How Primori handles personal and family data

1. Controller, audience and scope

Primori is operated by Mickael Lokhate. For privacy requests or questions, contact contact@mickaellokhate.fr. France, Alpes-Maritime.

This policy applies to the Primori iOS app, the related backend services and these public legal pages. Primori is intended for adults managing family memories. Children do not create independent Primori accounts. Growth tracking in Primori is informational only and does not constitute medical advice.

2. Data categories

• Account data, including Firebase Authentication identifiers, email address, display name, sign-in provider, anonymous onboarding status, account creation metadata and account deletion-job metadata.
• Child profile data, including names or nicknames, birth-related details you enter, family references and private profile metadata.
• Memory data, including notes, captions, milestones, photos, videos, audio, object keys, timestamps, uploader references and related metadata.
• Growth data, including height, weight, measurement dates and related notes.
• Collaboration data, including family memberships, invitation records, invitation email addresses, invitation status and role assignments.
• Subscription and billing-support data, including subscription plan, entitlement status, RevenueCat event identifiers and current period information received from Apple and RevenueCat.
• Technical, quota and security data, including signed URL issuance logs, upload reservation records, content type and file size checks, request logs and deletion job status.
• Limited analytics signals collected through TelemetryDeck for product reliability and usage measurement. These analytics must never include child names, birthdates, notes, media content or email addresses.

3. Family roles and permissions

Primori is designed around a single family-space owner account.

• One account owner controls the family space.
• Only the owner can invite, remove and manage collaborators.
• The owner and collaborators can view and add memories.
• Only the owner can create, edit or delete growth entries.
• Collaborators can view growth entries but cannot modify them.

4. Purposes and legal bases

• To provide the Primori service you request, including sign-in, private family collaboration, media upload flows and subscription-based access. Legal basis: performance of a contract or steps taken at your request before a contract.
• To secure the service, verify authorization, control costs, enforce quotas and investigate abuse. Legal basis: legitimate interests in service security, fraud prevention and infrastructure protection.
• To maintain subscription records, customer support and legally required accounting records. Legal basis: performance of a contract and compliance with legal obligations.
• To improve stability and product quality through limited analytics and operational monitoring. Legal basis: legitimate interests and, where required, consent.

5. Service providers and international transfers

Cloud Firestore (Google)

• Purpose: storage of user documents, child profiles, family memberships, invitations, growth entries, media metadata, subscriptions and account deletion-job records.
• Data categories: account data, child profile data, growth data, collaboration data, memory metadata, subscription records and deletion audit records.
• Configured processing region: europe-west9.

Cloudflare R2

• Purpose: private storage of media files and thumbnails.
• Data categories: photo, video and audio files, thumbnails, object keys, content type, file size and storage integrity metadata.
• Configured processing region: the backend currently sets R2_REGION=auto for the S3-compatible API: European Union (EU).

TelemetryDeck

• Purpose: privacy-focused analytics for reliability and feature usage.
• Data categories: app usage and performance signals only. Analytics must never contain child names, birthdates, notes, media content or email addresses.
• Configured processing region: Frankfurt, Germany.

OVHcloud

• Purpose: VPS use to host Primori's backend services and those legal pages.
• Data categories: No data save in OVHcloud.
• Configured processing region: Gravelines (GRA) - France.

Primori does not sell personal data, does not use advertising tracking, does not use cross-app tracking and does not expose private media through public URLs.

6. Retention schedule

The following retention periods must be completed with the final production decisions. Primori should not be released until these values are confirmed.

• Active account data: For the lifetime of the account
• Deleted account data: Deleted within 30 days
• Backups after deletion: No backup after deletion
• Failed or abandoned R2 uploads: 60 minutes.
• Technical and security logs: 90 days
• Invitation codes and expired invitations: Deleted when expired or after 30 days if unused
• Support communications: 2 years after the last interaction
• TelemetryDeck analytics signals: According to TelemetryDeck's configured retention policy
• Accounting and subscription records: 10 years

7. Your rights

Subject to applicable law, you may request access, rectification, deletion, restriction, portability or objection, and you may withdraw consent where processing relies on consent. You may also lodge a complaint with the CNIL or another competent supervisory authority.

To exercise your rights, contact contact@mickaellokhate.fr. Primori may request reasonable identity verification before acting on a request.

8. Security and deletion requests

Primori uses authenticated access controls, private object storage, signed media URLs, authorization checks and transport encryption to protect data. No service can eliminate all security risk, but Primori is built to avoid public media URLs and to minimize unnecessary access to family data.