Privacy Policy – COUCOU

Last update: 01/07/2025

This privacy policy outlines how your personal data (hereinafter "Personal Data") is collected, used, stored, and protected when using the COUCOU Mobile Application, published by the company COLD START, a simplified joint-stock company with a capital of €10,000, registered with the Lyon Trade and Companies Register under number 938 854 650, with its registered office located at 254 rue Vendôme, 69003 Lyon, represented by its president Mr. CALCADA (hereinafter "COLD START" or "we"), acting as the data controller.

1. Personal Data Processed

We collect personal data during your use of the application in three ways:

1.1 Data You Provide Directly

When creating and managing your account, certain information is required to access the core features of COUCOU:

  • Phone number
  • Email address
  • First name
  • Date of birth
  • City of residence
  • Gender
  • Relationship preferences
  • Profile photos (minimum of three required)
  • Biography
  • Hobbies and interests

You may also choose to complete your profile with optional data such as:

  • Sexual orientation
  • Occupation and education
  • Religion
  • Identity verification information via photo (see section 1.4)

1.2 Data Collected Automatically

When using the app, we automatically collect:

  • Usage data (swipes, likes, interactions, connections, preferences)
  • Technical information (IP address, device ID, operating system, language, geolocation)
  • Browsing statistics (crashes, errors, performance, anonymous advertising cookies)

1.3 Data from Third Parties

If you register via:

  • Google: name, first name, date of birth, email, gender
  • Apple: name, email

This data is used solely to facilitate account creation and authentication.

1.4 Photo Verification

To ensure the safety of our community, we offer (or require, for certain features) photo verification, which may involve biometric facial recognition analysis. The data collected is neither shared, displayed, nor used for any other purpose. It is stored securely and only used to validate future profile updates.

2. Purposes and Legal Bases of Processing

We use your data to:

2.1 Provide Our Services (Legal basis: contract execution)

  • Account creation and management
  • Matching and messaging
  • Managing preferences and profiles
  • Payments and subscriptions

2.2 Offer Relevant Profiles (Legal basis: contract)

Our algorithms recommend profiles based on your information, interactions, preferences, and geographic proximity.

2.3 Secure the Platform (Legal basis: legitimate interest)

  • Detect fraudulent accounts
  • Behavioral analysis to detect abuse
  • Monitoring reports

2.4 Marketing Campaigns and Experience Personalization (Legal basis: consent)

Subject to your consent, we use some of your data for marketing, audience measurement, and ad optimization purposes, including:

  • Personalizing content or advertising offers
  • Analyzing marketing campaign performance
  • Creating anonymized statistics
  • Attribution of conversions from advertisements

These operations are based on trackers or SDKs (see section 5 bis) and are activated only after your explicit consent via a pop-up when launching the app.

You may withdraw or modify your consent at any time in the "Privacy Settings" tab or by contacting us at contact@coucou-app.fr.

2.5 Fraud Prevention (Legal basis: legitimate interest & legal obligation)

We analyze profile data to prevent abuse, detect fake accounts, or bypassing bans.

2.6 Use Geolocation for Security Features (Legal basis: consent)

Certain app features, such as the Coucou Safe option, allow you to temporarily share your location with another user, particularly during dates. This feature is based exclusively on your explicit and voluntary consent.

Location data:

  • is collected only when the feature is activated;
  • is shared only with explicitly designated users;
  • is retained only as long as necessary for the feature to work, then automatically deleted;
  • is never used for commercial or advertising purposes.

You can enable or disable location access at any time via your device or app settings by going to the "Coucou Safe" tab then "my date is over".

2.7 Managing Consent for Cookies, Trackers, and SDKs

Before any non-essential cookies, trackers, or SDKs (advertising, analytics...) are activated, your consent is required. It is collected via a pop-up upon the app's first launch.

Types of trackers used include:

  • Analytical cookies: to measure audience and app performance
  • Advertising cookies or partner SDKs: to personalize ads or measure conversions
  • Technical cookies: required for app functionality (not subject to consent)

You may disable non-essential trackers at any time in the app's Privacy Settings.

Retention duration:

• Cookies and SDKs: up to 13 months

• Data from these trackers (anonymized statistics): up to 25 months

3. Data Retention Period

We retain your personal data only for as long as strictly necessary to fulfill the purposes described in section 2, then delete or anonymize it:

Data TypeRetention Period
Active accountUsage duration + 1 year
Inactive account (12 months)Deletion after 1 month
Banned account1 year active, then 1-year archive
Technical data (IP, logs...)Maximum 13 months
Cookies and trackers (SDKs)Maximum 13 months
Statistics from trackersMaximum 25 months
Legal or judicial dataAs per applicable law

After these periods, your data is irreversibly deleted or anonymized.

4. Underage Users

The use of COUCOU is strictly reserved for adults. If a minor registers fraudulently, we delete the account immediately upon detection or upon request from parents or legal guardians.

We reserve the right to temporarily retain certain technical data (e.g., device ID, IP address) for security purposes, especially to prevent fraudulent re-registration, within the limits authorized by law.

5. Sharing Your Data

Your data may be shared with:

  • Other app users (within limits you define)
  • Technical providers (hosting, maintenance)
  • Advertising partners
  • Judicial or administrative authorities when legally required

Our main partners include: Google, Apple, Adjust, Scalebay, RevenueCat, Digital Unicorn.

5 bis. Use of Advertising Trackers and SDKs

COUCOU uses tracking technologies similar to cookies, known as SDKs (Software Development Kits), integrated into the mobile app to measure and optimize app and ad campaign performance.

These trackers are provided by third parties and activated only after your consent. They do not directly identify you but may associate your device with certain pseudonymized actions.

Examples of SDKs used:

  • Adjust: ad conversion measurement, marketing attribution, fraud detection (partners
  • RevenueCat: secure management of in-app subscriptions and purchases

The data collected may include: advertising ID, anonymous usage data, app interactions, technical information (device model, language, OS version, etc.).

Consent:

  • Required and collected via a pop-up at first launch
  • Can be modified or withdrawn anytime via COUCOU's Privacy Settings

Retention:

  • SDKs and cookies: max 13 months
  • Data from SDKs: up to 25 months (statistical or pseudonymized)

🔗 Learn more:

6. Data Transfers Outside the EU

Some technical or pseudonymized data may be transferred to countries outside the European Union, notably the United States and Canada, via our technical partners:

  • Adjust (USA)
  • RevenueCat (USA)

These transfers are governed by:

• Standard Contractual Clauses (SCCs) approved by the European Commission

• Additional technical safeguards (encryption, pseudonymization, access control)

We ensure our partners provide a level of protection equivalent to that required by the GDPR.

7. Your Rights

In accordance with the GDPR, you have the following rights:

  • Access your data
  • Rectify inaccurate data
  • Erasure ("right to be forgotten") within legal limits
  • Object to certain processing, especially for marketing
  • Temporarily restrict processing
  • Data portability for information you provided
  • Post-mortem directives about your data after death

You may exercise your rights:

  • By email: contact@coucou-app.fr
  • Directly via the app settings
  • By mail: COLD START, 254 rue Vendôme, 69003 Lyon

We may request ID verification if there's doubt about your identity.

In case of dispute, you may file a complaint with the CNIL (www.cnil.fr). Please notify us beforehand.

8. Contact

For any questions regarding this privacy policy:

9. Deleting Your Account

You can delete your account at any time:

  1. Go to your profile
  2. Open Settings
  3. Select "Delete my account"
  4. Follow the confirmation steps

Your account and data will be deleted within the periods specified in section 3.

10. Reference Version

In the event of a discrepancy between the French version and a translation, the French version shall prevail.