Privacy Policy

As of 19 September 2026

In short: we process the data needed to run your account, profile, the radar of people and plans nearby, chats, events and attendance confirmation. We do not sell personal data or location data, and we do not share it with data brokers or advertisers. Your exact position is never shown to other users — only an approximate distance.

1. Data controller

The controller of your personal data is Lupi Sp. z o.o., ul. T. Kościuszki 11 lok. 12, 05-825 Grodzisk Mazowiecki, Poland, registered under KRS 0001258266, NIP 5291870782, REGON 545413929. Contact for data protection matters: team@ludivaro.com.

2. What data we process

  • Account: e-mail address, password (stored only as a cryptographic hash), date of birth; if you sign in with Apple or Google — your account identifier at that provider.
  • Profile: name, photos, description, city, interests and traits you provide.
  • Location: the last known position of your device and the previous point (used to detect implausible jumps). We do not keep a location history and we do not keep the coordinates used for attendance confirmations.
  • Activity: plans and events, participation and attendance confirmations, messages and photos in chats, Sparks, experience points and character level, reports and blocks.
  • Technical data: IP address and device information at sign-in, push notification tokens, error logs, bug reports together with a screenshot.
  • Shared-cost settlement: a BLIK phone number or bank account number, if the plan organiser provides one — visible only to the participants of that plan.

3. Purposes and legal bases

  • Account and app functionality — profile, radar of people and plans nearby, plans, chats, attendance confirmation, notifications: Art. 6(1)(b) GDPR (performance of a contract).
  • Security, abuse prevention, content moderation, handling reports: Art. 6(1)(f) GDPR (legitimate interest) and Art. 6(1)(c) GDPR (legal obligations, including the Digital Services Act).
  • Background location for automatic attendance confirmation: Art. 6(1)(a) GDPR (your consent, which you may withdraw at any time). The operating-system permission is a separate technical condition for this feature, not a legal basis; revoking it in your phone settings turns automatic attendance confirmation off.
  • Traits or preferences that may reveal special categories of data (e.g. beliefs, orientation) and their use for matching: Art. 9(2)(a) GDPR (explicit consent, which you can withdraw in the app at any time).

Providing data is voluntary, but without an e-mail address, date of birth and location some features cannot be provided.

4. Location, including background location

Location is used for proximity-based features (radar of people, plans and events nearby, place search) and to confirm attendance at a meet-up or event.

Other users are shown only an approximate distance — never your exact position. We store the last known position and the previous point; we do not build a movement history. Coordinates used to confirm attendance serve that check only and are not stored — we record the fact of attendance itself.

Background location is used only if you switch on automatic attendance confirmation for an event, and only so that the app can confirm your presence at the event venue while it is closed or running in the background. The app asks for this consent separately, after explaining the purpose, and does not use background location for any other purpose — in particular not for advertising, commercial profiling or selling data. You can withdraw the consent in your phone settings at any time; automatic attendance confirmation then stops working, while the rest of the app continues to function.

We do not sell location data and do not share it with data brokers or advertisers.

5. Automated photo screening

Photos you upload — including those sent in chats — are automatically screened before storage by an artificial-intelligence system for nudity, graphic violence and hate symbols. A photo found to be disallowed is not published. The text of private messages is not analysed by artificial intelligence. If you believe a photo was rejected unfairly, write to the address in section 1.

6. Who we share data with

  • Other users — whatever your profile and the app's features display; distance is always approximate, never an exact position.
  • Service providers processing data on our behalf:
    • Hetzner (Germany) — servers and database;
    • Cloudflare — network traffic intermediation;
    • Resend (USA) — e-mail delivery (account verification, password reset);
    • Expo (USA) — push notification delivery;
    • Anthropic (USA) — automated photo screening and plan suggestions based on the interests you enter;
    • Apple and Google — if you sign in with their account; Google — maps in the Android app;
    • Photon / OpenStreetMap — address and place search based on the location you indicate.
  • Public authorities — where required by law.

We do not sell data and do not pass it to advertisers.

7. Transfers outside the EEA

Transfers outside the European Economic Area take place with the safeguards required by the GDPR — an adequacy decision of the European Commission or standard contractual clauses.

8. How long we keep data

  • Account data and content — until the account is deleted. Deletion is immediate and also covers your messages in conversations with other people.
  • Plans — up to 30 days after they end. Exception: a plan for which a Memory was created is kept for as long as that Memory exists.
  • Which plans we suggested to you, where, why and whether you opened them — without content and without coordinates — stays linked to you for 35 days; after that only aggregate counters remain, with no user identifier and no plan identifier. Deleting your account removes this link immediately, not after 35 days.
  • Event participation and attendance confirmations (the fact of attendance, without coordinates) — until the account or the event is deleted; they have no separate, shorter period.
  • Sign-in logs (including the IP address), the record of moderation decisions, notifications — 90 days; error logs — 30 days.
  • Screenshots from bug reports — up to 30 days after the report is closed.
  • Database backups — no longer than 30 days.
  • Data needed to defend claims or required by law — for the period arising from the applicable provisions.

9. Security

We apply technical and organisational measures appropriate to the nature of the data, including encrypted connections, access control, storing passwords only as cryptographic hashes and anti-abuse mechanisms. No system, however, offers an absolute guarantee of security.

10. Your rights

You have the right to access your data, to rectify it, to erase it, to restrict processing, to data portability and to object to processing based on legitimate interest. You may withdraw consent at any time, without affecting the lawfulness of processing carried out beforehand. You can delete your account in the app (Settings → Delete account) or via ludivaro.com/en/delete-account/; other rights can be exercised by writing to the address in section 1. You may also lodge a complaint with the President of the Personal Data Protection Office in Poland (ul. Stawki 2, 00-193 Warsaw).

11. Account and data deletion

You delete your account yourself in the app: Settings → Delete account. If you no longer have access to the app, you can submit a request via ludivaro.com/en/delete-account/. Section 8 describes what is deleted.

12. Age of users

The app is intended solely for adults (18+). We do not direct the service at children and do not knowingly collect data of people under 18.

13. Changes to this policy

This policy may be updated as features, the law or our processing practices change. The date of the current version is shown at the top of the page.

14. Contact

Privacy questions: team@ludivaro.com.