Privacy Policy — Lucky Names

Last updated: July 18, 2026

1. Information we collect

On your device. The names you like, pass, save, and any filters or preferences you set are stored locally on your device. This data is the core of how the App works and is not automatically sent to us. We do not collect personal information about your child — names you browse or save are name candidates, not records about an actual person.

iCloud sync (if you're signed into iCloud). To keep your saved names and combinations available across your own devices, the App may sync this data through Apple's iCloud service, using your personal Apple ID. This sync happens through Apple's infrastructure — it does not pass through our servers, and we cannot see this data ourselves.

Usage and analytics data. We collect analytics about how the App is used — things like which screens and features you interact with, actions you take (e.g., applying a filter, liking a name, viewing a paywall, sharing an invite), and general app performance data, including new events as the App evolves. This helps us understand what's working and improve the App. Analytics data is tied to an anonymous device/installation identifier, not to your name or any offline identity, unless you separately choose to contact us directly (e.g., by emailing support).

Purchases. If you buy a Premium subscription or other in-app purchase, the transaction itself is handled entirely by Apple through StoreKit. We receive confirmation of your purchase/subscription status (e.g., that Premium is active) but never see your payment card details — Apple handles all of that.

Shared rooms (choosing together). If you create or join a shared room to pick names with people you invite, the room runs on our backend, and the following is stored there for the life of the room: the room code, an anonymous device identifier for each member (no account or sign-in required), each member's optional nickname or an app-assigned neutral handle, and the IDs of names each member has liked (so overlaps can be shown). Other room members can see your handle/nickname, your room activity, and the liked names that overlap with theirs — never your full liked list on its own. Your surname and your saved combinations never leave your device to a room. Rooms and their data are deleted when the room is closed or after 90 days of inactivity.

Feedback and reports. If you use the in-app forms — reporting an issue with a name, answering the "how's it going" check-in, or sharing feature feedback — we receive the text you write, the name concerned (for name reports), your feature votes, and an anonymous device identifier, delivered to us through our backend and internal notification tools. Please don't include sensitive personal information in free-text feedback.

Support requests. If you email us, we'll have whatever information you choose to include in that email (e.g., your email address, and anything you tell us).

2. Who receives your data

We don't sell your data (see Section 3), and we share it only with the service providers needed to run the App:

• Apple (App Store, StoreKit, iCloud) — distribution, payments, and optional sync, under Apple's own terms and privacy policy.
• Our analytics provider (PostHog, US cloud) — processes the anonymous usage data described above on our behalf. Events are anonymous by design: no automatic capture, no session recording, and no properties containing names you save, your surname, or any contact details.
• Our hosting providers — host the shared-rooms and feedback services described above (room data and feedback submissions only; never your local lists or surname).
• Basic infrastructure and internal tools (e.g., email hosting for support, and the private channel through which we receive feedback submissions) — only to the extent needed to operate the App and respond to you.

These providers may only use your data to provide services to us, not for their own purposes.

If required by law. We may disclose information if we believe in good faith that disclosure is required by law or a valid legal process (such as a court order), or is necessary to protect the rights, property, or safety of users, the public, or us. Given our architecture, the data we hold and could disclose is minimal (see Section 1).

Business transfers. If we ever sell, merge, or transfer all or part of the Lucky Names business, the data described in this policy may be transferred as part of that transaction. Any successor will remain bound by the substance of this policy, and we'll give notice (per Section 8) of any material change.

3. What we don't do

• We do not sell your personal information to anyone.
• We do not currently show third-party advertising inside the App.
• We do not have access to your iCloud-synced data — that stays between you and Apple.
• We do not knowingly collect data from children. Lucky Names is intended for adults (parents/parents-to-be), not for use by children.

4. Your choices

• Local data: deleting the App from your device removes the locally stored data.
• iCloud data: managed through your own iOS Settings → your Apple ID → iCloud.
• Shared rooms: you can leave a room at any time (or, as owner, close it); leaving or closing removes the room relationship, and closed/expired rooms are deleted from our backend.
• "Delete all my data" (in-app): removes your data from your device, purges your actions from our backend (including room activity), and resets your anonymous device identifier.
• Analytics: you can request more detail on, or object to, analytics collection by emailing support@luckynames.app.
• Deletion / access requests: email support@luckynames.app and we'll respond as soon as we reasonably can.

5. Data retention & security

We retain analytics data only as long as reasonably needed to understand app usage and improve the product, and delete or anonymize it on a routine basis. Locally-stored and iCloud-synced data is retained for as long as you keep the App installed / your iCloud account active, and is removed when you delete the App or that data yourself.

Security. We follow a data-minimization approach: your most sensitive data (your lists and preferences) never reaches us in identifiable form. For the limited data we do handle (anonymous analytics, support email, room data), we use reputable providers and safeguards such as encryption in transit. No method of transmission or storage is 100% secure, but the amount of your data at risk with us is deliberately kept minimal.

6. International users (EU / UK / Australia / Canada)

If you use Lucky Names from outside the US, the following applies in addition to the rest of this policy:

• Legal basis for processing (EU/UK). We process your data based on our legitimate interest in operating and improving the App, and, where required, your consent (e.g., for analytics). You can withdraw consent at any time by contacting support@luckynames.app.
• Your rights (EU/UK GDPR). Subject to applicable law, you may request access to, correction of, deletion of, or a portable copy of your data, and you may object to or restrict certain processing. Email support@luckynames.app to exercise these rights. If you believe we haven't addressed your concern, you have the right to lodge a complaint with your local data protection authority (in the UK, the ICO).
• Canada (PIPEDA). We collect, use, and disclose personal information only for purposes a reasonable person would consider appropriate in the circumstances, and only with your consent (which may be implied for low-sensitivity data like basic usage analytics).
• Australia (Privacy Act). We aim to handle personal information consistently with the Australian Privacy Principles. As a small-scale operation we may fall under applicable small-business thresholds, but we apply the same data-minimization practices described in this policy regardless.
• Cross-border transfers. We are based in Portugal (EU), and we rely on Apple's global infrastructure (App Store, iCloud, StoreKit) and standard analytics tooling, so your data may be processed in the US or other countries. We rely on the safeguards those providers already have in place (e.g., Apple's and our analytics provider's own data-processing terms) rather than operating our own international data centers.

7. Children's privacy

Lucky Names is not directed at children under 13 (or the relevant age of consent in your region) and we do not knowingly collect personal information from children. If you believe a child has provided us information, contact support@luckynames.app and we'll remove it.

8. Changes to this policy

We may update this policy from time to time as the App evolves. If we make material changes, we'll give notice — by an in-app notice, or by posting the updated policy here with a new "Last updated" date — before the changes take effect. Continued use of the App after the effective date means you accept the updated policy.

9. Contact & data controller

Questions about this policy or your data: support@luckynames.app — email is the fastest way to reach us.

The data controller is Lucky Names, operated by Iuliia Rodina, a sole trader registered in Portugal (registration number 314839925).