MyNewLifePlan Privacy Policy

Version 1.0 · Effective 16 October 2026

MyNewLifePlan helps you plan your wedding preparations (tasks, lists, budget, guests, calendar). In this version no account is created and no data is sent to a server: your data stays on your phone only. This text explains in plain language where your data is, what is shared for the subscription and what rights you have. The privacy notice (GDPR Art. 13 / Turkish KVKK Art. 10) is a separate document.

1. In short

• No account, no server: your plan, lists, budget, guests and notes are stored on your phone only; they are not sent to our servers.
• The estimated date and preparation records you enter in the baby preparation feature (which can count as health-related information) are kept on your device only; they are not sent to our servers and not collected by us.
• Your country, tradition and religious ceremony choices and your religious tasks are also only on your phone (and in your own device backup, if on); not on our servers.
• Your name and your partner's name (for greetings and the couple name in Our story) are stored only on your device, not on our servers. You can change or delete them in Settings.
• If your phone's cloud backup (such as iCloud) is on, your app data, including religious and sensitive records, is included in that backup; the backup is in your own cloud account, not on our servers, and we have no access (section 8).
• We do not collect your location or advertising ID, and we use no advertising or analytics tools. We do not sell your data.
• For a Premium subscription, an anonymous random ID, the purchase status and technical information (IP address, device and app version) go to our subscription provider RevenueCat (possibly in the US); no email, name or plan content.
• Contacts, calendar and photo permissions are optional. We never read your calendar. From your contacts we take only the name (and, if you choose, the phone number) of the person you pick.
• You can export your data and delete all data on your device from within the app.

2. Controller

• Controller and provider of the service: DEEF S.R.L. (CUI 52002438, RO52002438; Registrul Comerțului J2025044081000) (address: Calea București Nr. 9, Tunari 077180, Ilfov, România). It applies to all users in Türkiye and in the EU/EEA.
• Contact: info@deeftech.com

The plan data you keep on your phone is not sent to us; you control it. The data we process as controller is subscription status and support correspondence.

3. What data do we process?

Data we do not collect: location, advertising ID, behavioral analytics, crash reports, calendar content, your whole address book, ID documents (the app has no ID document type; please do not upload ID cards, passports or driver's licenses).

If you send us an email (for example a honeymoon guide request or support), your email address and message are used only to reply to you; the app itself does not collect or send this information, it only opens your email app.

4. Why we process it and on what legal basis

The plan data on your phone serves the app's operation and is not sent to us. No processing in this version requires explicit consent (features such as sharing sensitive records are not in this version).

5. Phone permissions

• Contacts (optional): requested when you choose "Add from contacts". Only the name of the person you select (and their phone number if you tick it) is saved on your phone. If you decline, you can add guests by hand.
• Calendar (optional): to add an appointment to your phone calendar we use write-only access; your calendar is not read. Hiding the title is the default ("MyNewLifePlan appointment"). The entry is not updated from the app afterwards.
• Photos (optional): a photo you pick with the system picker is stored on the phone. Location (GPS) and device data (EXIF) are removed before saving.
• Notifications (optional): reminders are local notifications scheduled on your phone; their text is generic (no names, amounts, health or religion). We do not use remote push notifications.

6. Who do we share it with?

We do not sell your data or share it for advertising. Your plan data is shared with no one; only the following providers are used for the subscription and support:

We may disclose data to authorities where legally required.

7. Transfers outside your country

The anonymous subscription ID, purchase status and technical information (IP address, device and app version) go to our subscription provider RevenueCat (possibly in the US); this is a transfer outside the EU/EEA and outside Türkiye. The transfer relies on appropriate safeguards such as Standard Contractual Clauses (SCCs) or the EU-US Data Privacy Framework: Standard Contractual Clauses (SCCs) and/or the provider's EU-US Data Privacy Framework certification. Payment through the app store is under its own policies. Your plan data is not transferred abroad; it stays on your phone (and in your own device backup).

8. Backup and device loss

App data is stored on your phone. If your phone's cloud backup (such as iCloud) is on, the operating system backs up app data (including the database, the photos and documents you added, and religious and sensitive records) to your own cloud account. This backup is not on our servers, we have no access to it, and it is subject to the terms of your cloud provider. If you keep the backup on, you can restore your data on a new phone; turning it off or deleting it is your choice. Records on a phone that is not backed up or is lost cannot be recovered, so you can also use the export under "More > Account and data" as a backup.

9. Retention

To delete all data on the device: "More > Account and data > Delete data" (confirmed, irreversible). Uninstalling the app removes local data; if you have a backup, the backup copy stays in your own account and must be deleted separately. Deleting the app or the data does not cancel a subscription: cancel it in your app store account settings.

10. Security

Because your data is on your phone, protection depends largely on your device's security: use a screen lock and keep the operating system up to date. Subscription communication uses TLS. If a breach occurs, we notify the competent authority within the legal deadlines (GDPR/KVKK: 72 hours) and you where required.

11. Your rights

For data on your phone you exercise your rights directly in the app: export (JSON, CSV, Our Story pack) and deletion. For data we process as controller (subscription, support), write to info@deeftech.com; we reply within 30 days at the latest.

If you are in Türkiye (KVKK Art. 11): learn whether your data is processed; request information; learn the purpose and whether it is used accordingly; know the recipients; request correction; request erasure or destruction; ask that these actions be notified to third parties; object to an adverse result of automated analysis; claim compensation for unlawful processing. Complaints: Personal Data Protection Board (kvkk.gov.tr), after applying to the controller first.

If you are in the EU/EEA (GDPR Art. 15–22): access, rectification, erasure, restriction, portability, objection and withdrawal of consent. Complaints: ANSPDCP (Romanian Data Protection Authority, dataprotection.ro) or the supervisory authority in your country.

We do not make solely automated decisions or profile you.

12. Third parties (guests, gift givers, family)

You enter the names and, optionally, phone numbers of guests, gift givers and family; they stay on your phone and are not sent to us or to companies. Only the name is required. Use such information for personal planning only; informing these people, where needed, is your responsibility.

13. No account, shared household or sync

This version has no sign-in, account, partner/family invitations, shared household or cross-device sync. If such a feature is added, this policy will be updated, you will be informed in advance, and we will ask separately for any consent or confirmation needed.

14. Children

The app is for users aged 18 and over and is not directed at children.

15. Changes

For significant changes we notify you in the app. Earlier versions are available on request.

16. Contact

DEEF S.R.L. (CUI 52002438, RO52002438; Registrul Comerțului J2025044081000) · Calea București Nr. 9, Tunari 077180, Ilfov, România · info@deeftech.com

MyNewLifePlan Privacy Notice (GDPR Art. 13 / Turkish KVKK Art. 10)

Pursuant to Law No. 6698 (KVKK) Art. 10 and the Communiqué on Procedures for the Fulfillment of the Obligation to Inform, and Regulation (EU) 2016/679 (GDPR) Art. 13. Version 1.0 · Effective 16 October 2026. See the Privacy Policy for details. In this version there is no account and plan data is kept on your phone only.

1. Controller and contact

2. Data, purposes and legal bases

Data that stays on your phone only (plan, lists, budget, calendar, guest and gift records, country/tradition/religion choices, religious tasks, photo and document files, Our Story pack): not sent to a server and not processed by the controller. If your phone's cloud backup (such as iCloud) is on, the operating system backs this data up (including religious and sensitive records) to your own account; the backup is not on our servers (Policy section 8).

Data not collected: location, advertising ID, analytics/crash data, calendar content, whole address book, ID document images.

3. How data is collected

Subscription information via the store and the subscription provider; support correspondence directly from you. You do not need to give us personal data to use the core features; subscription and support are optional. No automated decision-making or profiling takes place.

If you send us an email (for example a honeymoon guide request or support), your email address and message are used only to reply to you; the app itself does not collect or send this information, it only opens your email app.

4. Recipients and transfers

Transfers abroad (KVKK Art. 9 / GDPR Art. 44 ff.): The transfer to RevenueCat (US) for users in the EU/EEA and Türkiye relies on safeguards such as SCCs / the EU-US Data Privacy Framework: Standard Contractual Clauses (SCCs) and/or the provider's EU-US Data Privacy Framework certification. Your plan data is not transferred abroad.

5. Retention

Data on your phone until you delete it. Subscription records for statutory retention periods; support correspondence 24 months after the request is closed. See Privacy Policy section 9.

6. Your rights

Türkiye (KVKK Art. 11): learn whether data is processed; request information; learn the purpose and proper use; know recipients; correction; erasure/destruction; notification of these actions to recipients; object to the result of automated analysis; claim compensation for unlawful processing.
EU/EEA (GDPR Art. 15–22): access, rectification, erasure, restriction, portability, objection, withdrawal of consent.

How to apply: info@deeftech.com. For data on your phone, export and deletion are in the app ("Account and data"). We reply within 30 days at the latest, normally free of charge.

Complaints: in Türkiye, the Personal Data Protection Board (after applying to the controller, Art. 13–14); in the EU/EEA, ANSPDCP (Romania, dataprotection.ro) or the supervisory authority of your country of residence.

7. Third parties

You enter guest, gift giver or family details yourself; they stay on your phone. Informing these people is your responsibility if you go beyond personal use.

8. Consent

No processing in this version requires explicit consent; this text is information only. If a feature that needs consent is added later, a separate, single-purpose, withdrawable consent text will be shown.

MyNewLifePlan Consent and Acknowledgement Texts

Version 1.0 · Effective 16 October 2026

This document lists every consent and acknowledgement point in the app. Consent is separate from the privacy notice. In this version no processing requires consent. The app has no marketing, advertising, profiling or analytics consent; we do not process data for those purposes.

Summary table

In this 1.0 "device only" version no processing relies on consent; features that need explicit consent (sharing sensitive records) and the household acknowledgement do not exist in this version (full texts: 1.1-cevrimici/). The texts below are information, permission explanations and confirmation screens.

R1. Operating system permission explanations (iOS Info.plist)

Not consent; they explain the purpose of the permission. If you decline, you use the function manually.

• Contacts: "Contacts are accessed so you can pick people to add to your guest list. Only the names you select are saved."
• Calendar (write-only): "If you choose, appointments can be added to your phone calendar. Only add access is used; existing calendar entries are not read."
• Photos: "Photos are accessed so you can attach a photo to a list item. Only the photo you select is saved."
• Notifications: local reminders; separate explanation on screen ("Notifications are turned off. You can enable them in Settings to get reminders; your entry was saved anyway.").

Additional in-app explanations: contacts screen "Only the people you select are saved (name only). Adding a phone number is optional."; calendar "Adding to the phone calendar happens once and is not updated automatically; use your phone calendar for changes. The app does not read your calendar."; photos "The photo is stored on this device only and is compressed." and a photo is not added if its location data cannot be removed.

R2. Choices that stay on the device

Shown in setup: "This choice is stored on this device (and in your device backup, if on) and is never sent to a server." and "Religious/sensitive tasks are kept on this device and in your device backup, not on a server." No consent is needed because we do not process this data.

R3. Our Story pack

"Names of guests and gift givers, time capsule letters and sensitive device-only records stay out unless you switch them on." The pack is created on the device and never sent to a server; once shared, the file is your responsibility.

R4. Deletion confirmations

• Delete data: "All records, documents, photos and scheduled reminders on this device will be permanently deleted. This cannot be undone. Events you added to your phone calendar are not deleted." → "Yes, delete everything".
• Delete a period: "This CANNOT be undone. Make sure the pack is saved somewhere safe." → "Yes, delete permanently".
• Subscription warning: "If you have an active subscription, deleting the app or its data does not cancel it. Cancel the subscription separately in your app store account settings."

R5. Subscription terms (paywall)

Not consent; this is the mandatory subscription information shown on the purchase screen (Apple 3.1.2).

"Payment is charged to your app store account at purchase confirmation. The subscription renews automatically at the same length and price unless cancelled at least 24 hours before the end of the current period; the renewal charge is applied within 24 hours before the period ends. You can manage or cancel the subscription in your store account settings after purchase. If a free trial is offered, the selected plan is charged unless you cancel before the trial ends."

"If your subscription ends, your data is not deleted; only Premium features are locked and you can still view your records."

Versioning

When a text changes, the release version (1.0) is increased. When a feature that needs consent is added (1.1), the version constants and the consent record come back into use (see 1.1-cevrimici/).