Draft, to be reviewed by a lawyer before publication.

Privacy policy

Last updated: 8 November 2026. The German version is the legally binding one.

1. Controller

Weenja Solution (OPC) Private Limited, [PLATZHALTER: Anschrift]. E-mail: [PLATZHALTER E-MAIL]. More details in the imprint.

2. What we process and why

• Device account: a random account ID and a random device secret (stored securely on your device). We never ask for your e-mail address or phone number.
• Profile: your display name, the confirmation "16 or older", the time of your consent, language and time zone.
• Couple data: your answers, moods, chat under a question, memo, moments with photos, bucket list, anniversaries, your turtledove's state, pebbles and gems.
• Sign in with Apple or Google (optional): only the provider's pseudonymous subject ID, so you can restore your account on a new device. We do not store the e-mail address.
• Push tokens: so we can send you notifications (for example "Your question is here"). You choose which notifications you get in the app.
• Purchases: product, status and expiry of Turtelei Plus and gem purchases. We never see payment details; Apple or Google handle the payment.
• Technical logs: sampled server logs without content (time, endpoint, status code), kept briefly, for debugging and abuse prevention.
• This website: our host Cloudflare processes technically necessary data such as your IP address to deliver the page. We set no cookies and embed no external content.

3. Legal bases

• Art. 6 (1) (b) GDPR: providing the app and your account (contract).
• Art. 9 (2) (a) GDPR: your explicit consent where your answers contain very personal content (for example about health or sex life). You give it in the app and can withdraw it at any time by deleting your account.
• Art. 6 (1) (f) GDPR: security of the service and abuse prevention (legitimate interest).
• Art. 6 (1) (c) GDPR: legal retention duties for purchase records, where they apply.

4. Recipients and processors

• Cloudflare, Inc. (hosting of server, database and photos; D1 database and R2 storage with EU jurisdiction, data at rest stays in the EU; requests are processed at the nearest Cloudflare location).
• Google (Firebase Cloud Messaging for Android notifications, Google Sign-In, Google Play billing).
• Apple (Apple Push Notification service, Sign in with Apple, App Store billing).

We do not sell data and do not pass it on for advertising.

5. Transfers to third countries

Cloudflare, Google and Apple are (also) based in the USA. Where data reaches the USA, we rely on the EU-US Data Privacy Framework, under which these companies are certified, and additionally on the European Commission's standard contractual clauses.

6. Retention

• In general until you delete your account.
• After a couple unpairs: 90 days, so you can reconnect; then the couple data is deleted.
• If your partner deletes their account: the shared data is kept for 30 days for your export, then deleted.
• Exports (ZIP files): 7 days.
• Purchase records without personal reference may be kept longer where the law requires it.

7. Your rights

You have the right of access, rectification, erasure, restriction of processing, data portability (export right in the app: More → Export data), objection to processing based on legitimate interests, and withdrawal of consent with effect for the future. You can also complain to a data protection supervisory authority, for example the one where you live.

How to delete your account: Delete account.

8. No ads, no tracking

Turtelei shows no ads and uses no advertising IDs, no analytics or tracking services and no third-party crash reporting. This website uses no cookies.

9. Minimum age

Turtelei is for people aged 16 and over. We store no birth date, only your confirmation.

10. Changes

When Turtelei changes, we update this policy and announce significant changes in the app.

11. Contact

Privacy questions: [PLATZHALTER E-MAIL]