Privacy Policy

Who is responsible

Manish Rana
Lochmühlstraße 91
60437 Frankfurt am Main
Germany
Email: [email protected]

Cozyo is a private, free app without ads. It shares locations, photos and messages only between people who are in the same circle, which they can only join with an invite code. For every question about your data, write to the address above.

In short

• Only the people in your circles see what you share there.
• Sharing your location is voluntary and can be paused at any time.
• Snips disappear at the end of the day. Location history is kept for 24 hours.
• Ads and the sale of data have no place in Cozyo.
• Usage statistics are pseudonymous and can be switched off in the app.
• You can export your data and delete your account in the app yourself.

What the app processes, and why

• Account: email address, password (stored only as a hash), name, profile picture, app language, your notification settings and when you created the account. With “Sign in with Google” or “Sign in with Apple” we only receive your name and email address (with Apple, optionally a private relay address). Purpose: signing you in and showing the people in your circles who you are. Kept until you delete your account.
• Circles: which circles you belong to, their names and the invite codes you create. A code works for seven days and for one person. If someone enters wrong codes, we store the time of each failed attempt for one hour, so codes cannot be guessed. Kept as long as you are in the circle.
• Location: your current position (coordinates and accuracy), battery level, whether you are standing still and when the position was last updated. The app sends it also while it is closed, as long as location sharing is on. People in your circles see your current position while sharing is on; when you pause it, they no longer see it. Your last position stays stored for you until it is replaced or your account is deleted.
• Location history: the positions of the last 24 hours. Only we use it, to find errors in location updates; it is visible neither in the app nor to your circles. A job deletes every entry older than 24 hours each night, so an entry is gone after 48 hours at the latest.
• Wake signals: if your phone has not reported its position for a while although sharing is on, our server sends it a silent notification so the app updates the position. We store when the last signal was sent.
• Places and arrivals: saved places (name, category, position, radius) and with which circles and people they are shared. When someone arrives at a place, an arrival entry (place, time, optional short message) is stored and the people the place is shared with get a notification. Places are kept until they are deleted; arrival entries as long as your account exists.
• Snips: photo, optional caption, the position where it was taken and the time, plus who has seen it, reactions and replies. Snips are deleted at the end of the day together with their reactions and replies; a nightly job on our server also removes every snip older than 48 hours, in case nobody opened the app.
• Winks: who sent which wink to whom, when, and whether it was seen. Kept as long as the accounts of sender and receiver exist.
• Together, trips and meetups: ideas, plans, links, pictures, trips with destination, dates and photos, and meetups. Visible only in the circle they belong to. Kept until they are deleted, or as described under “Deleting your account”.
• Reports and blocks: if you report a person or a snip, we store who reported whom, which snip, the reason and the time, so we can look into it. If you block someone, we store that block. Blocks are kept until you lift them or one of the two accounts is deleted. Reports are kept as long as we need them to handle the case and to recognise repeated misuse; if the reporting person deletes their account, their name is removed from the report.
• Camera and photos: only when you take or pick a photo yourself. The app reads nothing else from your photo library.

Legal basis: providing the app you chose to use, under our Terms of Use (Art. 6(1)(b) GDPR). For location (also in the background), camera, photos and notifications, additionally your consent via your phone's permissions (Art. 6(1)(a) GDPR), which you can withdraw there at any time; sharing your location is voluntary and can be paused in the app under MORE → “Standort teilen”. Location history, failed code attempts, reports and blocks are based on our legitimate interest in a working, safe app (Art. 6(1)(f) GDPR).

Place search, maps and links

Place search: when you search for a place or an address in the app, your search term and the app language go to the Google Places API (Google), so it can return matching places. Your own position is not part of the search.

Maps links: if you add a Google Maps link to a Together idea, the app opens that link once to read the place name and coordinates. Google receives this request like any visit to the link.

Maps: the map in the app comes from Apple Maps on iPhone and from Google Maps on Android. To load the map, the provider receives your IP address and the map area shown.

Legal basis: Art. 6(1)(b) GDPR, as these are functions of the app you use when you choose to.

Notifications

So that winks, arrivals and snips reach you as notifications, the app stores a device token (push token) for your phone. Our server sends each notification with its text (for example, the sender's name and the kind of message, or the name of a place for an arrival) to the push service of Expo, which forwards it to Apple (iPhone) or Google (Android). The token is kept until it changes or your account is deleted. You can turn notifications off in MORE or in your phone's settings. Legal basis: Art. 6(1)(b) and (a) GDPR.

Usage statistics and error reports

Usage statistics: to see which parts of Cozyo people use, the app counts a few actions, for example “app opened”, “snip sent” or “circle created”, together with the platform (iOS or Android), the app version and the app language. Instead of your name or email address, these counts carry a pseudonymous ID (a SHA-256 hash of your account ID). Locations, photos, captions, messages and names are never part of them. They go to PostHog, whose servers for us are in the EU (Frankfurt). You can switch this off at any time in the app under MORE → “Nutzungsdaten teilen” (share usage data); from then on the app sends nothing more. The choice is also saved in your account, so it applies on your other phones too.

Error reports: when the app crashes or something fails in the background, it sends the error message, the place in the program code where it happened, the platform, the app version and, if you are signed in, your account ID. Error reports are stored at Supabase in the EU (Ireland) and deleted after 90 days. They contain no locations, photos or messages. If you delete your account, your account ID is removed from them.

The legal basis for both is our legitimate interest in keeping the app working and making it better (Art. 6(1)(f) GDPR). You can object at any time, for usage statistics in the app directly with the switch there.

Emails

Account emails: confirmation, sign-in and password emails are sent through Resend (Resend, Inc., USA). Resend receives your email address and the content of the email, and keeps delivery logs for a limited time. Legal basis: Art. 6(1)(b) GDPR.

Writing to us: emails to [email protected] are forwarded by Cloudflare Email Routing to our mailbox. We use your message and email address only to answer you, and delete the conversation when it is done, unless we need it for an open report. Legal basis: Art. 6(1)(b) or (f) GDPR.

This website

Hosting and delivery: jmcozy.com is hosted by Vercel and delivered through Cloudflare, which provides the domain's DNS, the encrypted connection and protection against attacks. Both process your IP address, the requested page, time, browser and referring page in technically necessary server logs, which they keep only for a short time.

Fonts: the font Outfit is stored on jmcozy.com itself and loaded from there, so no font provider receives your data.

Statistics: PostHog (EU servers, Frankfurt) counts which pages of jmcozy.com are viewed and what is clicked, and measures how fast pages load. The website sets no cookies and stores nothing on your device for this, so every visit counts on its own and no profile is created. Session recording is off. The only thing the site stores in your browser is your choice between English and German, if you click EN or DE.

Join form: if you leave your email address in the join form (and, optionally, who invited you), we store it only to send you the download link and get in touch about the app. It is kept at Supabase (EU) until you ask us to delete it, and at the latest until the waiting list is closed. Just email [email protected].

Legal basis: our legitimate interest in a secure, fast website and in knowing how it is used (Art. 6(1)(f) GDPR); for the join form, your request (Art. 6(1)(b) GDPR).

Who receives data

People in your circles see what you share in that circle: name, profile picture, your position while sharing is on, places, arrivals, snips, winks, ideas and trips. Blocked people see none of it.

Service providers who process data for us under a data processing agreement:

• Supabase (Supabase Pte. Ltd., Singapore): database, sign-in, file storage and error reports. Our project runs on servers in the EU (Ireland).
• Expo (650 Industries, Inc., USA): forwards notifications to Apple or Google and delivers app updates.
• PostHog (PostHog, Inc., USA): usage statistics of the app and of this website. Our data is stored on PostHog's EU servers (Frankfurt).
• Resend (Resend, Inc., USA): account emails.
• Google (Google Ireland Ltd. and Google LLC, USA): place search (Google Places API), maps on Android, “Sign in with Google”, notifications on Android.
• Vercel (Vercel Inc., USA): hosting of this website.
• Cloudflare (Cloudflare, Inc., USA): DNS, delivery and protection of this website, forwarding of emails to [email protected].

Apple provides maps and notifications on iPhone and “Sign in with Apple”. Apple and Google also run the App Store and Google Play; when you download Cozyo there, they process your data under their own responsibility.

We only pass on data to authorities when the law obliges us to.

Transfers outside the EU

Some of these providers are based in the USA or can access data from outside the EU. Such transfers are based on the EU-US Data Privacy Framework, where the provider is certified under it, and otherwise on the EU Standard Contractual Clauses (Art. 46(2)(c) GDPR). You can ask us for a copy of the relevant safeguards.

Deleting your account and exporting your data

Export: MORE → “Meine Daten exportieren” gives you a copy of what you created in Cozyo (profile, circles, places, ideas, trips, snip captions and replies) as a file. Do this before deleting your account if you want to keep anything.

Deletion: MORE → “Konto löschen” deletes your account immediately and permanently, together with your profile and profile picture, your location and location history, your arrivals, snips with their reactions and replies, winks, push tokens, the meetups you created, your circle memberships and everything in circles where you were the only member.

Content you created in a circle that still has other members stays there for them and is handed over to another member: shared places, trips with all their photos and Together ideas. That way the others keep their shared plans, and the content belongs to that member from then on. Please export or delete such content first if you want to take it with you.

You can leave a circle under MORE → “Kreise” → “Bearbeiten”. You can also request deletion by email to the address above.

Your rights

You have the right to access (Art. 15 GDPR), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18), data portability (Art. 20) and to object to processing based on legitimate interest (Art. 21). You can withdraw any consent at any time with effect for the future, for example in your phone's settings. You can also lodge a complaint with a data protection authority, for example the Hessian Commissioner for Data Protection and Freedom of Information (Hessischer Beauftragter für Datenschutz und Informationsfreiheit). For everything else, write to [email protected].

Minimum age

You must be at least 16 years old to use Cozyo. If we learn that someone younger has an account, we delete it.

Security and automated decisions

All connections are encrypted. In the database, access rules make sure that each person can only read what their circles may see. Cozyo makes no automated decisions about you and creates no profiles for advertising.

Changes

When Cozyo changes, we update this policy and the date at the top. We will let you know about important changes in good time, by email or in the app.