Privacy Policy

Last Updated: August 25, 2026

Your privacy is at the core of everything we do at Recap. Recap is a place for memories with friends — no algorithmic feed, no ads, and no selling of your data. This Privacy Policy explains what information we collect, how we use and share it, and the choices and rights you have concerning your data.

1. Who We Are

The Recap mobile application (the "App") and the website at therecap.app (together, the "Service") are operated by Recap d.o.o., a company registered in Slovenia ("Recap", "we", "us"). For the purposes of the EU General Data Protection Regulation (GDPR), Recap d.o.o. is the data controller of your personal data.

You can reach us about anything in this policy at info@therecap.app.

2. Scope

This policy applies to your use of the App and our website. By using the Service, you acknowledge this policy. Where our processing is based on your consent, we will ask for that consent separately and clearly in the App.

3. Information We Collect

a) Information you provide directly

• Account information: when you register, you provide information such as your name, email address, and password.
• Profile information: you may choose to add more to your profile, such as a username, profile picture, and bio.
• User content: the content you create and share in the App — photos, videos, text, captions, comments, reactions, and messages within your Recaps and chats.
• Contacts and friends: the connections you make in the App. If you choose to invite friends, we process the information needed to deliver your invitation; we do not upload your address book without your permission.
• Communications: information you send us when you contact support or give feedback.

b) Face verification data (biometric data)

To keep Recap a trusted community of real people, we require a one-time face verification during registration.

• What we collect: with your explicit consent, we use your device's camera to capture a scan of your facial geometry.
• How we use it: the scan is converted into a secure, encrypted biometric template used only to verify that you are a real person and to prevent duplicate or fake accounts.
• How we store it: we do not store the original face scan — only the encrypted template, which cannot be reverse-engineered to reconstruct your face.
• Sharing: we never share, sell, or disclose your biometric data to advertisers, data brokers, or any other third parties. It is used exclusively for the security and integrity of the Recap platform.
• Deletion: your biometric template is deleted when you delete your account. You may withdraw your consent at any time by deleting your account or contacting us; because verification is required to use Recap, withdrawing consent means your account will be closed.

c) Information we collect automatically

• Usage data: how you use the Service — for example the features you use, the Recaps you view, and the time and duration of your activity.
• Device information: device type, operating system and version, app version, device identifiers, language, time zone, and IP address.
• Notifications: a push token for your device, if you enable notifications.
• Photos and camera: the App accesses your camera and photo library only when you choose to capture or add content, with the permissions you grant in your device settings.

d) Website

Our website at therecap.app is a simple informational page. It does not use advertising cookies or cross-site trackers. Our hosting provider processes technical logs (such as IP address and browser type) to deliver and secure the site.

4. How We Use Your Information (and Our Legal Bases)

• To provide the Service — creating your account, hosting your Recaps, showing shared content to the friends you choose, and syncing across your devices. Legal basis: performance of a contract.
• To verify your identity and secure the platform — face verification at registration, preventing duplicate and fake accounts, and protecting against fraud and abuse. Legal basis: your explicit consent (biometric data) and our legitimate interest in keeping Recap safe.
• To communicate with you — service notifications (for example when a friend adds photos to a shared Recap) and replies to your inquiries. Legal basis: performance of a contract; legitimate interest.
• To maintain and improve the Service — understanding how features are used, fixing bugs, and developing new features. Legal basis: legitimate interest.
• To enforce our Terms of Use and prevent prohibited activities. Legal basis: legitimate interest; legal obligation.
• To comply with the law where we are legally required to process or disclose information. Legal basis: legal obligation.

We do not sell your personal data, and we do not show ads. Our business model is not based on advertising, and we do not use your content or biometric data to train advertising profiles.

5. How We Share Your Information

• With other Recap users: your profile information and the content you choose to share in a Recap are visible to the members of that Recap, as directed by you and your settings. Recaps are shared spaces — content you add can be seen, saved, or re-shared by the friends in that Recap, so share with people you trust.
• With service providers: we use a small number of third-party vendors who process data on our behalf and under our instructions — for example cloud hosting and storage (e.g., AWS), analytics, and customer support tooling. They are bound by data processing agreements, must protect your data, and may not use it for their own purposes.
• For legal reasons: if required by law or a valid legal request, or where necessary to protect the rights, safety, and integrity of Recap and its users.
• Business transfers: if Recap is involved in a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction; this policy will continue to apply to it.

6. International Data Transfers

Your information may be processed on servers located outside your country, including outside the European Economic Area. Where we transfer personal data out of the EEA, we rely on appropriate safeguards such as adequacy decisions or the European Commission's Standard Contractual Clauses.

7. Data Retention

We keep your data for as long as your account is active or as needed to provide the Service. If you delete your account, your profile, biometric template, and content are deleted from our active systems promptly; residual copies may remain in encrypted backups for a limited period before being purged. We may retain limited information where required by law or needed to resolve disputes and enforce our terms.

8. Security

We use technical and organizational measures appropriate to the risk — including encryption in transit and at rest for sensitive data such as biometric templates — to protect your information from loss, theft, and unauthorized access. No electronic transmission or storage system is 100% secure, but we work to keep protections current.

9. Your Rights and Choices

You are in control of your data:

• Access and correction: you can view and update most profile information directly in the App's settings, or ask us for a copy of your data.
• Deletion: you can delete your account at any time from the settings menu, which permanently deletes your profile and associated content as described in section 7.
• Portability: you can ask us for your data in a structured, commonly used, machine-readable format.
• Objection and restriction: you can object to, or ask us to restrict, processing based on legitimate interests.
• Withdraw consent: where processing is based on consent (such as face verification), you can withdraw it at any time; this does not affect processing that happened before withdrawal.
• Notifications and emails: you can manage push notifications in your device settings and opt out of promotional emails via the link in those messages. Service messages (like security notices) may still be sent.

To exercise any of these rights, use the App's settings or contact us at info@therecap.app. We respond within the timelines required by law. If you are in the EEA or UK, you also have the right to lodge a complaint with your local supervisory authority — in Slovenia, the Information Commissioner (Informacijski pooblaščenec, www.ip-rs.si). If you live elsewhere, you may have similar rights under your local law, and we honor requests consistent with the laws that apply to you.

10. Children's Privacy

Recap is not directed to children under 13, and we do not knowingly collect personal data from children under 13 — or under the higher minimum age that applies in your country for consenting to data processing without a parent. Because registration includes face verification, under-age accounts are actively prevented. If you believe a child has provided us personal data, contact us at info@therecap.app and we will delete it.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes, we will notify you in the App and update the "Last Updated" date above. Your continued use of the Service after changes take effect means the updated policy applies.

12. Contact Us

Questions or concerns about this Privacy Policy or your data are always welcome:

Recap d.o.o. — Slovenia
Email: info@therecap.app