legal

privacy policy

Effective date: June 21, 2026  ·  Last reviewed: June 21, 2026

Plain-language summary (this does not replace the policy below): Coople connects exactly two people. We collect the content you choose to send your partner, your approximate location if you enable it, and technical identifiers needed to deliver content and notifications. We do not sell data, show ads, or share information with third parties for marketing. You can request a copy or deletion of your data at any time by emailing us.

1. Scope & Data Controller

This Privacy Policy ("Policy") describes how Astro Developments ("Astro Developments," "we," "us," or "our"), the developer of the mobile application Coople (the "App" or "Service"), collects, uses, discloses, and safeguards information in connection with your use of the App. This Policy applies to all users of the App worldwide and is intended to satisfy our disclosure obligations under, among other frameworks, the EU General Data Protection Regulation 2016/679 ("GDPR"), Romania's implementing legislation, the California Consumer Privacy Act as amended ("CCPA/CPRA"), and Apple Inc.'s App Store Review Guidelines and Privacy requirements.

For the purposes of the GDPR, Astro Developments acts as the data controller with respect to the personal data described in this Policy. Apple Inc. acts as an independent data processor and, in certain respects, an independent controller with respect to the underlying iCloud and CloudKit infrastructure on which the App is built; Apple's own privacy practices are described at apple.com/legal/privacy and are not within our control.

By downloading, installing, or using the App, you acknowledge that you have read and understood this Policy. If you do not agree with this Policy, you should not use the App.

2. Definitions

TermMeaning
"Personal Data"Any information relating to an identified or identifiable natural person, as defined under GDPR Art. 4(1).
"Processing"Any operation performed on Personal Data, including collection, storage, use, transmission, and deletion.
"Pairing" / "Pair"The one-to-one connection established between two users of the App via a unique invitation code.
"Content"Photographs, drawings, status updates, animal-avatar selections, and any other material a user transmits through the App.
"You" / "User"The natural person using the App, whether as the pairing initiator or the joining partner.

3. Information We Collect

3.1 Information You Provide Directly

3.2 Information Collected Automatically

3.3 Information We Do Not Collect

We do not request, collect, or store your name, email address, phone number, government-issued identification, payment information, contacts/address book, browsing history outside the App, advertising identifiers, or biometric data. The App contains no advertising SDKs and no third-party analytics or tracking software.

4. Location Information

If you enable the optional distance feature, the App requests "When In Use" location access through Apple's standard system permission prompt. The following limitations apply by design:

Your rounded location, if enabled, is shared only with the one partner in your pairing and is stored alongside your status information for only as long as it remains current (see Section 9, Data Retention).

5. Legal Bases for Processing

Where the GDPR applies, we rely on the following legal bases under Article 6(1):

Processing ActivityLegal Basis
Delivering content between paired users; operating core App functionalityPerformance of a contract (Art. 6(1)(b)) — necessary to provide the Service you requested
Location-based distance calculationConsent (Art. 6(1)(a)) — obtained via the iOS system permission prompt, revocable at any time
Crash diagnostics and security monitoringLegitimate interests (Art. 6(1)(f)) — maintaining the stability and security of the Service
Responding to support requestsLegitimate interests (Art. 6(1)(f)) and, where applicable, performance of a contract

6. How We Use Your Information

We use the information described above exclusively to:

  1. Establish and maintain the pairing between you and your partner;
  2. Transmit, store, and render Content (including photographs, drawings, and status updates) on the recipient's lock screen, home screen widgets, and within the App;
  3. Calculate and display approximate distance between paired users, where location sharing is enabled;
  4. Send push notifications that alert your partner to new Content, status changes, or attention requests ("nudges");
  5. Diagnose, debug, and maintain the technical reliability of the App; and
  6. Respond to support inquiries you submit to us.

We do not use your information to serve advertising, to build behavioral profiles, or to make any decision that produces legal effects concerning you.

7. International Data Transfers

The App is built on Apple's CloudKit platform, and accordingly your data is stored on servers operated by Apple, which may be located outside of your country of residence, including outside the European Economic Area ("EEA"). Apple represents that it implements appropriate safeguards for such transfers, including reliance on the European Commission's Standard Contractual Clauses or other legally recognized transfer mechanisms where required by applicable law. We do not control, and accept no responsibility for, the specific data-center locations or transfer mechanisms used by Apple's infrastructure; users seeking further detail should consult Apple's own privacy and data-transfer disclosures.

8. Disclosure of Information

We do not sell, rent, or trade your Personal Data. We do not share it with data brokers, advertising networks, or third parties for marketing purposes. Information is disclosed only in the following limited circumstances:

9. Data Retention

We retain Personal Data only for as long as reasonably necessary to fulfil the purposes outlined in this Policy:

Upon a verified deletion request (see Section 10), we will delete or anonymize your Personal Data within thirty (30) days, except where retention is required by applicable law.

10. Your Rights

Subject to applicable law, and in particular where the GDPR applies, you have the right to:

If you are a California resident, you have broadly equivalent rights under the CCPA/CPRA, including the right to know, delete, and correct personal information, and the right to non-discrimination for exercising these rights. We do not "sell" or "share" personal information as those terms are defined under the CCPA/CPRA.

To exercise any of these rights, contact us using the details in Section 16. We will respond within the timeframes required by applicable law (generally one month under the GDPR, extendable by a further two months for complex requests).

11. Children's Privacy

The App is not directed at, and is not intended for use by, individuals under the age of sixteen (16). We do not knowingly collect Personal Data from children. If we become aware that we have inadvertently collected Personal Data from a child without appropriate consent, we will take reasonable steps to delete such data promptly. Parents or guardians who believe their child has provided us with Personal Data should contact us using the details in Section 16.

12. Security

We rely on Apple's CloudKit infrastructure, which applies encryption in transit (TLS) and at rest, and which scopes data access to the authenticated iCloud account associated with each device. Access to your pairing record is restricted, at the database level, to the two paired accounts. While we take reasonable measures consistent with industry practice, no method of electronic transmission or storage is completely secure, and we cannot guarantee absolute security.

13. Automated Decision-Making

We do not engage in automated decision-making or profiling, as defined under Article 22 of the GDPR, that produces legal effects concerning you or significantly affects you.

14. Changes to This Policy

We may update this Policy from time to time to reflect changes in our practices, the App's functionality, or applicable law. Material changes will be reflected by an updated "Effective date" at the top of this page and, where appropriate, accompanied by an in-app notice. Your continued use of the App after such changes take effect constitutes your acknowledgment of the revised Policy.

15. Supervisory Authority

If you are located in the European Economic Area and believe our processing of your Personal Data infringes applicable data protection law, you have the right to lodge a complaint with your local supervisory authority. As our principal place of operation is Romania, you may also contact:

Autoritatea Națională de Supraveghere a Prelucrării Datelor cu Caracter Personal (ANSPDCP)
B-dul G-ral. Gheorghe Magheru 28-30, Sector 1, Bucharest, Romania
www.dataprotection.ro

16. Contact Us

Questions, requests, or complaints regarding this Policy or our data practices should be directed to:

Astro Developments
Email: slime.match3@gmail.com