Privacy Policy
1. Who is responsible
Michael Büttner (private individual, Germany), contact: privacy@luciamor.life. We refer to the controller as “we”. Luciamor is in closed beta and offered to invited users only.
2. What Luciamor is
Luciamor is a private companion app for two people (a couple). Content is visible only to the two members of a couple, and to us as operators where technically necessary (see section 8). It is not end-to-end encrypted.
3. Data we process and why
| Data | Purpose | Legal basis (GDPR) |
|---|---|---|
| Account: sign-in identifier (phone number, or email address if you use email, Google or Apple sign-in), display name, account ID, sign-in and security logs | Create and secure your account, verify you by SMS code or provider sign-in, pair you with your partner, prevent abuse | Art. 6(1)(b) contract; Art. 6(1)(f) security |
| Profile: optional profile fields and profile photo | Show your profile to your partner and personalise games | Art. 6(1)(b) |
| Shared content you create: events, dates, locations, flight numbers, photos and comments, plans, links and link previews, chat messages, photos and GIFs, game answers and reactions, daily-background choices | Provide the app’s features to you and your partner | Art. 6(1)(b) |
| Calls: who called whom, when, duration, result, connection quality. Never the audio. Technical connection data incl. IP addresses is deleted within two days | Provide voice calls and diagnose connection problems | Art. 6(1)(b), (f) |
| Device data: push notification tokens, app version, platform | Deliver notifications and ringing for messages and calls | Art. 6(1)(b) |
| Approximate device location (only if you allow it) | Bias address suggestions when you add a place. Not stored on our servers | Art. 6(1)(a) consent |
| Microphone, camera and photo access (only if you allow it) | Calls, taking and uploading photos. You can revoke each permission in your device settings | Art. 6(1)(a) |
| Website: server logs (IP address, time, page) kept by our hosting provider | Deliver and secure the website | Art. 6(1)(f) |
We do not use advertising, tracking or analytics SDKs, and we do not sell personal data.
4. AI features (optional)
If you or your partner turn on the AI questions, we send a minimum of context to Google’s Gemini service to write and compare questions: filled-in profile fields, short excerpts of messages (not automatic notifications), titles and places of plans and events, and earlier answers, only from the sources enabled in the settings. We never send links, the private gallery, chat photos or GIFs, or your answers in some games. Either of you can switch the AI off at any time. We use a paid Gemini service for which Google states it does not use the data to improve its products.
5. Recipients and service providers
- Google (Firebase / Google Cloud): authentication, database (Firestore), file storage, cloud functions, push notifications (FCM), hosting, and the Gemini AI service. Google Ireland Limited / Google LLC act as our processor under a data processing agreement.
- Apple: push notification delivery on iOS, and “Sign in with Apple” if you choose it.
- Google Sign-In: if you choose it, we receive your name and email address from Google, only to authenticate you. We request no other Google user data. Our use of information received from Google APIs adheres to the Google API Services User Data Policy, including its Limited Use requirements.
- SMS delivery: the verification code is sent by Firebase Authentication through telecom providers.
- KLIPY (GIF search): the search text and your language are sent when you search for a GIF in the chat.
- Photon (komoot) / OpenStreetMap: address text you type (and your approximate location, if you allow it) is sent for address suggestions; map tiles are loaded from OpenStreetMap, which therefore receives your IP address.
- Link previews: when you add a link to a plan, our server fetches that page to read its title and image.
- Voice calls are sent directly between the devices where possible, or through relay servers that only forward encrypted media.
Some of these providers process data outside the EU/EEA, in particular in the USA. Where this happens we rely on the EU Standard Contractual Clauses or an adequacy decision.
6. Retention and deletion
We keep your data while your account exists. You can delete your account in the app (Settings → Delete account). This deletes your personal data (profile, sign-in identifier, devices, your game answers and your profile photo). Content created together (events, plans, photos, messages) stays for your partner, shown as written by a “Former member”. Backups may keep deleted data for a limited time before they expire. Security and abuse-prevention records are kept only as long as needed. If you leave a couple, your partner keeps the shared history.
7. Your rights
You have the right of access, rectification, erasure, restriction, data portability and objection (Art. 15–21 GDPR), and the right to withdraw consent at any time with effect for the future. Write to privacy@luciamor.life; we answer within one month. You may also lodge a complaint with a data protection supervisory authority, for example the one of your place of residence.
8. Security and access
Data is transmitted encrypted (TLS) and access is restricted by account and couple membership. Content is not end-to-end encrypted: our operators and Google, as hosting provider, can technically access stored data. We access content only where needed to run the service, fix faults or prevent abuse.
9. Age
Luciamor is intended for adults (18+). We do not knowingly process data of minors.
10. Changes
We will update this policy when the app or its processing changes and show the date above. Material changes are announced in the app.