Privacy Policy

LunaCycle is built to be private and honest: your cycle and pregnancy data belong to you. They are stored in your account and used only to provide the app to you. When you scan an ovulation test, the photo is evaluated directly on your device and never leaves it. We never sell data, and we never use your health data for advertising. This page explains what we process and why.

1. Controller

Milena Marketing ltd., Alabin Street 33, 1000 Sofia, Bulgaria (VAT ID BG208676776), represented by managing director Milena Barton. For any privacy question, reach us via our contact form.

2. Data we process

On this website:

  • Server logs — our hosting provider (Render Services, Inc., USA) processes technically necessary data such as IP address, browser type and time of access to deliver and secure the site.
  • Contact form — if you write to us via the contact form, we process your name, e-mail address and the content of your message in order to answer your enquiry. Delivery is handled by the form service FormSubmit; the message is delivered to our e-mail inbox.
  • Analytics and advertising services — only with your consent, see section 4.

In the LunaCycle app:

  • Account & sign-in — your e-mail address and sign-in credentials are managed through Firebase Authentication (a service of Google Ireland Ltd. / Google LLC) so you can sign in securely.
  • Cycle & pregnancy data — your entries: period and cycle day, fertile window and ovulation, basal body temperature and cervical mucus, symptoms, mood and energy, the results of your ovulation tests, and — when your cycle becomes a pregnancy — your week of pregnancy, appointments and milestones. This is health data and therefore a special category of personal data (Art. 9 GDPR). It is stored in your account in Firebase (Cloud Firestore) so the app can calculate your patterns and predictions and sync your data across devices. We use it solely to provide the app to you — never for advertising, and we never sell it.
  • Ovulation test photo — when you scan a test strip with the camera, the photo is evaluated directly on your device. It is held in memory only, does not leave your device, and is neither uploaded nor sent to any third party or AI service. Only the result you confirm is saved.
  • Profile picture (optional) — if you add a profile picture, it is stored in Firebase Storage; only a reference to it is kept in your account. You can remove it at any time in the app.
  • Subscription — your subscription (including the 3-day free trial) is managed through RevenueCat, Inc. (USA) together with the Apple App Store or Google Play. These process the purchase and a pseudonymous app-user identifier to check your subscription status. Your payment details are processed solely by Apple or Google — we neither see nor store any card or bank details.
  • Device & usage — basic technical data that keeps the app stable.

3. Purposes and legal bases

We process data to provide the service — securing your account, storing and syncing your entries, calculating your predictions, managing your subscription and answering enquiries (Art. 6(1)(b) GDPR). Your cycle and pregnancy data is health data; we process it on the basis of your explicit consent (Art. 9(2)(a) GDPR), which you give by using the tracking features and can withdraw at any time by deleting the data or your account. In addition, we rely on our legitimate interest in a safe, working product (Art. 6(1)(f) GDPR). For analytics and advertising on this website we use data only with your consent (see section 4); we never sell it.

4. Cookies, analytics & advertising

We use analytics and marketing services to improve our website and measure the performance of our advertising:

  • Google Analytics 4 and Google Ads (Google Ireland Ltd., Ireland)
  • Meta Ads / Meta Pixel (Meta Platforms Ireland Ltd., Ireland)
  • TikTok Pixel / TikTok Ads (TikTok Technology Ltd., Ireland)

These services use cookies and similar technologies and process pseudonymised usage data (e.g. pages visited, device and browser information, advertising IDs, approximate location) to measure reach, build audiences and attribute conversions. Data may be transferred to the parent companies in the USA; such transfers are based on the EU Standard Contractual Clauses or the EU-U.S. Data Privacy Framework.

All of these services run only if you consent via the cookie banner (Art. 6(1)(a) GDPR, ePrivacy rules). Without consent they remain fully disabled. You can withdraw or adjust your consent at any time with effect for the future via the website's cookie settings.

5. Affiliate links

Product suggestions in the app (e.g. ovulation and pregnancy tests) may contain affiliate links (e.g. to Amazon). Only when you tap such a link does the respective provider's page open and process data under its own privacy policy; we may earn a commission — at no extra cost to you.

6. Recipients and international transfers

We share data only with service providers that help us operate the service and that are contractually bound to confidentiality: Google/Firebase (authentication, database and storage) for your account, your entries and any profile picture; RevenueCat and Apple or Google for handling your subscription; Render (USA) for website hosting; FormSubmit for delivering contact enquiries; and — only with your consent — the analytics and advertising partners listed in section 4. Your ovulation test photo is transmitted to no one. Where data is transferred to countries outside the EU/EEA (e.g. the USA), this happens on the basis of appropriate safeguards such as the EU Standard Contractual Clauses or the EU-U.S. Data Privacy Framework.

7. Retention

We keep personal data only as long as necessary for the purposes described. Your account data, your cycle and pregnancy entries and any profile picture are deleted when you delete your account; contact-form enquiries are deleted once they have been fully answered and no statutory retention obligations apply.

8. Your rights

You have the right of access (Art. 15 GDPR), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18), data portability (Art. 20) and objection (Art. 21). You may withdraw any consent at any time with effect for the future. You can also lodge a complaint with a data protection authority — in Bulgaria, the Commission for Personal Data Protection (CPDP, cpdp.bg).

Just use our contact form.

9. Health notice

LunaCycle is not a medical diagnostic tool or a method of contraception. All content and predictions are for information only and do not replace medical advice. Always consult a qualified professional for health-related questions.