LUNYRAQ
1. Controller and scope
Romilson Alves is the controller for LUNYRAQ data, with the service managed from Luxembourg. Contact: alvescommerce@gmail.com; address: see the Legal notice, still to be completed. This policy covers website visitors, app users and business representatives. The GDPR and applicable Cabo Verde rules govern processing; testing or free access does not remove these duties.
2. Data you provide
Account: email, username, password hash, birth date, profile, photo, biography, preferences and terms-acceptance records. Participation: text, photos, video, audio, Drop locations and conditions, reactions, connection requests, conversations, participation and challenge evidence. Businesses: name, category, venue, contact information and information or documents needed for verification when requested. Support: requests, reports, appeals and correspondence.
3. Location and technical data
The app may process precise coordinates, signal accuracy, recent positions, distance to discoveries, proximity events and a home zone you choose to save. These support discovery, proximity checks and location protections. Some published points remain visible to others; hiding your presence does not erase an already published Drop location.
IP address, request timestamps, app version, operating system, technical identifiers, notification token and error and security logs may be processed. The app also records internal usage events, such as opening the map, discovering and posting, to assess operation and improve the product. These metrics are not necessarily anonymous.
4. Purposes and legal bases
Providing the requested service — contract performance: creating and authenticating accounts, posting and revealing content, enabling connections and conversations, and managing business profiles. Security and moderation — legitimate interests in preventing abuse, protecting people and maintaining the service, balanced against your rights; a legal obligation where a specific duty exists. Support and rights requests — contract administration or legal obligations depending on the request.
Optional location, sensor access and permission-based features are explained in context. Android permission alone does not replace informed consent where legally required. Necessary and proportionate internal metrics may rely on the legitimate interest in improving the service; optional tracking or analytics requiring consent must only operate after a valid choice. Accepting the terms is not advertising consent.
5. Required data and choices
Information marked as required during registration creates and protects your account and checks your declared age; registration cannot be completed without it. Optional profile details, home zone, media and notifications depend on your choices. You can withdraw permissions in phone settings, which may limit proximity discovery, media capture or alerts. Withdrawing consent does not affect earlier lawful processing.
6. Visibility and conversations
Profiles and posts are displayed according to the app’s options and access rules. We do not guarantee anonymity or prevent all copying. Conversations are private between participants but must not be treated as end-to-end encrypted. They are not automatically submitted to OpenAI moderation message by message. A report may lead to human review of the message and limited context and, if that safety option is enabled, classification by OpenAI.
7. Providers and recipients
Hetzner: server, database and file hosting according to the contracted services. Brevo: transactional emails, such as account recovery, using email address, message content and delivery status. Google/Firebase Cloud Messaging: notification delivery using installation/device tokens, technical information and notification content. Google/Gmail: receiving and managing emails sent to the support contact.
OpenAI: classifying text and images submitted for post moderation, potentially including reported private content under the conditions above. This does not mean sending the entire account or all conversations. Map providers receive map requests and technical information that may reveal the area viewed. The actual provider depends on the installed configuration: [CONFIRM MAP PROVIDER AND PROCESSING REGIONS].
Sentry is only being considered and is not presented as active in this version. If enabled, this policy must identify diagnostic data, configuration, recipients, retention and legal basis before collection. Firebase Analytics and Crashlytics were not identified in the reviewed dependencies; Firebase is described here for notifications, not advertising.
Authorised support and moderation staff, other users according to visibility choices, and authorities where required by law may also access data. We do not sell personal data. A business post does not grant access to every user’s private location or conversations.
8. International processing
Data from users in Cabo Verde is processed through infrastructure and providers outside Cabo Verde. Some services may involve processing outside the European Economic Area. We do not claim all data stays in Luxembourg or the EU. [BEFORE PUBLICATION: identify actual countries/regions, contracting entities, applicable safeguards and any Cabo Verde CNPD formalities or authorisations].
Where the GDPR requires transfer safeguards, these must rely on a valid mechanism, such as an applicable adequacy decision or standard contractual clauses with necessary assessments and measures. Using a well-known provider does not itself prove these requirements are met. You may request information and copies of relevant safeguards through the privacy contact, with justified redaction of confidential information.
9. Retention and deletion
Account and profile: while providing the service and until deletion, with limited justified exceptions for legal duties or disputes. Content and conversations: according to duration and deletion options and actual service needs. Expiring or disappearing from the map does not immediately erase the record, text, files or every copy.
The reviewed maintenance configuration schedules cleanup of recent position records older than 2 hours and proximity events older than 14 days. Read or deletion-marked notifications are cleaned after 120 days; unread notifications are not covered by that rule. These periodic tasks depend on running jobs and do not automatically cover backups or all location tables.
After 72 hours from expiry, Drops covered by the task are marked removed and their files are queued for cleanup. The post record and text are not necessarily erased by this task. [CONFIRM RETENTION AND PURGING OF THESE RECORDS]. Account deletion starts deletion of the account and dependent relationships in the main database and queues service-controlled files for cleanup.
Backups, access/error logs, metrics, support emails and moderation evidence need separate retention periods. [OPERATIONAL PERIODS TO CONFIRM BEFORE PUBLICATION]. They must only be kept as needed for technical recovery, security, resolving a request or a specific obligation; any dispute-related hold must be limited to that case and reviewed. This text promises neither complete erasure within 72 hours nor unlimited retention.
10. Rights and response times
You may request access, correction, erasure, restriction and portability, object to legitimate-interest processing or withdraw consent where applicable. Email alvescommerce@gmail.com. We verify identity proportionately without asking for your password. Requests are free unless a justified legal exception applies. For GDPR requests, we respond without undue delay, normally within one month; any lawful extension of up to two further months requires notice and reasons within the first month.
You can complain to Luxembourg’s CNPD (cnpd.public.lu), Cabo Verde’s CNPD (cnpd.cv) or another competent authority. Our permission or completion of an internal request is not required.
11. Recommendations, moderation and security
Suggestions may consider your selected vibe, distance, availability and interactions. Automated moderation may reject or limit a post; you can request human review through the appeal process. We do not present these systems as infallible or exclude applicable rights concerning automated decisions with legal or similarly significant effects.
We apply access controls and technical measures appropriate to the risk without promising absolute security. Do not send health information, identity documents or sensitive data in public posts or unsolicited support messages. Any necessary collection of special-category data requires its own legal condition; blanket acceptance of this policy does not authorise it.
12. Children, website and updates
The service is 18+. If we learn that an account belongs to a minor, we restrict access and address deletion, keeping only what a specific obligation requires. See the Child safety policy. Website language storage is explained on the Cookies and local storage page. Significant changes will be communicated, with renewed consent where required.