Privacy notice · platform
Privacy — The platform
Last updated: 21 October 2026 — version 1.0
This notice covers whoever has an account: profile, photos, messages, from sign-up onwards. For the waitlist alone, the waitlist notice applies →
The short version
We collect the minimum needed to let you meet people in a safe place. Your interests are seen only by you and by whoever you decide, and you declare them only if you want to. We show your photos according to the rules you set, without your phone's metadata. Identity verification is done by an external provider: we never see your documents. We sell nothing to anyone, we do not profile you, we use no tracking cookies. You can change, withdraw and delete everything from the settings.
This notice applies from sign-up onwards; the waitlist has its own, at luceva.it/privacy. Below is the full version: that is the one that counts.
1Controller
The operator of Luceva, reachable at matteo@luceva.it. Write to the same address for anything about your data.
The controller's full identity (name, registered office, VAT number) will be published here when the company is incorporated. The notice will be updated and we will let you know.
Data protection officer (DPO): not yet appointed. In the current phase — a closed, invite-only beta — the processing is not large-scale (art. 37(1)(c) GDPR). The appointment will be reassessed with legal advice before the public opening; if it happens, the contact will appear here.
2Which data, why, on what basis
| category | data | purpose | legal basis |
|---|---|---|---|
| Account | email, password (hashed), date of birth, language, invite code used | create and protect the account; check that you are an adult | contract (art. 6(1)(b)); legal obligation for age |
| Profile | chosen name, computed age, city, how you define yourself, pronouns, what you are looking for, bio, chosen visibilities | let others find you and present you according to your settings | contract |
| Interests (special categories, art. 9) | the kink/BDSM interests you declare, consent date | show them to whoever you decide; search by shared interests | explicit, separate consent (art. 9(2)(a)), revocable from the settings |
| Images | photos you upload to your profile or send in chat; the "explicit" mark; your declarations | show them according to your settings; prove you declared you are the only one in them | contract; accountability obligation for the declarations |
| Identity verification | outcome (level) and the provider's session identifier | let you start conversations; show the badge | contract; legitimate interest in preventing fake profiles |
| Messages | text and photos you exchange; dates; read status; first-message counters | make the chat work; anti-spam limits | contract |
| Relationships | blocks, reports, "always welcome" connections, settings | enforce your choices; moderation | contract; legitimate interest (moderation) |
| Consents | exact text, version, language and date of every consent and withdrawal | prove what you accepted and when | legal obligation (art. 7(1)) |
| Technical | session, last access, cookieless visit statistics, hosting provider logs | security; understanding aggregate use of the service | legitimate interest |
- category
- Account
- data
- email, password (hashed), date of birth, language, invite code used
- purpose
- create and protect the account; check that you are an adult
- legal basis
- contract (art. 6(1)(b)); legal obligation for age
- category
- Profile
- data
- chosen name, computed age, city, how you define yourself, pronouns, what you are looking for, bio, chosen visibilities
- purpose
- let others find you and present you according to your settings
- legal basis
- contract
- category
- Interests (special categories, art. 9)
- data
- the kink/BDSM interests you declare, consent date
- purpose
- show them to whoever you decide; search by shared interests
- legal basis
- explicit, separate consent (art. 9(2)(a)), revocable from the settings
- category
- Images
- data
- photos you upload to your profile or send in chat; the "explicit" mark; your declarations
- purpose
- show them according to your settings; prove you declared you are the only one in them
- legal basis
- contract; accountability obligation for the declarations
- category
- Identity verification
- data
- outcome (level) and the provider's session identifier
- purpose
- let you start conversations; show the badge
- legal basis
- contract; legitimate interest in preventing fake profiles
- category
- Messages
- data
- text and photos you exchange; dates; read status; first-message counters
- purpose
- make the chat work; anti-spam limits
- legal basis
- contract
- category
- Relationships
- data
- blocks, reports, "always welcome" connections, settings
- purpose
- enforce your choices; moderation
- legal basis
- contract; legitimate interest (moderation)
- category
- Consents
- data
- exact text, version, language and date of every consent and withdrawal
- purpose
- prove what you accepted and when
- legal basis
- legal obligation (art. 7(1))
- category
- Technical
- data
- session, last access, cookieless visit statistics, hosting provider logs
- purpose
- security; understanding aggregate use of the service
- legal basis
- legitimate interest
We do not collect: real name, address, phone number, payment data (the subscription is not active), geolocation. Your IP address does not enter the application database: it only appears in the hosting provider's technical logs.
No profiling, no automated decisions with effects on you. Message limits are rules that are the same for everyone, not judgements about the person.
3How visibility works
Every sensitive piece of information — interests, photos, city, what you are looking for — has a visibility you choose: everyone (registered users), verified only, on request. Photos marked explicit are visible only to those who have explicitly enabled their display in their own settings. The rules are enforced by the database, not by the interface: no page can show what the rule does not allow.
4Identity verification
Verification (selfie or document) will be carried out by a specialised external provider, an independent controller of your documents and of the biometric data of the check, under its own notice, shown to you before you start. We only receive the outcome and a session identifier: no document, no image of your face, no biometric data passes through or is stored in our systems.
In the closed beta the provider is not active yet: verification is an internal test. The provider's name and location will appear here before activation.
5Who processes data for us
| provider | role | where |
|---|---|---|
| Supabase Inc. | database, authentication, photo storage | European Union (Frankfurt) |
| Vercel Inc. | application hosting, cookieless statistics, technical logs | functions run in the European Union (Frankfurt); US company |
| Resend Inc. | transactional email (welcome) | European Union (Ireland) |
| Verification provider | identity verification, independent controller (see section 4) | to be stated at activation |
- provider
- Supabase Inc.
- role
- database, authentication, photo storage
- where
- European Union (Frankfurt)
- provider
- Vercel Inc.
- role
- application hosting, cookieless statistics, technical logs
- where
- functions run in the European Union (Frankfurt); US company
- provider
- Resend Inc.
- role
- transactional email (welcome)
- where
- European Union (Ireland)
- provider
- Verification provider
- role
- identity verification, independent controller (see section 4)
- where
- to be stated at activation
A data processing agreement (art. 28) is in place with each. Supabase, Vercel and Resend are US companies: transfers are covered by the standard contractual clauses and, where applicable, by the Data Privacy Framework.
We do not share your data with anyone else, except under a legal obligation or a request from an authority. In particular, data about orientation and interests is never shared with advertising partners: we have no advertising partners.
6Security — how we protect special-category data
- Separate stores: who you are (email, credentials, date of birth) and what you do (profile, interests, photos, messages) live in separate stores, linked by a random identifier that is neither your email nor your account identifier. An incident exposing only the profile store would contain neither emails nor keys to trace an identity.
- Every access by us to the table linking identity and profile is recorded with date and reason.
- Photos are stored privately and served only through temporary addresses issued after the visibility check.
- Writes to sensitive data go only through server-side controlled functions; no direct change is possible from the client, not even by you.
- Photo metadata (GPS position, device, date) is removed on upload: every image is re-encoded on the server before being stored.
- Passwords are kept only in hashed form by the authentication system; we do not see them and cannot read them.
7For how long
| data | retention |
|---|---|
| Account and profile | as long as the account exists; on deletion, 30 days of grace, then the profile is anonymised and the link with your login removed |
| Interests (art. 9) | until you withdraw them or delete the account; on withdrawal, immediate deletion |
| Photos | until you delete them or delete the account; after the 30 days of grace, the files are deleted |
| Photo declarations | kept as evidence even after the photo is deleted; period being defined |
| Messages | as long as the conversation exists; when you delete your account they remain for the other person, anonymised; period being defined |
| Reports and decisions | kept after the case is closed and after the account is deleted, to defend a right; period being defined |
| Consents | kept as evidence even after withdrawal or deletion; period being defined |
| Technical logs | kept by the hosting provider for the short period its service provides; we do not archive them |
- data
- Account and profile
- retention
- as long as the account exists; on deletion, 30 days of grace, then the profile is anonymised and the link with your login removed
- data
- Interests (art. 9)
- retention
- until you withdraw them or delete the account; on withdrawal, immediate deletion
- data
- Photos
- retention
- until you delete them or delete the account; after the 30 days of grace, the files are deleted
- data
- Photo declarations
- retention
- kept as evidence even after the photo is deleted; period being defined
- data
- Messages
- retention
- as long as the conversation exists; when you delete your account they remain for the other person, anonymised; period being defined
- data
- Reports and decisions
- retention
- kept after the case is closed and after the account is deleted, to defend a right; period being defined
- data
- Consents
- retention
- kept as evidence even after withdrawal or deletion; period being defined
- data
- Technical logs
- retention
- kept by the hosting provider for the short period its service provides; we do not archive them
The periods "being defined" will be set with legal advice before the public opening and communicated as a change to this notice. Today there is no automatic deletion for that data: you can still ask for it by writing to us, and we assess it case by case. No automatic deletion of inactive accounts is planned for now.
8Your rights
From the settings, without writing to us: change every visibility, withdraw consent on interests, unlock or cover explicit content, delete photos, change your password, delete the account (luceva.it/cancella-account).
By writing to ciao@luceva.it: access, rectification, portability, restriction, objection, and anything you do not find in the settings. We reply within 30 days.
You can lodge a complaint with the Italian data protection authority, the Garante (www.garanteprivacy.it).
10Changes
We notify you by email at least 15 days before changes that affect you. The version in force, with its date, is at luceva.it/privacy-app.
You confirm you have read this notice at sign-up, with a dedicated checkbox. The text, its version and the date are recorded.
Last updated: 21 October 2026 — version 1.0