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.
1.1. 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:
At the current stage, the planned technical addresses are:
1.6. Depending on the user’s country of residence, different personal data protection laws may apply to the processing, including, where relevant:
1.7. If the mandatory laws of the user’s country provide a higher level of protection than this Policy, those mandatory laws apply.
2.1. ForeveL is intended solely for persons aged 18 or over.
2.2. The user confirms that:
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.
Depending on how the Platform is used, ForeveL may process the following categories of data.
3.1. Account data
The following may be processed:
3.2. Relationship data
The user may provide:
3.3. Messages and user content
ForeveL may process:
3.4. Potentially sensitive data
User content may contain information relating to:
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:
3.6. Purchase data
Once a paid subscription is launched, ForeveL may receive from the App Store or Google Play:
Under the planned architecture, full bank card details or other payment instrument details are not transmitted directly to ForeveL.
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:
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.
5.1. 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:
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.
ForeveL processes personal data for the following purposes:
7.1. Depending on the jurisdiction and the specific processing operation, ForeveL may rely on one or more of the following bases:
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.
8.1. ForeveL uses artificial-intelligence technologies for:
8.2. ForeveL currently uses OpenAI technologies.
8.3. The current architecture uses:
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.
9.1. 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.
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:
10.3. Google FCM
May be used for technical push notifications.
10.4. Gmail
User enquiries are handled through:
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:
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.
11.1. As of the publication date of this version:
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.
12.1. 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:
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:
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.
13.1. 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:
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.
14.1. 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:
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.
15.1. ForeveL takes reasonable technical and organisational measures to protect data.
15.2. Such measures may include:
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.
Depending on applicable law, the user may have the right to:
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.
17.1. ForeveL uses AI to analyse user content and generate recommendations.
17.2. AI results are probabilistic.
17.3. ForeveL does not guarantee:
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.
18.1. Certain AI features may classify signs of possible:
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:
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.
19.1. 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.
20.1. 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.
For questions about the processing of personal data:
FOREWEL, MCHJ
Republic of Uzbekistan, Tashkent, Mirabad district, Shakhrisabz street, building 3, apartment 2.
Email:
The user may submit a request regarding:
The Company may request additional information to verify the requester’s identity where necessary to protect personal data.
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.