for the Lycka app and its pages at jwm.media/lycka-…. Last updated: 04. October 2026. The remaining pages of jwm.media are covered by that site’s own privacy policy. This is a translation of the German version, which prevails in case of any discrepancy.
1. Controller
Jonathan Werle Media (sole proprietorship)
Owner: Jonathan Werle
Am Römerhof 30
52066 Aachen
Germany
Email: lycka@jwm.media
VAT identification number: DE361350292
No data protection officer has been appointed, because the statutory thresholds (section 38 BDSG) are not met. For any privacy matter, please write to the address above.
2. The short version
Lycka is an app for two people in a long-distance relationship. What you write and photograph is meant for your partner, and for nobody else. Some things are deliberately not built, which is what makes that credible:
- No location tracking and no sensor-based inference. Your status is set by you, always.
- No tracking, no advertising, no analytics SDKs, and no sharing of data for advertising. This is also why the app has no cookie or consent banner: nothing is stored beyond what running the service requires.
- Anonymous crash reports, which you can switch off in Settings: when the app crashes, a report without your name, your account or anything you wrote goes to our error tracker in the EU.
- No profiling and no automated decision-making.
- The question game stores no answers, only whether a card was played or skipped.
- Your content is stored on servers in Frankfurt am Main (EU).
3. What we process, why, and on what legal basis
The core legal basis is Art. 6(1)(b) GDPR: processing is necessary to perform the contract you enter into when you register. Where something else applies, the table says so.
| Purpose | Data | Legal basis | Retention |
|---|---|---|---|
| Account and sign-in | Email address, sign-in times, session token (stored encrypted on your device) | Art. 6(1)(b) | until the account is deleted |
| Profile | Display name, profile photo, timezone and whether it was detected or set manually | Art. 6(1)(b) | until the account is deleted |
| Connecting with your partner | Invite code, its status and redemption time, the link between the two accounts, optionally the date you became a couple | Art. 6(1)(b) | codes: 7 days after redemption or expiry; the link: until you unpair |
| Daily question | Your free-text answers, timestamps, whether you skipped | Art. 6(1)(b), and for special categories additionally Art. 9(2)(a) (see section 4) | until account deletion or unpairing |
| Question game | per card only: played or skipped. No answers. | Art. 6(1)(b) | until account deletion or unpairing |
| Moments | Photo, caption, timestamp, expiry time, whether the moment was kept | Art. 6(1)(b), where applicable Art. 9(2)(a) | 24 hours; kept moments until either of you deletes them, until account deletion, or until unpairing |
| Status | A short text you write yourself, expiry time | Art. 6(1)(b) | expires automatically, deleted at the latest 7 days later |
| Events and lists | Title, place and the timezone of that place, date, entries in shared lists | Art. 6(1)(b) | until you delete them, until account deletion, or until unpairing |
| Push notifications | Device push token, notification title and body, the technical state of the home-screen widget including time-limited links to the current photo | Art. 6(1)(b); you grant permission to send through your operating system and can withdraw it there or in the app at any time | tokens until the device is deregistered or the account deleted; sent notifications 7 days |
| Place lookup for events | The search term you type and your IP address, sent to a geocoding service (section 5) | Art. 6(1)(b) | not stored by us; at the service provider up to 90 days per its own statements |
| App updates | On launch the app checks for updates; the update service receives IP address, device type, operating system and app version | Art. 6(1)(f) (legitimate interest in an up-to-date, working app) | not stored by us |
| Operation, security, troubleshooting | Platform server logs (IP address, time, endpoint, error codes) | Art. 6(1)(f) (legitimate interest in stable and secure operation) | short-term at the processor, typically a few days |
| Crash and error reports | Type of error and where in the code it happened; the technical steps just before it (e.g. which server request failed, without its content); app version, operating system and device model. No name, email address, account or couple identifier, and nothing you wrote or photographed. Your IP address is transmitted with the connection. | Art. 6(1)(f) (legitimate interest in finding and fixing errors); you can turn this off at any time under Settings > Share crash reports | raw reports are deleted after 60 days; aggregated error counts without personal data are kept until we remove them |
| Email contact | Your email address, your message and our reply | Art. 6(1)(b) or (f) | until resolved, then subject to statutory retention periods |
| The website hosting these documents | Access data at the hosting provider (IP address, time, page requested) | Art. 6(1)(f) | as configured by the hosting provider |
Access to your device happens only when you trigger it: your photo library or camera when you send a moment or choose a profile picture, and your calendar when you want to import an event. That data leaves your device only insofar as you pick a specific photo or a specific event. Neither your photo library nor your calendar is read or transmitted. To send a crash report, the app reads technical information about your device (model, operating system) and holds the report briefly on the device until it is sent. We consider this strictly necessary for a working app (section 25(2) no. 2 TDDDG); you can switch it off under Settings > Share crash reports.
Is providing data required? Without an email address and a display name no account can exist and no connection to your partner can be made. Everything else is voluntary: profile photo, timezone, events, photos, answers. Skipping a question is explicitly intended and has no consequences.
4. Special categories of personal data
Lycka has no fields for health data, religious or political beliefs, or information about your sex life. It is in the nature of the product, though, that an answer to the daily question or a caption may contain something that reveals such information. Where that happens, we process that content on the basis of your explicit consent under Art. 9(2)(a) GDPR, given at registration and withdrawable at any time with effect for the future. After a withdrawal you can no longer use the affected features; content already stored is deleted on request.
For the card game with the open questions: not a single answer is stored. The game only remembers which card has been played.
5. Recipients and processors
We do not pass your data to third parties for their own purposes and we do not sell it. Only providers necessary to run the service are used:
| Recipient | Role and purpose | Place of processing | Basis |
|---|---|---|---|
| Supabase Inc., 970 Toa Payoh North, Singapore (project region Frankfurt am Main) | Processor: database, authentication, file storage for photos, server functions | Frankfurt am Main, Germany (EU) | Art. 28 GDPR (data processing agreement) |
| Scaleway SAS, 8 rue de la Ville-l’Évêque, 75008 Paris, France | Processor: delivering the email that carries your one-time sign-in code and link | France (EU) | Art. 28 GDPR (data processing agreement) |
| Bugsink B.V., Peter Schathof 41, 3533 HZ Utrecht, The Netherlands | Processor: receiving and grouping crash and error reports | EU | Art. 28 GDPR (data processing agreement) |
| Expo (650 Industries, Inc.), USA | Processor: sending push notifications and delivering app updates | USA | Art. 28 GDPR; transfer per section 6 |
| Apple Inc. / Apple Distribution International Ltd. | Delivering notifications to iPhones (Apple Push Notification service) | USA and EU | Art. 28 GDPR; transfer per section 6 |
| Google Ireland Ltd. / Google LLC (Android devices only) | Delivering notifications via Firebase Cloud Messaging | EU and USA | Art. 28 GDPR; transfer per section 6 |
| OpenMeteo GmbH, Hintere Schilligmatte 6, 6463 Bürglen (UR), Switzerland | Turning a place name you type into coordinates and a timezone (geocoding) | Switzerland | European Commission adequacy decision for Switzerland |
| Microsoft Ireland Operations Ltd., One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland | Processor: the mailbox your email arrives in when you write to us | EU, with access from the USA possible | Art. 28 GDPR; transfer per section 6 |
| OVH SAS, 2 rue Kellermann, 59100 Roubaix, France | Hosting these legal documents | European Union | Art. 28 GDPR |
Apple and Google decide independently, as controllers, about the operation of the app stores themselves (purchase, installation, updates, reviews). Their own privacy notices apply to that, and we have no influence over it.
What a push notification actually carries
So you can judge this for yourself: a push notification contains the title and body shown on your lock screen, and therefore, depending on the occasion, your partner’s first name and the kind of event. So that the home-screen widget can stay current without you opening the app, the notification also carries the current widget state and a time-limited, signed link to the relevant photo. This travels through Expo’s push service and then through Apple or Google. According to Expo, notification content is not stored persistently and is processed only for delivery. The photo itself is fetched by your device from our storage in Frankfurt.
6. Transfers to third countries
Your content is processed in the EU. Transfers to the USA happen only for sending notifications and for app updates (Expo, Apple, Google), and for the mailbox your email arrives in when you write to us (Microsoft). They rely on the EU-US Data Privacy Framework where the recipient is certified under it, and otherwise on the European Commission’s standard contractual clauses under Art. 46(2)(c) GDPR together with additional safeguards. For Switzerland, a European Commission adequacy decision applies. Copies of the safeguards are available on request at the email address above.
7. Your partner as a recipient
This is the heart of the app, so it is stated plainly: everything you create as a moment, answer, status, event or list entry is meant for the person you are connected with and visible to them. With the daily question, both answers become visible only once you have both answered. After sending a moment you can delete it, but you cannot make it unseen. If the connection is ended, shared content is deleted for both of you.
8. Deletion and retention
- Moments expire after 24 hours and are deleted automatically if they were not kept. That includes the stored image file.
- Unpairing. When a connection ends, the couple and all shared content including photo files are deleted immediately and permanently, not merely hidden.
- Account deletion. You can delete your account at any time. We then delete your profile, credentials, push tokens, files and your membership of a couple. Shared content is treated as on unpairing. See Delete your account.
- Backups. The platform keeps technical backups, from which deleted data disappears once the relevant backup cycle has passed. It is no longer reachable from live operation the moment it is deleted.
- Statutory retention. Where commercial or tax law requires it (for example with a future paid feature), the relevant records are retained for the statutory period and otherwise restricted.
9. Your rights
You have the right of access (Art. 15), rectification (Art. 16), erasure (Art. 17), restriction (Art. 18), data portability (Art. 20) and objection to processing based on legitimate interests (Art. 21 GDPR). Consent can be withdrawn at any time with effect for the future, without affecting the lawfulness of processing up to that point. An email to lycka@jwm.media is enough; we reply within one month.
You may also lodge a complaint with a supervisory authority. The one competent for the controller is:Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen
Kavalleriestraße 2 to 4
40213 Düsseldorf, Germany
www.ldi.nrw.de
10. Security
All transmission is encrypted (TLS). Photos live in non-public storage buckets and are reachable only through short-lived signed links. Database access is secured row by row (row level security), so every query is technically confined to your own active couple; reads and writes go through vetted server functions. Your session is stored encrypted on your device. A residual risk can never be entirely excluded when transmitting over the internet.
11. Not for minors
Lycka is for adults only. Use by persons under 18 is not permitted, among other reasons because it includes a question card game with explicitly adult content. If we learn that an account is held by a minor, we delete it.
12. No automated decision-making
There is no automated decision-making within the meaning of Art. 22 GDPR and no profiling. Which question appears on a given day follows fixed rules over a deck of cards and does not evaluate your answers.
13. Changes to this policy
When the app changes, this policy changes with it. The current version is always at jwm.media/lycka-privacy-policy. We will additionally notify you in the app about material changes.
Legal notice · Terms of Service · Delete your account · Deutsche Fassung