Privacy Policy

Sincerly ("we," "us," or "our") operates the Sincerly mobile application (the "App") available on the Apple App Store and Google Play Store. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you use the App. By using Sincerly, you agree to the practices described in this policy.

This Privacy Policy is provided in compliance with applicable data protection laws, including the General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), the California Privacy Rights Act (CPRA), and the Apple App Store Guidelines.

1. Data Controller

The data controller responsible for your personal data is:

Booma Studio
Email: support@sincerly.app
Website: https://sincerly.app

2. Information We Collect

2.1 Information You Provide Directly

• Account Information: Email address, display name, and profile photo when you create an account.
• Partner Connection: Invite codes or links used to connect with your partner.
• User-Generated Content: Messages, love letters, photos, time capsule entries, bucket list items, journal entries, and other content you create within the App.
• Support Communications: Information you provide when contacting us for help, including your name, email, and message content.

2.2 Information Collected Automatically

• Device Information: Device model, operating system version, unique device identifiers, and language settings.
• Usage Data: Features used, session duration, and interaction patterns (collected in anonymized or aggregated form).
• Crash Data & Diagnostics: Crash logs, performance data, and error reports to help us identify and fix bugs.

2.3 Information We Do NOT Collect

• We do not collect precise location data.
• We do not collect contacts, call logs, or browsing history.
• We do not collect financial or payment information directly (all purchases are handled by Apple or Google).
• We do not track you across third-party apps or websites for advertising purposes.

3. Apple App Tracking Transparency (ATT)

Sincerly does not track users across other companies' apps or websites for advertising or advertising measurement purposes. We do not participate in ad networks and therefore do not trigger Apple's App Tracking Transparency prompt. We do not use the IDFA (Identifier for Advertisers).

4. How We Use Your Information

We use the information we collect to:

• Provide the Service: Operate the App, enable features, and facilitate communication between you and your partner.
• Improve the App: Analyze aggregated, anonymized usage data to understand which features are most valued and to fix issues.
• Communicate With You: Send service-related notifications (e.g., partner invitations, feature updates, security alerts). We do not send marketing emails without your consent.
• Ensure Security: Detect and prevent fraud, abuse, and security threats.
• Comply With Law: Meet legal obligations and respond to lawful requests from authorities.

5. Data Sharing and Disclosure

We do not sell, rent, or trade your personal data to any third party.

We may share limited data with the following categories of service providers, solely to operate the App:

• Cloud Infrastructure: Hosting and database services to store your data securely.
• Analytics (Anonymized): Aggregated, non-identifiable usage statistics to improve the App.
• Push Notification Services: Apple Push Notification Service (APNs) and Firebase Cloud Messaging (FCM) to deliver notifications.
• Crash Reporting: Services to collect crash logs and diagnostics for stability improvements.

All third-party service providers are bound by data processing agreements and are prohibited from using your data for their own purposes.

6. End-to-End Encryption

All private messages, love letters, and shared content exchanged between you and your partner are protected with end-to-end encryption (E2EE). This means:

• Only you and your partner can read your messages.
• Sincerly cannot access, read, or decrypt your private content.
• Even in the event of a data breach, encrypted content remains unreadable without the decryption keys held only on your devices.

7. Data Retention

• Account Data: Retained for as long as your account is active. When you delete your account, we delete your personal data within 30 days, except where retention is required by law.
• User-Generated Content: Deleted when you delete the specific content or your account, subject to E2EE constraints and backup retention periods.
• Anonymized Analytics: May be retained indefinitely as they cannot be linked back to you.
• Support Communications: Retained for up to 12 months after resolution to assist with follow-up inquiries.

8. Your Rights

Depending on your location, you may have the following rights regarding your personal data:

8.1 All Users

• Access: Request a copy of the personal data we hold about you.
• Correction: Request correction of inaccurate or incomplete data.
• Deletion: Request deletion of your account and all associated personal data. You can initiate this from within the App (Settings > Account > Delete Account) or by emailing us at support@sincerly.app.
• Data Portability: Request your data in a structured, machine-readable format.
• Withdraw Consent: Where processing is based on consent, you may withdraw it at any time.

8.2 European Economic Area (EEA) / UK Residents (GDPR)

• Right to restrict processing of your personal data.
• Right to object to processing based on legitimate interests.
• Right to lodge a complaint with your local data protection authority.
• Legal Basis for Processing: We process your data based on (a) performance of a contract (providing the App), (b) legitimate interests (improving the service, ensuring security), and (c) your consent where required.

8.3 California Residents (CCPA/CPRA)

• Right to know what personal information is collected and how it is used.
• Right to delete personal information.
• Right to opt out of the sale or sharing of personal information. Note: We do not sell or share your personal information.
• Right to non-discrimination for exercising your privacy rights.

9. Account Deletion

In compliance with Apple App Store guidelines, Sincerly provides a straightforward account deletion process:

• In-App: Go to Settings > Account > Delete Account. Follow the confirmation steps.
• Via Email: Send a request to support@sincerly.app with the subject line "Account Deletion Request."
• Via Contact Form: Use the contact form on our website and select "Data Deletion Request."

Upon deletion, all personal data, user-generated content, and account information will be permanently removed within 30 days. Some anonymized, aggregated data that cannot identify you may be retained for analytical purposes.

10. Children's Privacy

Sincerly is not directed at children under the age of 13 (or 16 in the EEA). We do not knowingly collect personal information from children. If you believe a child under the applicable minimum age has provided us with personal data, please contact us at support@sincerly.app and we will promptly delete the information.

11. International Data Transfers

Your data may be processed in countries other than your own. Where we transfer data outside the EEA/UK, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses (SCCs) approved by the European Commission, or other mechanisms permitted by applicable law.

12. Security Measures

We implement industry-standard security measures to protect your data, including:

• End-to-end encryption for private communications.
• Encryption at rest and in transit (TLS 1.2+) for all data.
• Regular security audits and vulnerability assessments.
• Access controls limiting employee access to personal data on a need-to-know basis.
• Secure authentication mechanisms for your account.

No system is 100% secure. While we strive to protect your data, we cannot guarantee absolute security. If we discover a data breach that affects your personal information, we will notify you and relevant authorities as required by law.

13. Third-Party Links

The App may contain links to third-party websites or services (e.g., our Instagram page, Booma Studio website). We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies before providing any personal information.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable laws. When we make material changes, we will:

• Update the "Last Updated" date at the top of this page.
• Notify you through the App or via email.
• Where required by law, obtain your consent to the changes.

Your continued use of Sincerly after the effective date of the revised Privacy Policy constitutes your acceptance of the changes.

15. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or your personal data, please contact us:

• Email: support@sincerly.app
• Contact Form: sincerly.app/contact

We aim to respond to all privacy-related requests within 30 days.