Luvkin

Privacy notice

Draft for testing. Words in square brackets are still being settled with our solicitor.

Last updated [date].

Who we are

Luvkin is provided by Luvero Limited, Bawtry Hall, South Parade, Doncaster, DN10 6JH, a company registered in England and Wales with number 16808899. We are the controller of the personal data described here. We are registered with the Information Commissioner's Office under number [ICO registration number].

If you have a question about your data, email privacy@luvkin.app. [Our data protection officer is [name], at [email]. / We have not appointed a data protection officer because [reason].]

The short version

What we collect and why

Your account. Your name, email address and password (we store only a scrambled version of it). We send a 6-digit code to your email the first time you sign in on a new phone, and we keep a record of each phone you have confirmed. We need these to run your account (contract).

Your details. If you add them, your phone number and postal address, so your details are in one place. They are optional, are never shown to your household, and are sent to a partner only if you tick "Include my phone number and address" on a quote or will-writing request. You can clear them in Settings at any time. [Lawful basis: consent / contract.]

Your household. If you create or join a household: the household's name, who is in it and their role, the invitations you send (including the email address you invite), and each record you choose to share and when you stop sharing it. Being in a household does not share anything on its own. (Contract.)

Your documents. The documents you upload to your vault, the details you confirm from them (such as provider, policy number, renewal date and premium), and where your will or lasting power of attorney is kept. Your documents may contain information about other people, such as a partner on a joint policy. (Contract.) [Basis for other people named in documents: legitimate interests, subject to the solicitor's balancing test.]

Your statements. The rows from bank statements you upload (date, description, amount), a nickname and the last four digits of each account, the regular payments you confirm and any savings you record. A CSV statement is read on your phone and never uploaded. A PDF statement is deleted from our systems as soon as it has been read. Statements can show things about you, such as a payment to a clinic or a place of worship. We do not look for or use this. (Contract.)

Plan Ahead, household jobs, pensions and budget. Your plan settings, savings goal, renewals, household jobs, the pension details you enter (provider, type, value and where the paperwork is) and your budget limits. We never ask for your National Insurance number. (Contract.)

Reminders. If you turn reminders on, the notification code for your phone and a record of each reminder sent. Reminders on your lock screen never say what the renewal or job is, or how much. You can turn them off in Settings. (Consent.)

Reading documents and statements for you (when switched on). If you agree, a document or PDF statement you choose is sent to Anthropic, which reads it and proposes details for you to check. Nothing is used until you confirm it. You agree separately for documents and for statements, and you can withdraw either in Settings. [Wording on health and other sensitive information: open, see the AI readers DPIA.] (Consent.)

Quotes and help with a will or lasting power of attorney (when switched on). If you tap "Get a quote", "Get help writing a will" or "Get help with a lasting power of attorney" and agree on the screen that follows, we send the details listed on that screen to the one named partner, and keep a record of what was sent and the words you agreed to. If you joined through a partner's link or entered their code, your requests for things they cover go to that partner for 12 months. The partner can see how many people joined through their link, but not who. The partner may pay us a fee if you take out a policy or switch. The partner then holds your details as a separate business under its own privacy notice. (Consent, for each request.) If you have saved a postcode under Your details and no partner's link applies, we may use the first half of it (for example DN4) to send your request to a partner who covers your area. That part of your postcode is used only to choose the partner and is not sent. [Lawful basis: part of your consent for each request, for legal review.]

Broadband and mobile quotes (when switched on). If you say a regular payment is broadband or a mobile contract, you can ask a partner for a quote. We send your name, email, the service, your current provider and what you pay a month, never your account numbers or statement rows. (Consent, for each request.)

Energy comparison (when switched on). Your yearly energy use, unit rates and standing charges, typed in or read from your bill, and your region. We compare them with one partner's prices only, not the whole market. A quote request sends your name, email, region, current supplier and yearly use, never your rates or account number. (Contract for the comparison; consent for a quote request.)

Subscriptions (when switched on). Whether you have a subscription, which plan, and when it renews. Apple or Google take the payment; we never see your card details. (Contract.)

Trusted people. If you choose someone to see selected records in an emergency, their name or email and what they would see. Today this is a simulation only: nothing is released to them [and they are not told / and we tell them by email]. (Contract for you; [legitimate interests] for them.)

Feedback. If you use Send feedback in Settings, the part of the app you chose, what you wrote and when. Only the Luvkin team reads it; it is never shared with your household. Please do not include bank details or other people's information. It is deleted with your account. (Legitimate interests: improving the app.) [Retention period: open.]

Keeping the service safe. A record of important actions (such as sharing, quote requests and account deletion), and counts used to limit how often some things can be done. (Legitimate interests: keeping your data and the service secure.)

Kept only on your phone

Your choice of look, whether Face ID or fingerprint unlock is on, and the offline copy of "Where things are" (encrypted, and removed when you sign out) stay on your phone. "Add to my calendar" makes a file on your phone from your own renewals and jobs. We do not send it anywhere or keep a copy. If you add it to a shared calendar, the people who share that calendar can see it, so amounts are left out unless you include them.

Who we share it with

We share your data only with:

We will also share data if the law requires it. We do not sell personal data.

Transfers outside the UK

When AI reading is switched on and you agree to it, your document or statement is processed by Anthropic in the United States. [Transfer mechanism: the UK extension to the EU-US Data Privacy Framework / the UK addendum to the standard contractual clauses.] [Resend, Cloudflare, Expo and RevenueCat are US companies: transfer mechanism for each to be confirmed, for example the UK extension to the EU-US Data Privacy Framework.] You can ask us for a copy of the safeguards we use.

How long we keep it

We keep your records until you delete them or your account. When you delete your account, it is locked straight away and everything you own is erased 7 days later, unless you sign in and cancel before then. Deleted data can stay in our backups for up to [7] days until they expire.

Some records are kept for a set time: [the record of what you agreed to on a quote request, for [6 years]; security records, for [2 years]; billing records, for 6 years after the end of the financial year they relate to, as company law requires]. Anthropic deletes what it reads within 30 days, except content its safety checks flag, which it can keep for up to 2 years. The full list is in our retention schedule [link].

Your rights

You have the right to:

To use any of these rights, use the app or email privacy@luvkin.app. We will reply within one month.

You can complain to the Information Commissioner's Office at ico.org.uk or on 0303 123 1113. We would like the chance to put things right first, so please contact us.

Households and your safety

Joining a household never shares your records. You can stop sharing any record, and leave a household, at any time in the app. If someone is pressuring you to share, you do not have to, and nobody is told what you have not shared. The "Households and sharing" page in the app explains how to stop sharing and leave a household, and lists free national helplines.

Children

Luvkin is for adults aged [18] and over. [How age is checked: open.]

Changes to this notice

If we change how we use your data, we will update this notice and tell you in the app before the change takes effect.