Privacy Policy

Last updated: 5 November 2026

Lucarna lets a family ask one older person a few small questions each day, and tells the family, in facts only, when a question with a deadline gets no answer. None of their answers are shared until they agree on their own phone, and they can stop at any time. Their agreement lasts 12 months from their latest yes, and then sharing pauses until they agree again on their own phone. This policy says what Lucarna keeps, why, who sees it, and for how long.

Who is responsible

Lucarna is an app from Itworked Systems, a company registered in Türkiye ("we"). We are the data controller for the data described here under Turkish data protection law (KVKK, Law No. 6698) and, for people in the EU and the UK, the GDPR. Contact: info@itworkedsystems.com.

What we keep about family members

Your sign-in: the account number Apple or Google gives Lucarna. We never see your password. When you sign in with Google on an iPhone, Google also sends your name, email address and a link to your profile picture; we do not keep any of them, or any other name or email address from Apple or Google.
The name you choose to show in a family, if you give one.
Your place in each family: whether you can change things or only see, when you joined or left, whether alerts reach you, and whether you were the one who tapped "Stop looking after". Others in the family see your role and whether alerts reach you. The family's app also receives when you joined, and uses it only to list people in order of joining. If you tap "Stop looking after" in a family that someone else's plan pays for, Lucarna may tell that person that it was you, using the name you show in the family. If you show no name, that person may be told that Lucarna was stopped, but not who stopped it.
Your phone's notification address, so alerts reach you.
Your daily summary time and time zone, if you turn the summary on.
Invitations you make or use, and the codes you make to link their phone.
A note about the codes that link their phone: who in the family made the first code since 4 November 2026, and when, and that the family's app did not ask them whether the person looked after can understand a short explanation and decide for themselves. Lucarna keeps at most one such note for each family, and none for a family they started on their own phone.
What you set up for the person you look after: their name, where they live (time zone), their language, and the questions and times you choose.
The plan: when you open the page that sells it, a random billing number Lucarna makes for you, which is how Adapty knows you (see "Who sees it"). If you start a plan: which family it pays for (and the family you last started one for), which store sold it, which plan it is, the store's number for the subscription, when it started and when it ends, and whether it is in its free days and will renew. We never see your card or bank details: Apple or Google takes the payment.

What we keep about the person looked after

The person looked after has no account and no password. Their phone is linked to the family with a code they type.

Their name, time zone and language, as entered when the family was set up, the language their phone uses for Lucarna, and the time zone their phone is set to.
Their phone: a random number Lucarna makes when the phone is linked, whether it is an iPhone or Android (and the brand of an Android phone), its notification address, whether notifications are allowed and which of Lucarna's notification settings are off, and the steps of setting it up, including test notifications.
Their answers: which answer they tapped (and any change they made to it) and when, the time their phone showed, when a question was shown or read, when a question with a deadline got no answer by its time, when the family was told, and when a question stopped being asked before they answered it. Answers about medicine, pain, sleep or mood are health information.
Questions they turned off.
Their yes or no to "Questions that stand out?", and when they gave it. Their phone may ask this after they agree to share.
Their agreement: what they were shown (the version of the words, the language, and the names of the people who would see their answers), when they were asked, what they chose, and any later "Stop sharing" (when they share again, the time of their latest stop is kept); when they are asked again each year, what they chose and the words they were shown (a new yes takes the place of the one before it, and their latest "Not now" after a yes is kept, with its words, beside it); while sharing is paused, when it paused; and notes that someone joined or left, which their phone shows them, or that a question was added.
When their phone last reached Lucarna, so the family can be told when it has gone quiet, and notes of times when Lucarna was open on it, whether or not they share. While they share, the family's app receives how many of these notes there were each month, including notes from times they were not sharing, but does not show it.
Setting up their phone: when someone last helped with it, so Lucarna waits before asking them, and when it was switched to the family side.

If they started the family on their own phone, Lucarna also keeps the name they typed there and the invitation codes their phone made.

What we never collect

No location (beyond the time zone a phone is set to), contacts, photos, camera, microphone or data from health apps. Every answer is a tap on one of a few words: there is nowhere to write an answer. The app contains no advertising or tracking software, and we never sell data or use it for advertising. On the family side it contains software from Adapty, which handles buying a plan and gives us reports on how plans are bought and kept; it runs only when a family member opens the page that sells the plan, never on the phone of the person looked after.

Why we use it, and on what basis

Data	Why	Legal basis
Answers and everything about them	To show the family the answers and tell them when a question with a deadline gets no answer	The explicit consent of the person looked after, given on their own phone (GDPR Art. 9(2)(a) and 6(1)(a)). Lucarna asks only when they open it themselves, and not soon after someone helped set it up, and asks again around the end of each 12 months
Family members' accounts	To provide the service you asked for	Performing our agreement with you (Art. 6(1)(b))
The person's name and time zone before they are asked	To prepare the question they are about to be asked	Legitimate interests (Art. 6(1)(f))
Records of agreement	To be able to show what was agreed to, and when	Legal obligation to demonstrate consent (Art. 7(1))
The note of who made the first code to link their phone, and when	To be able to show whether anyone in the family was asked to confirm that the person can decide for themselves	Legitimate interests (Art. 6(1)(f))
Phone and notification details	To deliver questions and alerts reliably	Performing our agreement, and the person's consent
Plans and billing numbers	To sell the plan, and to know whether a plan pays for a family: the person is asked only while one does, and the family member whose plan it is may be told if someone else taps "Stop looking after"	Performing our agreement with you (Art. 6(1)(b))

We never interpret answers. Lucarna draws no conclusions about anyone's health.

Who sees it

Everyone in the family sees their answers while they share, including people who join later. While they share, the family's app also receives the time zone their phone is set to. When their phone keeps a different time from the one Lucarna asks in, the family's app shows which place's time their phone is set to, such as "Germany time". Their phone shows who can see, and tells them when someone joins or leaves. Before they agree, after they stop, and while sharing is paused, the family never sees their answers to the family's questions.
Whether or not they share, the family sees whether and when they agreed (while sharing is paused, only the day it paused), whether they stopped sharing, which questions they turned off, their yes or no to "Questions that stand out?", and what Lucarna knows about their phone: when it last reached Lucarna, whether notifications are allowed and which of Lucarna's notification settings are off, whether it is switched to the family side and since which day, its setup steps and test notifications, and an Android phone's brand. The language their phone uses for Lucarna may be shown to people who can change things when adding a question, if the family has not chosen a language. In a family they started on their own phone, "Where they live" starts as the place of the time zone their phone was set to when they started it, and the family sees it whether or not they share. The family's app also receives the time they stopped sharing and when their phone was linked, but does not show either.
Family members see each other's names, whether each can change things, and whether alerts reach each one. The family's app also receives each member's account number from Apple or Google, which it does not show, and when each joined, which it uses only to put the list of people in order. Everyone in the family sees whether a plan pays for the family, until when, and whether the plan is in its free days and will renew. If the person whose plan it is gave a name in the family, the others also see that name, even after that person leaves, until that person's account is deleted. The family's app also receives which store sold the plan, but shows it only to the person whose plan it is. If someone taps "Stop looking after" in a family that another member's plan pays for, Lucarna may tell that member who it was, using the name shown in the family, if there is one.
Our service providers store the data for us: Amazon Web Services (servers in Frankfurt, Germany) and MongoDB (database in Frankfurt, Germany). Apple and Google provide sign-in and deliver notifications; for that they also act under their own privacy terms. Notifications never contain answers or the words of a question: they say things like "Please open" or "Something needs your attention".
Adapty (Adapty Tech Inc.) checks plans with Apple and Google for us. It receives your billing number, the stores' records of your plan (purchases, renewals, cancellations and refunds) and technical details of your phone, such as its model, system and app version, language and time zone, with a device identifier that is not an advertising identifier. We have switched off its collection of advertising identifiers and internet addresses. Once the page that sells the plan has been opened, Adapty also records when the app is opened and what is done on that page, and uses the plan records to count revenue. We see this only as reports in Adapty's dashboard, and use it only to understand how plans are bought and kept. It never receives names, answers or anything about the person looked after.
Apple and Google sell the plan and take the payment, under their own terms and privacy policies.
People at Lucarna look at data only when needed to keep the service working or to answer a request from you.

Where the data is processed

The data is stored in Germany, outside Türkiye. Amazon, MongoDB, Apple, Google and Adapty are US companies and may also process data in the United States. These transfers follow the rules for sending data abroad in Turkish data protection law and, for people in the EU and the UK, the GDPR.

How long we keep it

What	How long
Answers, while sharing continues	As long as the person keeps sharing
While sharing is paused (12 months after their yes with no new yes, or after a "Not now" when asked again)	Hidden from the family, and none of the family's questions is asked. Kept until they agree again, stop sharing, or the family stops looking after them
After "Stop sharing"	Hidden from the family at once. Answers and questions are deleted after 30 days, unless the person shares again on their own phone; copies of the words of the questions, and everything else about the family, after 90 days
After the family stops looking after them	Their phone is unlinked. Answers and questions are deleted after 30 days; copies of the words of the questions, and everything else, after 90 days. Nobody can undo it
After "Delete it all now" on their phone	Everything about that family is deleted within about a minute, except the proof of agreement and the notes that an alert, reminder or daily summary was sent, which go within 30 days
A family where the person has never agreed and has not yet answered whether to share	Deleted 30 days after it was made (for a family they started on their own phone, 30 days after the first family member joined)
After a new phone is linked, until the person agrees on it	If they had agreed before and sharing was not stopped when the new phone was linked, even if it had paused or they had said "Not now" since: answers kept, hidden from the family, until they agree on the new phone or the family stops looking after them. If sharing was stopped at that time, or they had never agreed: the family is treated as in the row above, so one whose 30 days have already passed is deleted within about a minute
A family where the person said "Not now"	Kept until the family stops looking after them
Proof of agreement	Up to 3 years from when it is made, which is when the family's data is deleted or when a new phone is linked, without any names or answers. A family keeps only its latest one
A family member's account	Until you delete it. See Delete your Lucarna account
Which plan pays for a family	As long as the family exists, and deleted with it. When the person whose plan it is deletes their account, the record no longer names them
Your billing number, and Adapty's record of it	Until you delete your account. Adapty is then asked to delete its record too, unless a plan you bought is still running or set to renew; in that case, once it has ended and will not renew. Apple and Google keep their own records of a purchase
Notes that an alert, reminder or daily summary was sent	30 days
Server logs	4 days, kept by our hosting provider
Backups	None are kept

Your rights

Under Turkish data protection law (KVKK, article 11) and the GDPR, you can ask for a copy of your data, correct it, delete it, take it elsewhere, or object to how we use it. Where we rely on consent, you can withdraw it at any time.

The person looked after: on their phone, "Who can see this" then "Stop sharing" stops the questions and hides their answers from the family at once. After stopping, "Delete it all now" deletes that family's data within about a minute, apart from what the table above keeps. For a copy of their data, they can email us.
Family members: "Delete my account" in the app, or email us.
Anyone: email info@itworkedsystems.com. We answer within 30 days, free of charge.

You can also complain to Türkiye's Personal Data Protection Authority (Kişisel Verileri Koruma Kurumu) or, if you live in the EU or the UK, to the data protection authority where you live.

Security

Everything travels encrypted (HTTPS), and our database provider encrypts stored data. The person's phone has no password: the linked phone itself is the key, so anyone holding it unlocked can use Lucarna on it. Family sign-ins end after 90 days. Internet addresses are used only to answer requests and to limit abuse: they are held in memory, not stored. Server logs can include a phone's notification address when a notification could not be delivered.

Age

Lucarna is for adults. Family members must be 18 or older, and the person looked after must be able to understand the request and decide for themselves.

Changes

If this policy changes, we update this page and the date at the top.