LEGAL

Privacy Policy — ceya

Effective date: 10.09.2026 · Version: 1.0

At a glance

The short version, so you don't have to read everything:

We do not collect your location. No GPS, no coordinates. The city on your profile is text you typed yourself.

Nearby discovery doesn't reveal who you are. Your phone broadcasts a random, short-lived code over Bluetooth that changes regularly — not your name, not your user ID.

We don't sell your data. ceya has no ads, no ad networks, and no advertising trackers.

Analytics only if you say yes. Until you actively agree, not a single analytics event is collected.

You can delete your account yourself, at any time, from inside the app.

ceya is for adults only — 18 and over.

1. Who is responsible for your data

Aurora GmbH Geisenhausen 4 83250 Marquartstein Germany

Managing Director: Luca Kraus Privacy contact: privacy@aurora-creation.com

Aurora GmbH is the "controller" of your personal data under the General Data Protection Regulation (GDPR).

Data Protection Officer: We have not appointed a Data Protection Officer, as the conditions under Article 37 GDPR and § 38 of the German Federal Data Protection Act (BDSG) do not currently apply to us. For any privacy matter, contact us at the address above.

This policy covers the ceya mobile app (iOS and Android) and the servers behind it. Our website has its own separate privacy policy, which you'll find there.

2. Minimum age: ceya is 18+

ceya is for people aged 18 and over.

When you register, you must enter your date of birth. If it shows you are under 18, registration stops and no account is created. We store your date of birth so we can carry out and evidence this check.

If we learn that someone under 18 has circumvented the age check, we will suspend the account and delete the data. If you are a parent who believes your child has an account, write to privacy@aurora-creation.com and we will handle it.

Because ceya is adults-only, we do not knowingly process children's data. Rules such as COPPA (United States) or Article 8 GDPR on children's consent therefore do not apply.

3. What data we process

3.1 Data you give us

Email address, display name

Where it comes from
Registration

Date of birth and age

Where it comes from
Registration (age check)

Profile photo (avatar)

Where it comes from
Profile — optional

Short bio

Where it comes from
Profile — optional

Home city, as free text you type yourself (e.g. "Barcelona")

Where it comes from
Profile — optional

Workplace, university

Where it comes from
Profile — optional

Interests, languages

Where it comes from
Profile — optional

Posts, photos, videos, comments, likes

Where it comes from
Using the app

Reports about other users (reason + free text)

Where it comes from
Reporting function

Your invite code and who invited you

Where it comes from
Invite system

3.2 Data created automatically as you use ceya

Authentication identifiers and session data

Purpose
Keeping you signed in

IP address

Purpose
Technically unavoidable for any server request; held in server logs

Device and operating system information

Purpose
Troubleshooting and analytics

Your device's push token

Purpose
Delivering notifications

Notification history

Purpose
Showing it to you in the app

Short-lived Bluetooth tokens

Purpose
Nearby discovery (see section 4)

Your visibility and radar settings

Purpose
So the app behaves the way you want

3.3 Your connections

We store your friendships and connections. This social graph is the core of the app — without it, ceya cannot work.

3.4 What we do not collect

Stated plainly, so there's no ambiguity:

No GPS or location coordinates. Anywhere.

No phone number.

No payment data — ceya currently has no paid features.

No advertising IDs, no ad tracking, no ad networks.

No access to your contacts or address book.

4. How nearby discovery ("radar") works

This is the feature people quite reasonably look at most closely, so here is the detail.

The mechanism

Your device broadcasts a randomly generated, short-lived code over Bluetooth Low Energy (BLE) and simultaneously scans for codes broadcast by other ceya devices.

The important part: this code is not your user ID, your name, or any lasting identifier. It is random, it expires, and it is regularly replaced with a new one. Another device near you sees only a meaningless string.

For that code to become a person, the app has to ask our server — and the server checks whether your visibility settings allow the two of you to see each other at all. Without that check, nothing happens.

What this means for you

Someone intercepting Bluetooth traffic cannot use these codes to recognise you over time.

No movement profile is created. We don't store where you've been. We don't know.

No coordinates are transmitted or derived at any point.

The location permission on Android

Android itself requires apps to hold the "location" permission before they may scan for Bluetooth devices. That is Google's rule, not our choice.

We use this permission exclusively for Bluetooth scanning. Your position is never read, never stored, and never transmitted to us. There is no code in the app that requests location data.

On iOS no location permission is needed; nearby discovery there runs on the Bluetooth background modes.

Staying in control

You can switch nearby discovery off in the app at any time, and revoke the Bluetooth permission in your device settings. Radar then stops working — the rest of the app carries on.

6. Special categories of data — please think before you type

Some information is given extra protection under Article 9 GDPR: health, religion, political opinions, trade union membership, racial or ethnic origin, sexual orientation, and biometric data.

We do not ask for any of it and we do not want it.

But free text fields — your bio, your interests, the notes box on a report — will accept whatever you write. If you choose to put such information there, you are making it public yourself, and our processing then rests on Article 9(2)(e) GDPR.

Our advice: think carefully about what goes into a public profile. And when filing a report, please don't include sensitive information about other people unless it's genuinely relevant.

7. Who we share data with

We do not sell your data and we do not share it for advertising.

7.1 Processors acting on our behalf

These providers process personal data on our instructions. We have a data processing agreement in place with each of them under Article 28 GDPR.

Clerk (Clerk, Inc., USA)

What it does
Sign-in, account management, Google and Apple sign-in, account emails
Data it receives
Email, name, profile image, authentication identifiers, session and device metadata
Where processed
United States

Neon (Neon Inc.)

What it does
Our application database
Data it receives
Everything stored under section 3
Where processed
AWS eu-central-1, Frankfurt

Cloudflare R2 (Cloudflare, Inc.)

What it does
Storage for photos and video
Data it receives
Profile avatars, post media
Where processed
Western Europe

Fly.io

What it does
Running our servers
Data it receives
All API traffic, IP addresses
Where processed
Frankfurt (fra)

PostHog Cloud EU

What it does
Product analytics and error reporting — only with your consent
Data it receives
User ID, email, app events, device and OS metadata
Where processed
EU (eu.i.posthog.com)

Expo Push Notification Service (650 Industries, Inc., USA)

What it does
Delivering push notifications
Data it receives
Push tokens, notification content
Where processed
United States

7.2 Independent controllers

These companies decide for themselves how they handle the data, under their own privacy policies. They are not acting on our instructions:

Apple (Apple Distribution International Ltd., Ireland, for users in the EEA)

Context
App Store and TestFlight distribution, Sign in with Apple, Apple Push Notification service
Data involved
Apple ID (if you use Sign in with Apple), device push tokens

Google (Google LLC, USA)

Context
Google Sign-In, offered through Clerk
Data involved
Your Google account identity

Provider privacy notices: clerk.com/legal/privacy · neon.tech/privacy-policy · cloudflare.com/privacypolicy/ · fly.io/legal/privacy-policy · posthog.com/privacy · expo.dev/privacy · apple.com/legal/privacy · policies.google.com/privacy

We may also disclose data where the law requires it — for example under a court order or a lawful request from law enforcement.

8. Transfers to the United States

Some of the providers above process data in the United States. The US does not automatically offer a level of data protection equivalent to Europe's, and US authorities have access powers that EU residents can only challenge to a limited extent. We'd rather say that plainly than bury it.

We rely on two recognised transfer mechanisms:

Adequacy decision (Art. 45 GDPR) — EU-US Data Privacy Framework

These providers are certified with the US Department of Commerce under the EU-US Data Privacy Framework, for which the European Commission has found an adequate level of protection:

Clerk, Inc. — certified under the EU-US DPF, the UK Extension, and the Swiss-US DPF

Google LLC — certified under the EU-US DPF, the UK Extension, and the Swiss-US DPF

Standard Contractual Clauses (Art. 46(2)(c) GDPR)

For these providers, the European Commission's Standard Contractual Clauses apply:

650 Industries, Inc. (Expo) — Standard Contractual Clauses, Module Two (controller to processor)

Apple — for users in the EEA the controller is Apple Distribution International Limited in Ireland; Apple's onward transfers to the United States are governed by Standard Contractual Clauses

We will provide copies of the Standard Contractual Clauses on request at privacy@aurora-creation.com.

9. How long we keep data

Account and profile data

Retention
Until you delete your account

Posts, photos, videos, comments, likes

Retention
Until you delete them, or delete your account

Bluetooth tokens

Retention
Very briefly — they expire automatically and are replaced

Push tokens

Retention
Until account deletion, or until the token becomes invalid

Notification history

Retention
Until account deletion

Reports about users

Retention
12 months after the report is resolved, then anonymised

Server logs (Fly.io)

Retention
7 days

Database backups (Neon)

Retention
Deleted data remains technically restorable for 6 hours, after which it is gone

We deliberately keep reports longer than other data, including beyond account deletion. Otherwise someone could escape a ban simply by deleting their account and signing up again. This protects other users, and rests on our legitimate interest in a safe platform (Art. 6(1)(f) GDPR).

10. Your rights

Under the GDPR you have the following rights. Exercising them is free, and we respond within one month.

Access (Art. 15) — what data we hold about you

Rectification (Art. 16) — correcting inaccurate data

Erasure (Art. 17) — the "right to be forgotten"

Restriction of processing (Art. 18)

Data portability (Art. 20) — your data in a machine-readable format

Objection (Art. 21) — to processing based on legitimate interests

Withdrawal of consent (Art. 7(3)) — at any time, with effect for the future. What happened lawfully before your withdrawal is unaffected.

In practice:

Delete your account: in the app under Profile → Settings → Delete account, then confirm

Withdraw analytics consent: in the app under Profile → Settings → Analytics, then confirm turning them off

Turn off push notifications: in your device's system settings

Anything else: email privacy@aurora-creation.com

Right to complain

You can lodge a complaint with a data protection supervisory authority at any time. Ours is:

Bayerisches Landesamt für Datenschutzaufsicht (BayLDA) Promenade 18, 91522 Ansbach, Germany poststelle@lda.bayern.de

You may also complain to the authority where you live or work.

11. What happens when you delete your account

You can delete your account yourself at any time, under Profile → Settings → Delete account. You'll be asked to confirm once more.

Deletion is immediate and permanent. There is no recovery period. If you sign up again later, you start with an empty account.

Deleted:

  • your profile and everything on it,
  • your posts, comments and likes,
  • your uploaded photos and videos, including the underlying files in our object storage,
  • your friendships and connections,
  • your push tokens and notification history,

your sign-in account at Clerk.

Retained:

Reports you were involved in, for the 12 months set out in section 9.

Database backups still contain deleted data for up to 6 hours. After that it is gone from there too.

12. Security

We protect your data with measures including:

Encrypted transport (TLS) between the app and our servers

Encrypted credential storage on your device — via the iOS Keychain and the Android Keystore

Cryptographically secure random values for Bluetooth tokens

Access controls — only people who need data for their work can reach it

EU server locations for our database, object storage and application servers

Nobody can promise absolute security. If a breach occurs that poses a risk to you, we will notify you and the supervisory authority as required by Articles 33 and 34 GDPR.

13. Where ceya is available, and what that means for you

ceya is offered in the European Economic Area, the United States and Canada. Wherever you live, we apply the standard described in this policy to everyone.

United States. The California Consumer Privacy Act (CCPA/CPRA) applies to businesses above certain size thresholds, which Aurora GmbH does not currently meet. Regardless: we do not sell your personal information, we do not share it for cross-context behavioural advertising, and we receive no consideration for passing it on. Send access and deletion requests to privacy@aurora-creation.com and we will handle them exactly as described in section 10.

Canada. Under PIPEDA you have the right to know what data we hold about you and how we use it, and to have inaccurate data corrected. Complaints go to the Office of the Privacy Commissioner of Canada. Residents of Québec have additional rights under Law 25, including data portability; the person accountable for privacy at Aurora GmbH is the Managing Director, reachable at privacy@aurora-creation.com.

14. Changes to this policy

As ceya develops, this policy may change. We will tell you about significant changes in the app or by email before they take effect. The date at the top always shows the current version.

15. Contact

Questions, concerns, complaints — get in touch:

Aurora GmbH Geisenhausen 4, 83250 Marquartstein, Germany privacy@aurora-creation.com