, Luvliy may restore that archived relationship so the couple can continue from where they left off.

An archived relationship may be permanently deleted by an authorized former partner. Permanent deletion removes the shared archive for both former partners and may include Memories, Milestones, Surprises, Reunions, Quick Sends, and related media. Once deleted, the archived relationship cannot be restored.

6. How We Use Personal Data

We do not sell your personal data. We do not use private couple content for third-party advertising.

• Create and manage Luvliy accounts and profiles.
• Connect users with their partners and manage active or archived relationship records.
• Provide Memories, Milestones, Surprises, Reunion, Quick Sends, and other couple features.
• Store, retrieve, and display content that you choose to add to Luvliy.
• Deliver notifications that you request or enable.
• Manage Premium access, trial eligibility and subscription status.
• Provide customer support and respond to requests.
• Detect, investigate, and prevent fraud, abuse, unauthorized access, and security incidents.
• Maintain, troubleshoot, and improve service reliability.
• Comply with applicable legal obligations and protect legal rights.

7. Legal Bases for Processing

Where the GDPR applies, Luvliy relies on one or more lawful bases depending on the processing activity.

• Performance of a contract: processing necessary to provide the Luvliy service you request, including account features, partner connection, storage of shared content, and access management.
• Legitimate interests: limited processing necessary to protect accounts and infrastructure, prevent abuse, diagnose technical problems, maintain service reliability, and respond to support requests, while taking your privacy rights into account.
• Consent: optional processing where applicable law requires consent. Where processing relies on consent, you may withdraw it at any time without affecting processing that was lawful before withdrawal.
• Legal obligations: processing or retention necessary to comply with applicable laws, lawful requests, regulatory requirements, or legal proceedings.

8. Sensitive Information

Luvliy does not require sensitive personal data in order to create an account. However, free-form text, photos, or videos that users voluntarily upload could reveal information that may be considered sensitive or a special category of personal data under applicable law.

Luvliy does not use such private content for advertising, unrelated profiling, or sale to third parties. You should avoid uploading sensitive information about another person unless you have the right and appropriate permission to do so.

9. Service Providers and Third Parties

We may use service providers to operate Luvliy. These providers may process data only for authorized purposes and are expected to apply appropriate safeguards.

Luvliy currently uses Supabase for parts of its backend infrastructure, including authentication, database, and storage functionality; Expo-related infrastructure for applicable app and notification functionality; and RevenueCat to help manage subscription products, purchase status and Premium entitlements.

Apple App Store and Google Play may process transaction information under their own privacy terms. Luvliy does not receive your full payment-card details.

• Cloud database and storage infrastructure.
• Authentication services.
• Push notification delivery.
• App hosting and distribution.
• Subscription entitlement and purchase-status management.
• Subscription and payment processing by the applicable app store.
• Security, diagnostics, and error monitoring where used.
• Customer-support infrastructure where used.

10. Third-Party Links

Luvliy may contain links that open external services or websites, such as Tripadvisor. When you open an external service, that provider's privacy policy and terms apply to your interaction with it. Luvliy is not responsible for the privacy practices of third-party services.

11. International Data Transfers

Some service providers used by Luvliy may process information in countries outside your country of residence. Where applicable privacy law requires safeguards for international transfers, we will use legally recognized transfer mechanisms and other appropriate protections.

12. Data Retention

We retain personal data only for as long as reasonably necessary for the purposes described in this Policy, including providing the service, meeting legal obligations, resolving disputes, and protecting security.

When information is no longer required, we will delete or anonymize it where reasonably possible.

• Account information is generally retained while your account remains active.
• Shared relationship content is retained while the active or archived relationship exists, unless it is deleted earlier or another applicable retention rule requires removal.
• Archived relationship data may remain available until an authorized user deletes the archive, an applicable account-deletion process removes it, or another retention rule applies.
• Support records may be retained for a reasonable period to resolve requests and maintain service records.
• Technical and security logs may be retained for a limited period appropriate to their purpose.
• Certain transaction or subscription records may be retained where required for legal, accounting, fraud-prevention, or platform-compliance purposes.

13. Account Deletion

Luvliy provides an account deletion option inside the application. Deleting your account is different from disconnecting your partner.

An account deletion request may permanently remove personal data and shared relationship data associated with your account, subject to information that must be retained by law or for legitimate legal purposes. Because some Luvliy content is shared between two users, deletion may also affect shared content available to the connected partner.

14. Your Privacy Rights

Depending on where you live and which privacy law applies, you may have rights concerning your personal data. Under the GDPR, these may include the rights listed below.

To exercise a privacy right, contact sertacokp@gmail.com. We may need to verify your identity before completing certain requests. Some rights are subject to legal limitations and may not apply in every situation.

• Request access to your personal data.
• Request correction of inaccurate or incomplete personal data.
• Request deletion of personal data in applicable circumstances.
• Request restriction of processing in applicable circumstances.
• Object to certain processing.
• Receive eligible personal data in a structured, commonly used, machine-readable format.
• Withdraw consent where processing is based on consent.
• Lodge a complaint with an appropriate data-protection authority.

15. Data Portability

Where required by applicable law, you may request a copy of eligible personal data that you provided to Luvliy in a structured, commonly used, machine-readable format. Portability may be limited where providing data would adversely affect the rights and freedoms of another person, including a current or former partner.

16. Security

We use reasonable technical and organizational safeguards designed to protect personal data against unauthorized access, loss, misuse, alteration, or disclosure. Measures may include authentication controls, database access restrictions, access-control policies, secure transmission, limited administrative access, and security monitoring.

No online service can guarantee absolute security. You are responsible for protecting your login credentials and for notifying us if you believe your account has been compromised.

17. Automated Decision-Making

Luvliy does not currently use personal data to make solely automated decisions that produce legal effects or similarly significant effects on users. If this changes, this Policy will be updated and any additional rights required by law will be provided.

18. Children's Privacy

Luvliy is intended only for users who are 18 years of age or older. By creating an account or using Luvliy, you confirm that you are at least 18 years old.

If we learn that personal data from a person under 18 has been collected through Luvliy, we will take appropriate steps to delete it, subject to applicable law.

19. Changes to this Privacy Policy

We may update this Privacy Policy when Luvliy's features, service providers, legal obligations, or data-processing practices change. When changes are material, we may notify users through the application or another appropriate method. The current version will show its last-updated date.

20. Contact

For privacy-related questions, requests, or complaints, contact Sertaç Özküçükparlak at sertacokp@gmail.com.

Postal location: Tevfikbey SK. No: 20, Kadıköy - İstanbul

You may also have the right to contact the data-protection authority in your country or region.