Privacy Policy
1. Introduction
CoVœur places fundamental importance on protecting your personal data. This Privacy Policy describes how we collect, use, store, and protect your data when you use the CoVœur Service, available via WhatsApp and the website www.covoeur.com.
This policy complies with the General Data Protection Regulation (GDPR — EU Regulation 2016/679) and the amended French Data Protection Act.
2. Data controller
The data controller is NOproBS, a SASU with share capital of €1,000, RCS Paris 984 241 075, registered office in Paris, France. Contact: contact form
3. Data collected
CoVœur only collects data that you voluntarily provide when using the Service:
- Identifier: your WhatsApp phone number
- First name: provided during onboarding to personalize your experience
- Gender: inferred automatically from your first name, mentions, or grammatical agreements in your messages — never asked for directly
- Relationship status: single or in a relationship, communicated during onboarding
- Questionnaire responses: your answers to the relational self-assessment questionnaire
- Relationship context: information you choose to share about your relationship
- WhatsApp conversations: only if you explicitly consent, with double consent with your partner
- Usage data: history of interactions with the Service (via WhatsApp)
We do not collect special categories of data (health data, ethnic origins, religious or political beliefs) within the strict meaning of the GDPR.
4. Legal bases for processing
| Purpose | Legal basis |
|---|---|
| Provision of the Service (assessments, analyses, programs) | Performance of a contract (Art. 6(1)(b) GDPR) |
| Analysis of WhatsApp conversations | Explicit consent (Art. 6(1)(a) GDPR) |
| Service improvement | Legitimate interest (Art. 6(1)(f) GDPR) |
| Compliance with legal obligations | Legal obligation (Art. 6(1)(c) GDPR) |
5. How we use data
Your data is used exclusively to:
- Generate your personalized Relational Profile (individual assessment)
- Produce the combined Couple Assessment (if you and your partner consent)
- Personalize your coaching journey and programs
- Send you exercises, reminders, and check-ins via WhatsApp
- Improve the quality of the CoVœur Service
Your data is never sold, shared, or transferred to third parties for commercial purposes.
6. Analysis of WhatsApp conversations
If you choose to share a WhatsApp conversation for analysis:
- Consent from both partners is required before any processing
- The conversation is anonymized before processing: first names, addresses, and phone numbers are replaced by neutral identifiers (Partner A / Partner B, [CITY], [NUMBER]…)
- Anonymization is performed in memory (RAM) on our servers, right before sending it to the AI model. The raw (non-anonymized) version of your conversation is not durably stored on disk: only the anonymized version may be retained as needed for the analysis.
- The analysis is performed by an AI model (Azure OpenAI, Microsoft — hosted in France) in accordance with their terms of use, and only receives the anonymized version
- Raw (non-anonymized) data is not retained after analysis
7. Processors and recipients
CoVœur uses the following processors, with GDPR-compliant data processing agreements in place:
| Processor | Role | Location |
|---|---|---|
| Microsoft Azure OpenAI | AI-generated analyses and reports (GPT-4o / GPT-5) | France and Switzerland (European Union) — GDPR DPA |
| Meta (WhatsApp Business API) | Messaging infrastructure for WhatsApp | Ireland (European Union) — GDPR DPA |
| Microsoft Azure | Hosting of the backend and data | France (France Central region) — GDPR DPA |
| Stripe | Payment processing (subscriptions and purchases) | Ireland (European Union) — GDPR DPA |
| CoVœur lead therapist | Review and validation of individual and couple assessments before delivery | France — anonymized access to generated reports for control and to conversations with CoVœur for analysis |
No other third party has access to your personal data.
8. Data retention
Your data is retained for the following durations:
- Profile data and questionnaire responses: as long as needed to provide the Service, then deletion upon request
- WhatsApp conversations submitted for analysis: kept in anonymized form after analysis
- Coaching conversation history: up to 12 months
- Therapist files (notes and conversation summaries): duration of Service use + 12 months, then deletion upon request
- Interaction history: 30 days (raw messages); coaching summaries: duration of Service use
- Billing data (where applicable): 10 years (statutory accounting obligation)
You can request the deletion of your data at any time by contacting us via WhatsApp.
9. Your rights (GDPR)
In accordance with the GDPR, you have the following rights:
- Right of access: obtain a copy of your personal data being processed
- Right to rectification: correct inaccurate or incomplete data
- Right to erasure: obtain the deletion of your data ("right to be forgotten")
- Right to data portability: receive your data in a structured, machine-readable format
- Right to object: object to the processing of your data for legitimate interest purposes
- Right to withdraw consent: withdraw your consent at any time for processing based on it
- Right to restriction: request the suspension of processing in certain cases
To exercise these rights, contact us via our contact form. We commit to responding within one month.
You also have the right to lodge a complaint with the CNIL (Commission Nationale de l'Informatique et des Libertés): www.cnil.fr.
10. Data security
CoVœur implements appropriate technical and organizational measures to protect your data:
- Transmission via encrypted protocols (HTTPS/TLS)
- Hosting on secure servers in Europe (Microsoft Azure, France)
- Access to data restricted to authorized members of the CoVœur team only
- Anonymization of sensitive data before AI processing
11. International transfers
All data processing carried out by CoVœur and its main processors (Microsoft Azure — backend hosting and database in France, Azure OpenAI — AI processing in France and Switzerland, Meta WhatsApp Business API — messaging in Ireland, Stripe — payments in Ireland) is located within the European Union or the European Economic Area. No transfers of personal data to third countries are carried out.
12. Cookies and trackers
The CoVœur Service is mainly accessible via WhatsApp and does not use tracking cookies. The site www.covoeur.com may use technical cookies strictly necessary for the website to function. No advertising or profiling cookies are used.
Personal Space session cookie: when you access your personal space via the secure link sent by WhatsApp, a session cookie (espace_session) is placed on your browser. This cookie is strictly necessary to maintain your connection to your personal space. It contains no personal data — only a random session identifier. It expires automatically after 7 days. This technical cookie does not require your prior consent in accordance with Article 82 of the French Data Protection Act.
13. Minors
The CoVœur Service is reserved for adults (18 years or older). We do not knowingly collect personal data regarding minors. If you become aware that a minor has used the Service, please inform us so that we can take the necessary measures.
14. Changes to this policy
CoVœur reserves the right to modify this Privacy Policy. Any material change will be communicated via WhatsApp. We encourage you to check this page regularly.
15. Contact
For any question related to the protection of your data: contact us via our contact form.
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