Lovements Privacy Policy
Version 1.5 · Effective date: August 28, 2026
1. Who we are and how to contact us
Lovements is a private family app that lets parents keep a closed album of their child's photos, videos, and milestones and share it only with the relatives they personally invite.
For privacy questions, to exercise your rights, or for requests regarding personal data, write to: [email protected]. For technical questions — [email protected].
The terms "we", "us", and "Lovements" mean the operator of the Service — the data controller identified in the "Data Controller" section. "You" means a user of the app (an adult). "Service" means the Lovements app, the website lovements.app, and the my.lovements.app application.
2. Who uses the Service and whose data we process
The Service is intended exclusively for adults (18+). Only adults may register and use the app.
Children are not users of the Service and do not register themselves. A child is a data subject whose photos, videos, and details (name/nickname and, if the parent chooses, sex and date of birth) are uploaded and controlled by the child's parent or legal guardian (the "album administrator"). The legal basis for processing a child's data is the consent of the child's parent/legal guardian, given at registration and when uploading content (see Section 9 — Children's data).
3. What data we process
3.1. Data you provide to us:
- Account: nickname, email address, password (stored only as a cryptographic hash — we never see your password in plain text), and your role in each album (administrator / viewer).
- Child data: nickname; optionally, sex and date of birth. These fields are not required for the Service to work.
- Content: photos and videos you upload, captions and milestones, and reactions (likes).
- Correspondence: the content of messages when you write to us at [email protected] or [email protected].
3.2. Payment and subscription data:
What we receive depends on where you bought the subscription. In both cases we receive only what is needed to manage your subscription and your access to the Service, and in neither case do we receive or store your full payment-card details.
If you bought on the web, payments are handled by Armitage Labs OÜ, trading as Creem, our Merchant of Record. At checkout, Creem may collect your name, email address, billing address, payment details, and order details under its Privacy Policy. We receive your Creem customer or transaction identifier, selected plan, subscription and payment status, and billing period.
If you bought in the iOS or Android app, the purchase is made through Apple (App Store) or Google (Google Play), which collect and hold the payment data under their own policies. We use RevenueCat as our processor to read the resulting subscription state from the stores. For that purpose we generate a random identifier for your account that is not derived from your name, email, or any other personal detail, and we send it to RevenueCat as the account reference. From RevenueCat we receive, against that identifier: which store the purchase was made in, the purchased product and plan, the subscription status and its dates (period end, any grace period, whether renewal has been turned off, whether the store reported a billing problem, whether the purchase was refunded or paused), and whether the purchase was made in the store's test environment. We do not send your name or email address to RevenueCat, and we do not receive your Apple ID, Google account, or store account identity from anyone.
3.3. Data collected automatically:
- Technical data: IP address, device and browser type (user-agent), Service usage logs, and error logs (for security and diagnostics). Error logs do not include the content of your requests or photos.
- Analytics: de-identified usage statistics via a third-party analytics service (see Section 7). We do not send any personal identifiers to analytics — event parameters are limited to a technical allowlist without names, emails, or album content.
3.4. Data we deliberately do NOT collect: full payment-card details (they are processed by Creem, Apple, or Google), your Apple ID or Google account identity, data from your contacts, precise geolocation, advertising profiles.
4. Why we process data and legal bases (GDPR Art. 6, 9)
| Purpose | Legal basis (GDPR) |
|---|---|
| Creating and running your account; providing the Service | Performance of a contract (Art. 6(1)(b)) |
| Managing the free trial, subscription, billing status, and paid access | Performance of a contract (Art. 6(1)(b)); compliance with legal obligations for required financial records (Art. 6(1)(c)) |
| Storing and showing a child's photos/videos to invited relatives | Consent of the parent/guardian (Art. 6(1)(a); Art. 9(2)(a), as a child's photos may contain sensitive information) |
| Sending transactional emails (password reset, invitations) | Performance of a contract / legitimate interest (Art. 6(1)(b), 6(1)(f)) |
| Security, abuse prevention, error diagnostics | Legitimate interest (Art. 6(1)(f)) |
| De-identified usage analytics | Consent for non-essential cookies (Art. 6(1)(a)) |
| Complying with legal obligations (authority requests) | Legal obligation (Art. 6(1)(c)) |
You may withdraw consent at any time (Section 10). Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.
5. Who can access data and to whom we disclose it
Your album is private. Only you and the people you (or a co-administrator) personally invited to a given album can see the photos, videos, and moments. The number of album members may be limited; we may set or change such limits.
We do not sell your data and do not share it for advertising. Under U.S. laws (including the CCPA/CPRA), we do not "sell" or "share" personal data.
To operate the Service we engage a limited set of processors and service providers (infrastructure providers — hosting, media storage, email delivery, analytics), each under a contract and only to the extent needed to provide the Service. The current list is provided in a separate "Processors and Subprocessors" document (subprocessors.md) so we can keep it up to date without changing this Policy.
For payments we work with different parties depending on where you bought the subscription. For buyer, store-account, and payment data that they determine how to process under their own policies, the relevant payment or store platform acts as an independent data controller, not as our processor.
- Web purchases: Creem acts as our Merchant of Record. Creem handles checkout, payment processing, invoicing, tax administration, refunds, and chargebacks under its own Privacy Policy.
- In-app purchases: Apple (App Store) or Google (Google Play) bills the transaction and collects and processes payment and store-account data under Apple's Privacy Policy and Google's Privacy Policy respectively, and independently determines how to process that data. Its commercial role as seller, Merchant of Record, agent, or marketplace service provider depends on the storefront, territory, and applicable platform terms. We have no access to your store account.
In every case we exchange only the data needed to complete the purchase and manage your subscription and paid access. RevenueCat, which reads store subscription state for us, is different: it is our processor, acts on our instructions, and is listed in the "Processors and Subprocessors" document.
We may also disclose data to law-enforcement/government authorities where required by law and pursuant to a valid legal request.
6. Artificial intelligence
We do not use users' photos, videos, or other content to train artificial-intelligence models, nor do we share it with third parties for that purpose.
7. Cookies and similar technologies
We use:
- Essential: a session cookie to keep you signed in and a first-party preference cookie that remembers your analytics choice across lovements.app and my.lovements.app. The Service does not work without the session cookie; no consent is required for these essential cookies.
- Analytics: We use Google Consent Mode. Before consent, analytics requests may be sent without analytics cookies or persistent identifiers. Analytics cookies are created only after your consent. Local development and the staging environment do not collect analytics.
The iOS and Android apps use an embedded web view for their interface, but the native build does not use browser cookies for sign-in or analytics. Your sign-in session is kept in the device's secure storage instead, and analytics is disabled in the native build.
You can change or withdraw your analytics choice at any time through the Analytics settings link in the website footer or in the web app profile. When you withdraw consent, we set analytics storage to denied and remove available first-party Google Analytics cookies from the Lovements domain. You can also manage cookies in your browser settings. Disabling essential cookies will make the Service unusable.
8. International data transfers
Core data (the app and database) is stored within the EU. Certain processors and service providers (in particular the analytics service and, for store purchases, RevenueCat) may process technical data in the United States and other countries. For transfers to our processors, we rely on appropriate safeguards (EU Standard Contractual Clauses — SCCs — and/or adequacy decisions where applicable). Apple and Google process purchase data internationally as independent controllers and are responsible for their own transfer safeguards under their policies and applicable law. You can request details of the safeguards we apply: [email protected].
9. Children's data
The Service is not intended for use by children and does not collect data directly from children. A child's data is provided by their parent/legal guardian acting as the album administrator.
United States (COPPA). Because the Service uploads and stores personal data of children under 13 provided by parents, we:
- obtain the parent's/guardian's consent before processing a child's data;
- process the minimum necessary amount of a child's data;
- do not condition a child's participation on providing more data than necessary;
- upon a parent's request, provide access to the child's data, stop its further use, or delete it.
EU (GDPR Art. 8). The minimum digital-consent age in EU member states is 13 to 16 depending on the country. Because consent is given by the parent/guardian rather than the child, this processing is based on parental consent.
If you believe we are processing a child's data without proper consent, write to [email protected] — we will promptly delete such data.
10. Your rights
For all users you can: obtain a copy of your data, correct inaccurate data, delete your account, and contact us with any privacy question — [email protected]. Many of these actions are available directly in the app (editing your profile, deleting your account).
EEA / United Kingdom residents (GDPR / UK GDPR). You have the right to: access, rectification, erasure ("right to be forgotten"), restriction of processing, objection to processing, data portability (export), withdrawal of consent, and the right to lodge a complaint with a data-protection supervisory authority (in your EU country or the ICO in the UK).
California residents (CCPA/CPRA). You have the right to: know which categories of data we collect and why; obtain a copy; request deletion; correct inaccurate data; limit the use of sensitive data. We do not sell or share personal data, so a separate "opt-out of sale" mechanism does not apply. We will not discriminate against you for exercising these rights.
Ukraine residents have rights under the Law of Ukraine "On Personal Data Protection," including access to, amendment of, and deletion of their data, and the right to appeal to the Ukrainian Parliament Commissioner for Human Rights.
We respond to requests within the timeframes set by applicable law (generally up to 30 days). We may ask you to verify your identity before fulfilling a request.
11. How long we keep data
- Active account: we keep your data for as long as your account exists.
- Account deletion (at your request / via the in-app button): data is removed from active systems without delay, and from backups within their rotation cycle, after which it is gone permanently. See the "Account and Data Deletion" page for details.
- Subscription end: if your subscription ends, your content will be retained for a limited grace period to allow you to reactivate your subscription or export your data. After this grace period, your content may be permanently deleted.
- Individual deleted photos/videos: removed from active storage shortly afterward, and from backups within the rotation cycle.
- Legal exceptions: we may keep certain data longer where required by law (e.g., to resolve disputes or comply with legal obligations).
Once data has been permanently deleted, it cannot be restored.
12. How we protect data
We apply modern technical and organizational measures to protect personal data, including encryption of data in transit, storing passwords only in hashed form, regular backups, and restricting access to the people you invited. A brief overview is on the "Security" page.
No system is completely secure; we cannot guarantee absolute security, but we make reasonable efforts in line with current practices.
13. Security incidents
If a security incident occurs that may affect your personal data, we will notify the affected users and the competent authorities in the cases and within the timeframes required by applicable law.
14. Changes to this Policy
We may update this Policy. We will notify you of material changes in the app and/or by email. The effective date of the current version is shown at the top. Continuing to use the Service after changes take effect means you have reviewed them.
15. Data Controller
The data controller for the processing described in this Policy is:
Sole Proprietor (FOP) Kostiantyn Ivanov Ukraine Email: [email protected]
16. Contact
Questions, rights requests, complaints: [email protected].