Privacy Policy

Scope of this Privacy Policy

This Privacy Policy applies exclusively to the Lovy mobile application published under the FlowDeer and DeerDigital brands, referred to in this Policy as the “Application”.

This Policy explains:

• what information may be entered into the Application;
• where that information is stored;
• when the operator may receive personal data;
• how long operator-controlled data may be kept;
• what privacy rights may apply.

This Policy does not apply to the main DeerDigital website, other FlowDeer products or independent services provided directly by Google or another third party.

Data controller

The controller responsible for personal data processed directly in connection with the Application is:

Privacy summary

Lovy is designed around local storage and data minimisation.

• The Application does not require registration or a Lovy user account.
• The operator does not maintain a proprietary backend containing users’ relationship information.
• Relationship information is stored locally on the user’s device.
• Information is not automatically synchronised with another device or partner.
• The operator cannot normally view or recover locally stored relationship information.
• The operator may receive information if a person voluntarily sends an email, support request or testing feedback.
• Google may independently process information in connection with Google Play distribution, testing, installation, updates or purchases.

Information stored locally on the device

Depending on the features available in the current version, users may enter or generate relationship information such as:

• first names, nicknames or partner names;
• relationship start dates and anniversaries;
• birthdays and other important dates;
• answers to daily or relationship questions;
• mood check-ins;
• memories, notes and descriptions;
• shared goals or personal goals;
• activity preferences;
• favourites and completed activities;
• Application preferences and settings;
• relationship counters and locally calculated statistics.

This information is stored in the Application’s local storage on the device.

The operator does not normally receive, transmit, view or otherwise access this information.

Locally stored information remains under the control of the person who controls or has access to the device.

Categories of personal data

The following categories may be relevant to use of the Application:

The Application is not designed to collect government identifiers, banking credentials, precise location, contact lists, call history, microphone recordings or biometric data.

Purposes of processing

Where the operator processes personal data directly, it may be used to:

• respond to questions and support requests;
• investigate reported bugs or technical problems;
• analyse voluntary testing feedback;
• improve Application functionality and usability;
• process complaints or consumer requests;
• provide or verify optional paid functionality;
• prevent misuse and protect legal rights;
• comply with accounting, tax, consumer or other legal obligations.

Locally stored relationship information is used by the Application on the device to provide its features. It is not processed on a proprietary Lovy server.

Legal bases for processing

Where the GDPR applies, operator-controlled processing may rely on the following legal bases:

Consent may be withdrawn at any time where processing is based on consent. Withdrawal does not affect processing lawfully carried out before the withdrawal.

No Lovy account or proprietary backend

Lovy does not currently require users to create an account using a name, email address, password or social sign-in.

The operator does not operate a proprietary backend used to store:

• relationship profiles;
• personal answers;
• mood history;
• relationship memories;
• important dates;
• goals or activity history.

The absence of a proprietary account also means that the operator cannot normally restore relationship information after it has been deleted or the device has been lost.

Sharing information with a partner

Lovy does not currently provide automatic account-based synchronisation or automatic transmission of relationship information to a partner’s device.

If users choose to show the Application to another person, share a screenshot, export information or allow another person to use the same device, that sharing is initiated and controlled by the users.

Users should consider whether they have the other person’s permission before entering or sharing information concerning that person.

The operator is not responsible for disclosure caused by:

• sharing an unlocked device;
• taking or sending screenshots;
• using operating-system backup tools;
• granting another person access to local Application data;
• exporting information through a feature controlled by the user.

Testing and voluntary feedback

Lovy is currently undergoing testing.

Testers may voluntarily provide:

• descriptions of errors or unexpected behaviour;
• suggestions and opinions;
• screenshots;
• device model;
• operating-system version;
• Application version;
• steps used to reproduce an error.

Feedback is used to test, troubleshoot and improve Lovy.

Testers should remove or hide private relationship information before sending screenshots or recordings unless that information is strictly necessary to explain the problem.

Do not send intimate, highly sensitive or unnecessary personal information in testing feedback.

Support and email communication

If you contact the operator by email, the operator may receive:

• your email address;
• your name or signature, if provided;
• the content of your message;
• attached screenshots or files;
• technical information you voluntarily include.

This information is used to respond to the message, provide support, investigate a problem or handle a legal or consumer request.

The operator does not use support messages to create advertising profiles.

Google Play and independent Google processing

Lovy may be distributed or tested through Google Play.

Google may independently process information relating to:

• the user’s Google account;
• Application discovery and store activity;
• installation and updates;
• device compatibility;
• platform security and fraud prevention;
• crash or diagnostic information made available through Google services;
• testing programme participation;
• payments and purchase history if paid functionality is introduced.

Google determines the purposes, scope and retention of its independent processing under its own terms, privacy documentation and account settings.

The operator does not control all processing performed directly by Google Play or through the user’s Google account.

Advertising and analytics

The current version of Lovy is not designed to display third-party advertising or use personal relationship information for advertising.

The operator does not use names, dates, moods, answers, notes or memories entered into the Application to create marketing profiles.

No proprietary Lovy analytics backend receives the relationship information stored in the Application.

Google Play may provide the developer with aggregated or technical information relating to distribution, installations, purchases, stability or testing. This does not give the operator access to the relationship content stored locally within Lovy.

Recipients and service providers

Personal data controlled by the operator may be processed by or disclosed to:

• the operator’s email provider when a person sends a message;
• Google in connection with Google Play, testing, distribution or purchases;
• technical providers where reasonably necessary to maintain or secure the Application or website;
• legal, accounting or tax advisers where necessary;
• public authorities where disclosure is required by law.

The operator does not sell personal data.

The operator does not provide locally stored relationship information to advertisers or data brokers.

International data transfers

Google, the email provider or another necessary service provider may process information in a country outside the European Economic Area.

Where European data-protection law applies, international transfers must rely on a legally recognised mechanism, such as:

• an adequacy decision;
• standard contractual clauses;
• another safeguard recognised by applicable law.

The transfer mechanism used by an independent provider is described in that provider’s own privacy documentation.

Data retention

Information is retained according to its location and purpose.

• Relationship information stored locally remains on the device until it is deleted by the user, cleared by the system or removed with the Application.
• Ordinary support messages may be retained for the time needed to respond and for a reasonable follow-up period.
• Testing feedback may be retained while it remains relevant to development, bug tracking or documentation.
• Purchase, complaint, accounting and legal records may be retained for statutory periods or applicable limitation periods.
• Information independently controlled by Google or another provider is retained under that provider’s own rules.

Operator-controlled personal data will be deleted or anonymised when it is no longer necessary and no legal basis for further retention exists.

Deleting locally stored information

Users can generally remove local Lovy information by:

• deleting individual content through the Application, where that option is available;
• resetting the Application through an available in-app function;
• clearing the Application’s storage through the device settings;
• uninstalling the Application.

Clearing storage or uninstalling Lovy may permanently remove locally stored relationship information.

Because the operator does not maintain a proprietary Lovy account or relationship database, the operator normally cannot remotely delete, recover or return information that exists only on the user’s device.

A request concerning support emails or other information held directly by the operator may be sent using the contact details below.

Data-protection rights

Subject to the conditions and exceptions of applicable law, you may have the right to:

• obtain confirmation of whether the operator processes your personal data;
• request access to personal data and receive a copy;
• request correction of inaccurate or incomplete data;
• request deletion of personal data;
• request restriction of processing;
• receive certain information in a portable format where the legal requirements are met;
• object to processing based on legitimate interests;
• withdraw consent where processing is based on consent;
• lodge a complaint with a competent data-protection authority.

In the Czech Republic, the competent supervisory authority is the Office for Personal Data Protection — Úřad pro ochranu osobních údajů.

Because Lovy does not use proprietary user accounts, the operator may be unable to identify a person from relationship information stored only on that person’s device.

The operator may reasonably verify the identity of a requester before disclosing, changing or deleting operator-controlled information.

Security and device protection

Lovy uses local storage to reduce the need to transmit relationship information to a remote server.

However, local storage does not make information immune from unauthorised access.

Users should protect their information by:

• using a device screen lock;
• keeping the operating system updated;
• preventing unauthorised access to the unlocked device;
• considering whether device backups include Application data;
• avoiding unnecessary screenshots of private information;
• installing Lovy only from an authorised source.

No technical system can be guaranteed to be completely secure.

Do not send intimate, confidential or unnecessary personal information through an ordinary support email.

Privacy of younger users

Lovy is designed as a relationship and lifestyle application and is not intended to encourage children to disclose personal information to the operator.

The Application does not require a Lovy account, public profile, chat or public sharing function.

A user who is not legally able to accept the Application’s Terms independently should use Lovy only with the knowledge and permission of a parent or legal guardian.

If a parent or legal guardian believes that a younger user has directly sent personal information to the operator without appropriate permission, they may contact the operator and request that the situation be reviewed.

Changes to this Privacy Policy

This Policy may be updated if:

• Lovy’s features change;
• an account or backend is introduced;
• cloud backup or partner synchronisation is introduced;
• advertising or analytics tools are added;
• paid functionality is introduced;
• service providers change;
• legal or platform requirements change.

The current version will be published on this page together with its effective date.

Where a change materially affects privacy, users may also be informed through the Application, its store listing or another appropriate channel.