1. Scope and controller
This Policy applies to Palio, including its shared bucket list, linked-couple space, messaging, mutual-friend features, Couples Square public feed, moderation tools, customer support, and related websites (collectively, the “Service”). Palio is the controller of personal data processed for the purposes described here. This Policy does not cover third-party services governed by their own privacy notices.
2. Personal data we collect
| Category | Examples | Source |
|---|---|---|
| Account and profile | Name or display name, username, email address, profile photo, age or date-of-birth confirmation, language, country or region, and account settings. | You; sign-in providers where selected. |
| Relationship and social graph | Partner-link status, invitation and connection records, mutual-friend connections, blocked users, and related preferences. | You and the users you connect with. |
| User content | Bucket-list entries, goals, milestones, captions, posts, comments, reactions, photos, videos, and other material you create or upload. | You. |
| Communications | Messages and their metadata, customer-support communications, reports, appeals, and safety-related correspondence. | You and other users. |
| Device and usage | IP address, device and app identifiers, operating system, app version, language, time zone, crash diagnostics, pages or features used, timestamps, and security logs. | Your device and the Service. |
| Approximate location | Country, region, or city inferred from IP address or device settings. Palio does not require precise location unless a feature clearly asks for permission first. | Your device and settings. |
| Purchases | Subscription status, transaction identifiers, and limited receipt information. Apple or Google processes payment-card details. | App stores and payment providers. |
| Moderation and safety | Reported content, reporter and reported-account identifiers, block records, enforcement history, and evidence needed to investigate abuse or security incidents. | You, other users, and Palio review systems. |
We may infer limited information needed to recommend content, detect abuse, protect accounts, or improve the Service. We do not intentionally collect government identifiers, financial account credentials, health records, or precise geolocation unless a clearly identified feature requires it and applicable notice or consent is provided.
3. How we use personal data
- Provide and operate accounts, partner linking, shared lists, messaging, mutual-friend connections, Couples Square, blocking, reporting, and customer support.
- Display content to the audience you select and personalize relevant product features.
- Authenticate users, maintain account integrity, prevent spam, fraud, harassment, unauthorized access, and other harmful activity.
- Review reports, enforce the Terms of Use and community rules, preserve evidence, and respond to appeals.
- Measure performance, fix errors, develop new features, and improve accessibility and reliability.
- Send service notices, safety alerts, account messages, and, where permitted, product communications that you can opt out of.
- Comply with law, valid legal process, regulatory obligations, and requests necessary to protect users or the public.
4. Legal bases
Where law requires a legal basis, Palio relies on: performance of our contract with you to provide the Service; legitimate interests in operating, securing, improving, and responsibly moderating Palio; consent where requested, including for optional device permissions or certain communications; and compliance with legal obligations. Where processing is based on consent, you may withdraw it at any time without affecting processing already completed.
5. Visibility and disclosure
Your audience choices
Couples Square posts, comments, profile elements, and interactions designated as public can be viewed, copied, or reshared by others. Linked-couple content is available to your connected partner. Messages and mutual-friend conversations are available to their participants. Removing content from Palio does not remove copies another person lawfully saved or shared outside the Service.
When we disclose data
- To your partner, mutual friends, conversation participants, or the public, according to the feature and audience you choose.
- To vendors that provide hosting, storage, content delivery, analytics, crash reporting, communications, customer support, safety, payment verification, and other operational services under contractual safeguards.
- To authorities or other parties when reasonably necessary to comply with law, protect rights and safety, investigate abuse, or enforce our agreements.
- In connection with a merger, financing, acquisition, reorganization, bankruptcy, or sale of assets, subject to applicable notice and legal protections.
Palio does not sell personal data for money. Palio does not use personal data for cross-context behavioral advertising. If these practices change, we will update this Policy and provide legally required choices before the change takes effect.
6. Service providers and app platforms
We use service providers only as necessary to operate the Service and require them to protect personal data and process it for authorized purposes. Apple, Google, sign-in providers, mobile operating systems, and external links may process information independently under their own terms and privacy policies. The data practices declared in App Store Connect and Google Play’s Data safety section must match the app’s actual code, SDKs, permissions, and backend behavior.
7. International data transfers
Palio is available internationally, so personal data may be processed in countries other than where you live. Where required, we use recognized transfer mechanisms and supplementary safeguards, such as adequacy decisions, standard contractual clauses, contractual protections, or consent. Local laws in a processing country may differ from those in your country.
8. Data retention and deletion
We retain personal data only for as long as needed to provide the Service, maintain security and moderation records, resolve disputes, meet legal obligations, and enforce agreements. Retention depends on the data type, account status, sensitivity, legal requirements, and risk of harm. When you delete your account, we delete or de-identify associated personal data unless retention is required for legal, fraud-prevention, safety, dispute, or backup purposes. Residual backup copies are isolated and removed through our ordinary backup cycle.
You may request account and data deletion through available in-app account controls or by emailing palio@gmail.com. Deleting the app from a device does not delete your account.
9. Security
We use administrative, technical, and organizational safeguards designed to protect personal data, including access controls, secure transmission, monitoring, and incident response. No method of storage or transmission is completely secure. Protect your credentials, review your post audience, and notify us promptly if you suspect unauthorized account activity.
10. Your privacy rights
Depending on your location, you may have rights to access, receive, correct, delete, or restrict personal data; object to certain processing; withdraw consent; obtain data portability; opt out of certain sales, sharing, targeted advertising, or profiling; and appeal a denied request. You may also have the right to complain to your local data-protection authority.
Submit a request through available in-app privacy controls or email palio@gmail.com. We may verify your identity and authority before completing a request. We will not discriminate against you for exercising a legal privacy right. Authorized agents may submit requests where local law allows, subject to verification.
11. Regional privacy notices
European Economic Area, United Kingdom, and Switzerland
You may exercise rights of access, rectification, erasure, restriction, objection, and portability, and may withdraw consent. You may lodge a complaint with the supervisory authority where you live, work, or believe an infringement occurred. Palio’s legal bases are described in Section 4.
California and other U.S. states
Subject to applicable thresholds and exceptions, residents may request to know, access, correct, or delete personal information and may opt out of sale, sharing, targeted advertising, or certain profiling. Palio does not sell personal information for money or share it for cross-context behavioral advertising. We do not knowingly use or disclose sensitive personal information for purposes requiring a right to limit under California law.
Brazil, China, and other jurisdictions
Where applicable, residents may request confirmation of processing, access, correction, deletion, information about recipients, withdrawal of consent, or other rights provided by local law. Cross-border processing is handled using legally recognized mechanisms where required.
12. Age requirements
Palio is intended only for people aged 18 or older and is not directed to children. We do not knowingly collect personal data from anyone under 18. If you believe a minor has used the Service or provided personal data, contact us so we can investigate and take appropriate action. Do not upload or publicly share another person’s information, image, or voice without appropriate authorization.
13. Changes to this Policy
We may update this Policy to reflect changes to the Service, law, or our practices. We will post the revised Policy with a new effective date and provide additional notice when required. Material changes apply prospectively unless law permits otherwise.
14. Contact Palio
For privacy questions, data requests, account deletion, or complaints, contact palio@gmail.com. Please include “Privacy Request” in the subject line and identify the country or region connected with your account so we can route your request appropriately.