Privacy Policy

ForeveL · FOREWEL, MCHJ · updated 7 October 2026

This is an English translation of the Privacy Policy provided for convenience. The legally binding version is the Russian text. In case of any discrepancy between the two, the Russian version prevails.

1. GENERAL PROVISIONS

1.1. This Privacy and Personal Data Processing Policy (the “Policy”) sets out how personal data of users of the ForeveL digital platform (the “Platform”) is collected, used, stored, protected, transferred and deleted.

1.2. The personal data controller is:

FOREWEL, MCHJ (limited liability company), registered in the Republic of Uzbekistan.

Registered address:

Republic of Uzbekistan, Tashkent, Mirabad district, Shakhrisabz street, building 3, apartment 2.

Hereinafter — “ForeveL”, the “Company”, the “Controller” or “we”.

1.3. ForeveL is a digital technology platform that gives users access to software tools and artificial-intelligence features for informational and advisory support in the area of relationships, communication and emotional well-being.

1.4. ForeveL is not a medical, psychological, psychotherapeutic, legal or other professional advisory organisation, unless expressly stated otherwise for a specific service.

1.5. This Policy applies to information processed through:

  • the ForeveL mobile application;
  • the ForeveL website and web interfaces;
  • the ForeveL API and server infrastructure;
  • administrative interfaces;
  • other digital services owned or controlled by ForeveL.

At the current stage, the planned technical addresses are:

  • forevel.uz — website and administration panel;
  • api.forevel.uz — API;
  • com.forevel — mobile application package identifier.

1.6. Depending on the user’s country of residence, different personal data protection laws may apply to the processing, including, where relevant:

  • the legislation of the Republic of Uzbekistan;
  • the GDPR;
  • the UK GDPR;
  • the personal data protection laws of individual states;
  • the CCPA/CPRA and other applicable United States laws;
  • other mandatory rules of the user’s country of residence.

1.7. If the mandatory laws of the user’s country provide a higher level of protection than this Policy, those mandatory laws apply.

2. AGE RESTRICTIONS

2.1. ForeveL is intended solely for persons aged 18 or over.

2.2. The user confirms that:

  • they are at least 18 years old;
  • they have the necessary legal capacity;
  • the information they provide is accurate;
  • their use of the Platform does not violate the laws of their country of residence.

2.3. Persons under 18 may not create an account or use the Platform.

2.4. If the laws of the user’s country of residence set a higher minimum age for using the relevant digital services, entering into a contract or giving consent to the processing of personal data, that higher age threshold applies.

2.5. If ForeveL receives reliable information that an account belongs to a person below the applicable minimum age, the Company may suspend or delete that account.

3. WHAT DATA WE MAY PROCESS

Depending on how the Platform is used, ForeveL may process the following categories of data.

3.1. Account data

The following may be processed:

  • name or display name;
  • email address, if provided;
  • user identifier;
  • password or authentication data in protected form;
  • avatar;
  • account settings;
  • technical identifiers.

3.2. Relationship data

The user may provide:

  • the date the relationship began;
  • information about their partner;
  • information about the relationship;
  • questionnaire answers;
  • relationship ratings;
  • information about conflicts;
  • emotional assessments;
  • notes;
  • exercise results;
  • other information the user voluntarily enters into the Platform.

3.3. Messages and user content

ForeveL may process:

  • chat messages;
  • texts;
  • notes;
  • answers to questions;
  • questionnaire results;
  • photographs;
  • uploaded materials;
  • other materials the user voluntarily provides to the Platform.

3.4. Potentially sensitive data

User content may contain information relating to:

  • physical or mental health;
  • sex life;
  • sexual orientation;
  • emotional state;
  • violence;
  • conflicts;
  • crisis situations;
  • suicidal thoughts;
  • other categories of data that some jurisdictions treat as special or sensitive categories of personal data.

ForeveL does not require the user to provide such information in order to use all features of the Platform; however, certain features may use it if the user voluntarily provides the relevant information.

3.5. Technical data

The following may be processed:

  • IP address;
  • device information;
  • operating system;
  • application version;
  • technical identifiers;
  • session data;
  • date and time of use;
  • technical logs;
  • crash information;
  • information required to ensure security.

3.6. Purchase data

Once a paid subscription is launched, ForeveL may receive from the App Store or Google Play:

  • purchase identifier;
  • transaction identifier;
  • the product purchased;
  • the store;
  • subscription status;
  • validity period;
  • purchase verification result.

Under the planned architecture, full bank card details or other payment instrument details are not transmitted directly to ForeveL.

4. DATA OF AN UNREGISTERED PARTNER

4.1. ForeveL may receive and process information about a person who is not themselves registered on the Platform.

4.2. Such information may appear, for example, when a registered user:

  • enters the date the relationship began;
  • describes their partner in a questionnaire;
  • writes about their partner in the chat;
  • provides notes;
  • uploads materials;
  • uses relationship analysis features.

4.3. ForeveL does not access the user’s phone contacts and does not automatically read the phone’s address book.

4.4. A partner is connected by means of a six-digit code provided by the user.

4.5. The partner’s name appears after the partner creates their own account.

4.6. The user must not provide personal data of another person through ForeveL without a lawful basis for doing so, especially where sensitive data is concerned.

4.7. If the user provides information about another person, the user is responsible for the lawfulness of doing so to the extent provided by applicable law.

4.8. ForeveL may restrict processing, delete, anonymise or otherwise change access to information about a third party if the Company receives a justified request or concludes that there are legal grounds to stop such processing.

4.9. A person whose information was provided by another user may contact ForeveL regarding the processing of their personal data.

4.10. Depending on applicable law, ForeveL may require the requester to verify their identity and may provide only such data or take only such measures as the law allows.

5. SEPARATE PARTNER ACCOUNTS

5.1. ForeveL does not use a single shared account for a couple.

5.2. Each partner has a separate account and separate access.

5.3. A “couple” is a separate digital entity that links two user accounts.

5.4. Within a couple, the following may be processed jointly:

  • chat;
  • moments;
  • activities;
  • results of certain questionnaires;
  • shared materials;
  • AI analyses;
  • other data specifically intended for shared use.

5.5. Deletion of an account by one partner may result in deletion of the couple entity and the shared data, in accordance with ForeveL’s technical architecture.

5.6. The other partner’s account is retained and is unlinked from the deleted couple.

6. PURPOSES OF PROCESSING

ForeveL processes personal data for the following purposes:

  • creating and maintaining the account;
  • providing the Platform’s features;
  • linking partners;
  • operating shared features;
  • processing questionnaires;
  • generating personalised recommendations;
  • AI analysis of user content;
  • communication analysis;
  • generating relationship recommendations;
  • identifying possible points of tension;
  • generating advice;
  • operating crisis classification;
  • ensuring security;
  • preventing abuse;
  • technical support;
  • error diagnostics;
  • performing the user agreement;
  • processing payments and subscriptions once those features are launched;
  • complying with legal obligations;
  • protecting ForeveL’s rights and legitimate interests;
  • resolving disputes;
  • ensuring information security;
  • improving the technical operation of the Platform within the limits of applicable law.

7. LEGAL BASES FOR PROCESSING

7.1. Depending on the jurisdiction and the specific processing operation, ForeveL may rely on one or more of the following bases:

  • performance of a contract;
  • steps taken prior to entering into a contract;
  • the user’s consent;
  • compliance with a legal obligation;
  • protection of vital interests;
  • the legitimate interests of ForeveL or a third party, where such interests are not overridden by the user’s rights and freedoms;
  • another basis provided by applicable law.

7.2. For the processing of special categories of personal data in jurisdictions that require an additional legal basis, ForeveL relies on the relevant additional basis provided by applicable law.

7.3. Where a specific processing operation requires separate consent, ForeveL requests such consent in an appropriate manner.

7.4. The user may withdraw consent where processing is based on consent. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

7.5. Withdrawal of consent may make certain features of the Platform unavailable.

8. ARTIFICIAL INTELLIGENCE

8.1. ForeveL uses artificial-intelligence technologies for:

  • analysing conversations;
  • identifying possible points of tension;
  • generating the tip of the day;
  • crisis classification;
  • analysing user answers;
  • generating individual recommendations;
  • the full ForeveL+ analysis;
  • other features.

8.2. ForeveL currently uses OpenAI technologies.

8.3. The current architecture uses:

  • gpt-5.4-mini — for conversation analysis, points of tension, the tip of the day and crisis classification;
  • gpt-5.6-luna — for the full ForeveL+ analysis.

8.4. ForeveL may use other AI technology providers in the future. In that case this Policy may be updated.

8.5. For AI features to work, certain user content may be transmitted to the relevant AI provider.

8.6. To build the AI context, ForeveL’s current architecture uses the tips from the last 14 days and the last 30 chat messages. This limit refers to the amount of context transmitted for a specific AI operation and is not the general retention period for data in the ForeveL database.

9. DATA PROCESSING BY OPENAI

9.1. For certain ForeveL features to work, user content may be transmitted to OpenAI.

9.2. In ForeveL’s OpenAI organisation, the data-sharing settings for feedback, evaluation/fine-tuning and the use of API inputs/outputs for training are set to Disabled, to the extent reflected in ForeveL’s current configuration.

9.3. ForeveL does not conclude from this that data can never be stored by the provider for other purposes provided for by its terms and technical mechanisms.

9.4. In particular, Zero Data Retention (ZDR) is not enabled in the current configuration.

9.5. Therefore, certain request and response data may be processed by the provider under its abuse-monitoring and safety mechanisms.

9.6. According to the information currently available to ForeveL, the potential retention period of the relevant abuse-monitoring logs may be up to 30 days, unless the provider’s applicable terms or settings provide otherwise.

9.7. ForeveL does not state that data is “never stored by OpenAI”, because not using data for training does not mean the absence of any technical storage.

9.8. ForeveL may change AI providers, configuration, models and technical processing mechanisms, provided that applicable law is complied with and the disclosed information is updated where required.

10. PROVIDERS AND THIRD PARTIES

Depending on the specific feature, data may be processed using:

10.1. OpenAI

Used for certain AI features.

10.2. “SUVAN NET” LLC

ForeveL’s current infrastructure is hosted on a VPS in Tashkent, Republic of Uzbekistan.

The VPS hosts, in particular:

  • the API;
  • PostgreSQL;
  • file storage.

10.3. Google FCM

May be used for technical push notifications.

10.4. Gmail

User enquiries are handled through:

info@forevel.uz

At the current stage this is a free Gmail account, not Google Workspace and not corporate email on our own domain.

10.5. App Store and Google Play

Once the subscription is launched, the respective stores may process payment data and provide ForeveL with information about the purchase status.

10.6. Future services

ForeveL may in the future use:

  • Firebase Analytics;
  • Firebase Crashlytics;
  • email services;
  • analytics services;
  • attribution services;
  • advertising services;
  • other technology services.

Before connecting such services, ForeveL must determine the relevant data categories, purposes, legal bases, international transfers and the necessary consent mechanisms in accordance with applicable law.

11. ANALYTICS, ADVERTISING AND CRASH REPORTING

11.1. As of the publication date of this version:

  • Firebase Analytics is not used;
  • Firebase Crashlytics is not used;
  • advertising SDKs are not used;
  • there is no banner advertising;
  • there is no interstitial advertising;
  • the IDFA and Advertising ID are not requested.

11.2. ForeveL may introduce analytics, crash reporting or advertising in the future.

11.3. Before launching such mechanisms, ForeveL determines the necessary notices, consents, privacy settings and opt-out mechanisms where required by law.

12. DATA STORAGE

12.1. ForeveL’s primary storage is currently located in Uzbekistan.

12.2. The primary data is hosted on a VPS in Tashkent.

12.3. Data of an active account and an active couple is stored until:

  • the account is deleted;
  • the relevant item is deleted;
  • the couple relationship is ended;
  • or another established period expires.

12.4. Sessions are stored for 180 days of inactivity. The period is rolling and may be extended by activity.

12.5. The archive of a dissolved couple and its shared data is stored for up to 6 months, after which it is deleted in accordance with the technical procedure.

12.6. PostgreSQL backups:

  • 7 daily;
  • 4 weekly;
  • 3 monthly.

12.7. The last 14 exported database dumps may be kept on a work Mac.

12.8. Uploads and private photographs are archived weekly; the two most recent archives of each kind are kept.

12.9. After data is deleted from the production database, copies may temporarily remain in previously created backups until their scheduled rotation.

12.10. ForeveL does not guarantee the immediate physical destruction of every backup at the moment data is deleted from the primary database where this is technically impossible or conflicts with mandatory retention requirements.

13. ACCOUNT DELETION

13.1. The user may initiate deletion of their account directly in the application.

13.2. The technical deletion operation triggers the account deletion procedure.

13.3. The procedure may delete:

  • the account;
  • related records;
  • sessions;
  • the avatar;
  • private photographs;
  • other data subject to deletion.

13.4. If the user is in a couple, deletion may result in deletion of the couple entity and the shared data.

13.5. The other partner’s account is retained but is unlinked from the couple.

13.6. Backups may retain deleted data until their scheduled rotation.

14. INTERNATIONAL DATA TRANSFERS

14.1. The user understands that ForeveL is an international digital platform and certain processing operations may take place outside the user’s country of residence.

14.2. In particular, user content may be transmitted to technology providers located in, or processing data in, other countries.

14.3. Depending on applicable law, ForeveL uses the international data transfer mechanisms provided by law.

14.4. Such mechanisms may include:

  • an adequacy decision;
  • standard contractual clauses;
  • the UK IDTA/Addendum;
  • other contractual safeguards provided by law;
  • specific derogations provided by law;
  • other lawful mechanisms.

14.5. The specific mechanism is determined for each transfer with regard to applicable law and the actual data route.

14.6. ForeveL may carry out international transfer risk assessments and take additional technical and organisational measures.

14.7. The user understands that the laws of the recipient country may differ from the laws of the user’s country of residence.

15. SECURITY

15.1. ForeveL takes reasonable technical and organisational measures to protect data.

15.2. Such measures may include:

  • access control;
  • authentication;
  • separation of privileges;
  • secure connections;
  • backups;
  • restricting access by employees and contractors;
  • security monitoring;
  • deletion procedures;
  • technical protection of the server infrastructure.

15.3. Despite the measures taken, no method of storing or transmitting data over the Internet can guarantee absolute security.

15.4. The user is responsible for keeping their login credentials safe.

16. USERS’ RIGHTS

Depending on applicable law, the user may have the right to:

  • obtain information about the processing of their data;
  • obtain a copy of their data;
  • correct inaccurate data;
  • request deletion;
  • restrict processing;
  • object to processing;
  • withdraw consent;
  • receive their data in a portable format;
  • object to certain types of automated processing;
  • limit the use of sensitive data;
  • lodge a complaint with a supervisory authority.

For users covered by the CCPA/CPRA, the relevant rights may include the right to know, to delete, to correct, to opt out of the sale/sharing of data, to limit the use of sensitive information, and other rights provided by law.

ForeveL does not sell users’ personal data under its current business model.

17. AUTOMATED ANALYSIS

17.1. ForeveL uses AI to analyse user content and generate recommendations.

17.2. AI results are probabilistic.

17.3. ForeveL does not guarantee:

  • absolute accuracy;
  • completeness;
  • currency;
  • objectivity;
  • the absence of errors;
  • the suitability of AI output for a specific situation.

17.4. AI analysis must not be treated as a medical, psychological, psychotherapeutic or legal diagnosis.

17.5. Where applicable law grants the user specific rights in relation to automated decision-making, ForeveL provides those rights to the extent required by law.

18. CRISIS SITUATIONS

18.1. Certain AI features may classify signs of possible:

  • violence;
  • threats;
  • suicidal thoughts;
  • a crisis situation;
  • another potentially dangerous situation.

18.2. Such classification is an automated probabilistic assessment and is not a medical or psychological diagnosis.

18.3. ForeveL does not guarantee that the system will:

  • detect every crisis situation;
  • classify it correctly;
  • determine the degree of danger;
  • prevent negative consequences.

18.4. The user must not use ForeveL as a substitute for emergency services, a doctor, a psychologist, a psychotherapist, a lawyer or another professional.

18.5. In the event of an immediate threat to life or safety, the user must contact the appropriate emergency services in their country.

19. COOKIES AND SIMILAR TECHNOLOGIES

19.1. The web version of ForeveL may use technically necessary cookies and similar technologies.

19.2. If analytics, advertising or other optional technologies are used in the future, ForeveL will provide the relevant notices and consent/opt-out mechanisms where required by law.

20. CHANGES TO THE POLICY

20.1. ForeveL may amend this Policy.

20.2. In the event of material changes, the Company may notify users through the Platform or by other reasonable means.

20.3. The date of the last update is indicated at the beginning of the Policy.

20.4. Continued use of the Platform after the changes take effect constitutes acknowledgement of the new version, to the extent permitted by law.

21. CONTACTS

For questions about the processing of personal data:

FOREWEL, MCHJ

Republic of Uzbekistan, Tashkent, Mirabad district, Shakhrisabz street, building 3, apartment 2.

Email:

info@forevel.uz

The user may submit a request regarding:

  • access to data;
  • deletion;
  • correction;
  • restriction of processing;
  • objection;
  • withdrawal of consent;
  • other privacy matters.

The Company may request additional information to verify the requester’s identity where necessary to protect personal data.

22. GOVERNING LAW

22.1. This Policy is interpreted in accordance with the laws of the Republic of Uzbekistan and the mandatory laws of the user’s country of residence.

22.2. Nothing in this Policy limits the user’s rights that cannot be limited by contract under applicable law.

ForeveL — Privacy Policy