Privacy Policy — LifeCouple
Version app-1.0 — last updated 9 September 2026. Provided under Articles 13–14 of Regulation (EU) 2016/679 (GDPR).
1. Who is responsible for your data
F.R. di Busato Fausto, owner Fausto Busato, Novellara (RE), Italy — VAT no. 01878620358, REA RE 232527.
- Contact, support and exercising your rights: info@heleox.it
- Certified email (PEC): fr-busato@pec.fr-busato.it
No Data Protection Officer has been appointed. The service does not involve systematic large-scale monitoring, but it does handle data that is particularly sensitive when combined; this assessment is kept under review.
2. What this app does, in one line
LifeCouple is the private diary of two people: a shared calendar, places, photographs, lists and games between the two members of a couple. The unit of the service is the couple, not the individual — and that has consequences for your data, described in section 6.
3. What data we process, why, and on what legal basis
| Data | Purpose | Legal basis | Retention |
|---|---|---|---|
| Account: email address, user identifier | Creating and managing your account, access to the service | Performance of the contract (Art. 6.1.b) | For as long as the account exists |
| Couple link: the association between two accounts, start date and any end date | Providing a service that exists only between two people | Performance of the contract (Art. 6.1.b) | For as long as the account exists |
| Photographs uploaded by users | Keeping shared memories | Performance of the contract (Art. 6.1.b) | For as long as the account exists |
| Places entered manually (wished for and visited), with an optional date | Shared map and lists | Performance of the contract (Art. 6.1.b) | For as long as the account exists |
| Calendar events created in the app | Shared calendar | Performance of the contract (Art. 6.1.b) | For as long as the account exists |
| List entries (films, trips, restaurants and lists you create), with ratings and reviews | Shared lists | Performance of the contract (Art. 6.1.b) | For as long as the account exists |
| Answers to the affinity games | Game mechanics and the couple's score | Performance of the contract (Art. 6.1.b) | For as long as the account exists |
| Subscription data (status, expiry) | Providing paid features | Performance of the contract (Art. 6.1.b) | For as long as the account exists |
| Accounting and tax data relating to purchases | Legal obligations | Legal obligation (Art. 6.1.c) | 10 years |
| Date of birth | Two things at once: showing your birthday on the calendar you share with your partner, and checking that you meet the minimum age for the service | Performance of the contract (Art. 6.1.b) for the birthday; legal obligation (Art. 6.1.c, in relation to Art. 8 GDPR) for the age check | For as long as the account exists |
| Current location, if you choose to share it with your partner | Letting you see where each other are, and the distance between you | Consent (Art. 6.1.a) | Only the current value: each update replaces the previous one and no history is kept. It disappears when you turn sharing off, or when the couple is dissolved |
Providing an email address is required: without it an account cannot be created.
3.1 Data the app reads from your device but does not collect
This section exists because the difference is a real one, and it should be stated rather than hidden.
| What actually happens | |
|---|---|
| Location (while sharing is off) | It is read once, when you open the map, and only if you have already granted permission, for the sole purpose of centring the map where you are. It is not recorded, not transmitted to us, does not leave your phone and is not visible to your partner. If you turn on location sharing, this no longer applies: your location is then transmitted and shown to your partner — see section 6. In neither case is there any background tracking or automatic history. |
| Device calendar | Read only when you choose to import, and only the entries you tick are imported. |
| Device photographs | Accessible only for the images you choose to add. |
How location sharing works, exactly:
- Sharing is yours and only you can turn it on, from the map. It is not reciprocal: you can see your partner without being seen, and the other way round.
- You can turn it off whenever you want, with one tap, from the same screen. When you turn it off your partner receives no notification: for them the result is identical to a flat battery, a closed app or a disabled GPS. Nowhere in the system is there any information saying that you stopped sharing — and that is a design decision, not an oversight.
- We keep no history of your movements. There is a single location per person, the current one, and each update replaces the previous one. Neither we nor your partner can reconstruct where you have been.
- A location older than fifteen minutes is not shown, because it would no longer say where you are.
- If you dissolve the couple, locations are deleted, not hidden.
3.2 Text you write freely
Some features let you write free text (reviews, notes, and — when the feature becomes available — custom questions for the games).
We never ask you for special category data under Article 9 GDPR (health, sex life, religious or political beliefs), and the built-in game questions are filtered to exclude them. If you choose to write such information into a free text field, it stays private to your couple: we do not reuse it, do not suggest it to others, do not aggregate it and do not analyse its content.
Menstrual cycle tracking is not present in this version of the app, and no health data is processed.
4. Who we share data with
Data is never sold or traded. It is processed by suppliers appointed as processors under Article 28 GDPR:
| Supplier | What it receives | Location |
|---|---|---|
| Supabase | Accounts, content, photographs — the entire database | Region eu-central-1 (Frankfurt, Germany) — European Union |
| Google (Places) | The text of place searches, and the places you select | United States — see section 5 |
| TMDB (The Movie Database) | The text of film searches | United States — see section 5 |
| Apple and Google | Data relating to purchases and subscriptions | See section 5 |
We do not use behavioural analytics, advertising or profiling tools, neither third-party nor our own.
Data may be disclosed to competent authorities where required by law.
5. Transfers outside the European Union
The database and the photographs reside in the European Union (Frankfurt, Germany). They do not leave the European Economic Area.
The only services that transfer data to the United States are the place and film search services, and they receive only the text you type into the search box — not your content, not your photographs, not your account. The transfer is based on standard contractual clauses approved by the European Commission, or on equivalent mechanisms such as adherence to the Data Privacy Framework where applicable.
A copy of the safeguards adopted can be requested at the contact address in section 1.
6. The couple: what your partner sees, and what happens if you break up
This section describes the most important aspect of the service, and it is written to be read before you start.
While you are a couple, your partner sees the shared content: calendar, places, photographs, lists, game results, and your date of birth, which appears as a birthday on the calendar you share. They cannot read your answers to a game before you have both answered.
Your current location is the only thing that depends on an action of yours: your partner sees it only if you turn sharing on, and it stays off until you do. The exact conditions — no history, a fifteen-minute expiry, no notification when you switch it off — are described in section 3.1, and should be read before you turn it on.
Each of you remains the author of what you uploaded: only the person who added something can change or delete it. Your partner cannot delete your photographs or your content.
If the couple is dissolved, mutual access is revoked: neither of you will be able to see the other's content any more. Dissolving the couple does not delete data — each of you keeps what you authored, and shared content follows the rules shown in the app at the moment of dissolution. Both of you are notified.
Dissolving the couple is not enough to delete your data: you must delete your account (section 7). They are two different actions with different consequences.
7. Deleting your account
You can delete your account directly from the app, in Settings.
Deletion is immediate and permanent, and covers — in this order — your stored photographs, all content you authored, and finally your account. There is no cooling-off period: once you confirm, the data is deleted.
Deleting your account does not cancel your subscription. Subscriptions are managed by Apple and Google, not by us: they must be cancelled from your phone's settings, otherwise renewal continues even though the account no longer exists.
Accounting and tax data relating to purchases is an exception, kept for 10 years as required by law.
A limit worth stating plainly: the service hosting the database keeps continuity copies so that data can be restored after an incident. Deleted data may persist in those copies for a limited period set by our hosting provider's backup policy, after which it disappears permanently. Those copies are not accessible in day-to-day operation.
8. How long we keep your data
For as long as the relationship lasts, that is, for as long as your account exists. There is no automatic deletion for inactivity: your memories stay for as long as you want them to, and disappear when you delete your account.
9. Security
Technical and organisational measures are in place under Article 32 GDPR, including: encryption of data in transit and at rest; row-level data isolation (each couple can reach only its own data); access to photographs through temporary, unguessable links rather than public files; least privilege, with a single server function holding elevated rights and limited to account deletion alone; a log of state-changing actions; and a documented threat analysis that is reviewed periodically.
One limit it is only honest to state: no technical measure protects against someone who knows your credentials or uses your unlocked phone. Protect your device with a screen lock.
10. Your rights
Under Articles 15–22 GDPR you have the right to obtain access to your data, rectification, erasure, restriction of processing, portability, and to object to processing based on legitimate interest.
Erasure and portability are available directly in the app, in Settings, without having to write to us.
For the other rights, write to the contact address in section 1: we reply within 30 days.
You have the right to lodge a complaint with the Italian Data Protection Authority (www.garanteprivacy.it) or with the supervisory authority of the country where you live.
10-bis. If the service were to close
If LifeCouple were one day to stop being offered, you would receive at least 60 days' advance notice inside the app and at your account's email address, with a definite date. The closing date is never earlier than the end of a subscription period you have already paid for.
Before that date you would be able to export your data from the app, a feature already available today in Settings. On closure, data is deleted in accordance with section 7, with the sole exception of the accounting and tax data the law requires us to keep.
Subscriptions in progress are managed by Apple and Google: automatic renewal is switched off and the service remains available until the end of the period already paid for.
11. Minimum age
The service is reserved for people who have reached the age of 14, the age set by Italian law under Article 8 GDPR.
Your date of birth is requested at registration, and anyone who turns out to be under 14 cannot create an account. This remains a declaration by the person concerned rather than a documentary check — anyone can enter a false date, and no app of this kind does more — but it is the difference between a rule written down and a rule applied.
12. Changes
Changes to this policy are published with an updated version number and date. Substantial changes are communicated inside the app.