Lucentay

Lucentay — Privacy Policy

DRAFT — NOT LEGAL ADVICE. Drafted by an AI assistant from the actual data Lucentay's codebase collects and stores, as a starting point for a lawyer's review. PIPEDA (Canada's federal private-sector privacy law) requires naming a real accountable person (see Section 9) and describing real practices accurately — several sections below are marked as needing a real answer, not a placeholder, before this is trustworthy to publish. Do not publish this until a lawyer has reviewed it and the bracketed items are resolved.

Last drafted: 19 August 2026 Effective date: [TO BE SET ON PUBLICATION]

1. Who we are

Lucentay ("we," "us," "our"), operated by Lucentay Inc. (Corporation No. 1817129-7), a corporation incorporated under the Canada Business Corporations Act (federal), operates the Lucentay mobile app, a halal matrimonial platform. This Privacy Policy explains what personal information we collect, why, how we use and protect it, and the choices available to you. It is intended to comply with Canada's Personal Information Protection and Electronic Documents Act (PIPEDA).

2. Information we collect

Account information: email address, phone number (optional), and a Firebase-issued authentication identifier. We do not currently store your password directly — authentication is handled by Firebase.

Profile information, all of which you provide directly: first and last name, date of birth, gender, city, province/state, country, marital status, whether you have children, whether you want children, your intended marriage timeline, willingness to relocate, and whether you are open to polygamy.

Religious information, which is sensitive personal information under Canadian privacy guidance and is treated with particular care: your madhab (school of Islamic jurisprudence), prayer frequency, hijab status (for women), whether you are a revert to Islam and the year of your reversion, and your self-assessed Qur'an and Arabic proficiency levels.

Background information: ethnicity, languages spoken, education level, profession, and income range (income range is optional and coarse-grained, not an exact figure).

About you: a free-text biography, what you are looking for in a spouse, and any dealbreakers you choose to share.

Photos: up to six profile photos, stored with a third-party image hosting provider (Cloudinary). You control whether your primary photo is visible only to your matches or more broadly within the app's Discover feature, via the "photos public" setting in your profile.

Verification data: if you choose to pursue identity verification, we work with Stripe Identity, a third-party provider, which may collect a government-issued ID and related biometric verification data directly — [CONFIRM EXACTLY WHAT STRIPE IDENTITY COLLECTS AND WHETHER LUCENTAY EVER RECEIVES OR STORES THE UNDERLYING DOCUMENT IMAGE, OR ONLY A VERIFIED/NOT-VERIFIED RESULT — THIS MATERIALLY CHANGES WHAT THIS SECTION SHOULD SAY AND WHAT SAFEGUARDS APPLY]. If you choose to pursue Imam Verification, we collect the name, email address, and mosque affiliation of a religious leader you name, and use this to send them a verification request by email.

Guardian (wali) information: if you choose to add a guardian, we collect that person's name, email address, phone number, and their relationship to you. This is personal information about someone who is not a Lucentay user and has not created an account or agreed to this Policy themselves — see Section 8 for how we handle this.

Messages: the content of messages you send to your matches, timestamps, and read status. Message content is scanned automatically by simple pattern-matching (not human review, and not AI analysis) to detect phrases suggesting an in-person meeting request, or the presence of an actual phone number, email address, or social media handle, in order to show you an in-app safety reminder. [CONFIRM: message content is not otherwise reviewed by staff except when a report is filed, or as needed to investigate abuse.]

Usage and device information: log data such as IP address, general error and request logs, and — if you enable notifications — a device push-notification token used solely to deliver notifications to your device.

Payment information: if and when Lucentay's paid tier becomes available with real payments, billing is handled by Stripe; [CONFIRM: Lucentay does not store full card numbers directly — only whatever token/customer ID Stripe provides.]

3. Why we collect this information

We use your information to: operate the matching and Discover features; enable messaging between matches; support the guardian and Imam Verification features you opt into; verify identity where you request it; respond to safety reports; send you service-related notifications (matches, messages, verification results); and improve the Service.

We do not use your religious information, or any other information you provide, to build advertising profiles, and [CONFIRM: Lucentay does not currently sell or rent personal information to third parties, and this Policy should say so explicitly once confirmed].

4. Who we share information with

Your matches: your profile information (subject to your photo-visibility setting), and any messages you send them.

Your named guardian, if you add one: notified by email that they have been named as your guardian, and — per the app's current design — able to view your active matches' profile information if they later access the guardian view. [CONFIRM CURRENT STATE: as of this draft, wali involvement is described as "soft, skippable" — this section should be updated if/when a wali is given a persistent login or more access.]

Your named imam, if you request verification: contacted by email with a request to confirm your standing in your local mosque community, and shown your name and mosque information in that request.

Service providers who process data on our behalf, currently: Firebase (authentication), Supabase (database hosting), Cloudinary (photo storage), Resend (transactional email delivery), Stripe (identity verification and, eventually, payments), Railway (application hosting), and Expo (push notification delivery, once enabled). [CONFIRM CURRENT DATA-PROCESSING/HOSTING REGIONS FOR EACH OF THESE — PIPEDA REQUIRES DISCLOSING IF PERSONAL INFORMATION IS PROCESSED OR STORED OUTSIDE CANADA, WHICH IS LIKELY TRUE FOR SEVERAL OF THESE US-BASED PROVIDERS, AND THIS MUST BE STATED EXPLICITLY, NOT OMITTED.]

Law enforcement or legal process, where required by law, or to protect the safety of a user or the public.

We do not sell your personal information.

5. Your choices and rights

Under PIPEDA, you generally have the right to access the personal information we hold about you, correct inaccurate information, and withdraw consent to certain uses (which may limit your ability to use parts of the Service). You may:

[FILL IN: current actual process and timeline for handling access/deletion requests — PIPEDA expects a response within a reasonable time (commonly interpreted as 30 days), and this should reflect a real, workable process, not an aspirational one.]

6. Data retention

[THIS SECTION IS CURRENTLY UNDEFINED IN THE APP AND NEEDS A REAL POLICY, NOT JUST LEGAL LANGUAGE. As of this draft: ended matches and their message history remain visible to both parties for a 7-day grace period, after which the app's behavior around message visibility going forward is not yet explicitly defined; deactivated accounts are marked inactive but their underlying data is not automatically deleted; there is no automatic data-deletion schedule implemented. Decide, and describe here: how long is personal information kept after account deactivation versus deletion, how long are photos retained after profile removal, and how long is data about a banned user retained to prevent re-registration under the same identity (an explicit open item in MILESTONES.md).]**

7. Security

We take reasonable steps to protect your information, including encrypted connections (HTTPS) between the app and our servers, authentication tokens verified server-side, and role-based access controls limiting who can view moderation and admin data. No system is completely secure, and we cannot guarantee absolute security. [ONCE THE SECURITY HOUSEKEEPING ITEMS IN MILESTONES.MD ARE DONE — ROTATING THE SUPABASE/FIREBASE/JWT SECRETS AND ENABLING 2FA ON CLOUDINARY — THIS SECTION CAN BE MADE MORE SPECIFIC IF DESIRED, THOUGH DETAILING EXACT SECURITY MEASURES PUBLICLY IS OPTIONAL AND SOME COMPANIES DELIBERATELY KEEP THIS HIGH-LEVEL.]

8. A note on third parties who are not Lucentay users

Because you can name a guardian or an imam who has never created a Lucentay account or agreed to this Policy, we collect their name and contact information based on your representation that you have their permission to do so. [THIS IS A REAL PIPEDA CONSIDERATION WORTH DISCUSSING WITH A LAWYER: PIPEDA GENERALLY REQUIRES MEANINGFUL CONSENT FROM THE INDIVIDUAL WHOSE INFORMATION IS COLLECTED, NOT JUST FROM THE USER SUBMITTING IT ON THEIR BEHALF. CONSIDER WHETHER GUARDIANS/IMAMS SHOULD RECEIVE A DIRECT NOTICE — WHICH THE APP ALREADY DOES VIA THE INVITATION/REQUEST EMAILS — EXPLAINING WHAT INFORMATION WAS SHARED ABOUT THEM AND HOW TO HAVE IT REMOVED IF THEY OBJECT.]

9. Privacy Officer

PIPEDA requires that an organization designate someone accountable for privacy compliance. [NAME A REAL PERSON AND CONTACT METHOD HERE — LISTED AS AN OPEN "BEFORE LAUNCH" ITEM IN MILESTONES.MD. THIS CANNOT BE A PLACEHOLDER AT LAUNCH; PIPEDA COMPLIANCE ACTUALLY REQUIRES THIS ROLE TO EXIST, NOT JUST BE NAMED IN A DOCUMENT.]

10. Children's privacy

Lucentay is not intended for use by anyone under [MINIMUM AGE], and we do not knowingly collect information from anyone under that age. [NOTE: AS OF THIS DRAFT, THE SIGNUP FLOW DOES NOT TECHNICALLY VALIDATE AGE FROM DATE OF BIRTH — THIS IS A GAP BETWEEN POLICY AND PRACTICE THAT SHOULD BE CLOSED IN THE APP, NOT JUST STATED HERE.]

11. Changes to this Policy

[DEFINE NOTICE MECHANISM FOR CHANGES, SAME AS TERMS OF SERVICE.]

12. Contact us

Questions about this Privacy Policy, or requests to access, correct, or delete your information, can be sent to [PRIVACY CONTACT EMAIL].

End of draft. Sections 6, 8, and 9 describe real gaps between current practice and what PIPEDA expects — these need real decisions and, in the case of Section 9, a real person, before this document can be honestly published.