Privacy Policy

Who is collecting your data

Luvvy is operated by Couples Lab B.V., registered in the Netherlands, which acts as the data controller and decides what personal data is collected and how it is used.

Our services may contain links to expert sites and social platforms that have their own privacy policies. Couples Lab accepts no responsibility for the privacy practices of those third parties.

How we collect and use your personal data

Depending on how you use Luvvy, we may collect: identity information (such as your name, user code, device ID and email); activity information (such as your in-app responses, pairing details, course completion and any photos or videos you add); demographic information (such as age, gender and preferences, including sensitive data where you have given consent); and usage information (such as survey responses, time spent in the app, IP address and device ID).

We also collect support information (contact and device details when you reach out), subscription and registration information, marketing information (such as the email address you give us for offers and promotions), and technology information (such as cookies, pixels and device identifiers).

Anonymised activity and demographic data may be shared with academic partners for relationship research.

Our lawful bases for the use of your personal data

We rely on three primary lawful bases to process your personal data: the performance of our contractual obligations to you; our legitimate business interests in developing our product and improving the customer experience; and your explicit consent, in particular for any sensitive information.

Information sharing you control

You control the data you share with your partner through the app's pairing functionality. When you are paired, your shared conversations remain visible until you end the pairing or delete your account.

Sharing personal data with service providers and other organisations

We work with service providers for technology, payment processing, data storage, analytics and support, and share only the data necessary for them to perform those functions on our behalf.

We may also disclose personal data where legally required, to establish or defend legal rights, or in connection with a business transfer.

Sharing with our academic partners

We share anonymised user data with academic institutions to advance the scientific understanding of how our service affects relationships, including through published research.

How we protect your information and where we store it

Luvvy has physical, electronic and procedural safeguards that comply with applicable regulations to protect your personal information. Employee access is limited to those who need it to deliver the service.

No transmission of data over the internet can be guaranteed to be 100% secure. Your data may be stored outside the EEA or the UK, in which case we put adequate contractual protections in place.

How long we use personal data for

We consider the purpose for which the data was collected, its age, any legal requirements and whether it is needed to protect our users or the service. We retain personal data for as long as necessary to comply with legal obligations, resolve disputes and enforce our agreements.

Your data protection rights — UK and EEA residents

If you are in the UK or EEA, the GDPR gives you the right to access the personal data we hold about you, to have inaccurate data corrected, to object to or restrict our processing, and to have your data deleted.

You also have the right to lodge a complaint with your data protection regulator (for example, the ICO in the UK at ico.org.uk, or the Autoriteit Persoonsgegevens in the Netherlands).

Children’s data

Luvvy does not knowingly collect personal data from children under the age of 18. Those under 18 should not submit personal information without the permission of a parent or guardian. If we become aware that we have collected a child's data, we delete it promptly.

International privacy laws

This policy complements the data protection laws that apply to you. Where those laws impose stronger requirements, they take precedence over this policy.

Advertising

Third-party advertising networks may use cookies and web beacons to deliver targeted advertising. You can opt out through the Network Advertising Initiative and the Digital Advertising Alliance. Opting out prevents targeted ads but not generic advertising.

U.S. state data privacy

Residents of California, Colorado, Connecticut, Utah and Virginia have state-specific rights, including the right to access, correct, delete and port their data, and to opt out of targeted advertising and data sales. We do not sell personal data for money, and we do not knowingly sell or share the data of California residents under the age of 16.

How to contact us

If you have any questions about this policy or wish to exercise your rights, contact us at contact@couples-lab.com.