Privacy Policy
Last updated: 18 September 2026
This is a draft. It has not yet been reviewed by a lawyer and will change before Incico is published.
Who is responsible for your data
Incico is made and operated by Sefaja, Bongersweg 22, 8095PH ’t Loo Oldebroek, The Netherlands. Sefaja is the controller for the personal data described in this policy.
For any question about this policy, or to exercise the rights described below, write to privacy@incico.eu.
What this policy covers
This policy covers the Incico mobile app for Android and iOS and the website at www.incico.eu. It does not cover the services you choose to connect Incico to, such as Google Contacts, which are governed by their own providers.
What we collect
Incico is built so that we hold as little as the service allows. In practice that is:
- Account data: the e-mail address you sign in with, and the authentication records that go with it, including the signed-in sessions and the type of device each one was started on.
- Profile data: the details you choose to enter, such as names, phone numbers, e-mail addresses, postal addresses, special dates and photos.
- Connections and circles: who you are connected to, which circle you placed them in, and which details each circle may see.
- Settings: your language, theme, notification choices and how you like your contacts sorted and shown.
- Device data for notifications: a push token from Apple or Google, the platform, the app version and the language of your device, so a notification reaches you in your own language.
- Usage statistics and crash reports, only if you say yes: which features are used and technical crash details. They never contain your details or anyone else’s.
- Security records: a log of sensitive actions such as searches, invitations, blocks, exports and deletions, with a hashed version of the network address they came from.
Your address book and Google Contacts
If you connect your phone’s address book, Incico reads it and writes to it on your phone. The address book itself is never uploaded. To tell you which of your contacts are already on Incico, the app sends one-way hashes of their e-mail addresses and phone numbers, and the server only compares them with the hashes of details people chose to make searchable.
If you connect Google Contacts, the app signs in to Google on your phone and the access it receives stays on your phone. Our servers never see it, and never see your Google contacts. What the server keeps for a connected service is its name, the circles it syncs and which entry stands for which of your Incico contacts, so a second device can carry on where the first left off.
Why we use it, and on what legal basis
Every use below is tied to a purpose and a legal basis under the General Data Protection Regulation.
- Running your account and syncing your details to the circles you chose. Legal basis: performance of a contract with you. Retention: until you delete your account.
- Sending push notifications about updates from your connections. Legal basis: performance of a contract with you. Retention: push tokens are deleted when you sign out, when the app is removed or when the account is deleted.
- Sending e-mail: sign-in and verification codes, export links and the confirmation of a deletion. Legal basis: performance of a contract with you. Retention: the e-mail provider keeps delivery records for a limited time only.
- Usage statistics and crash reports, to see what works and to fix faults. Legal basis: your consent, which you can withdraw at any time in Settings → Privacy. Retention: usage statistics 12 months, crash reports 90 days.
- Keeping the service secure and diagnosing faults. Legal basis: our legitimate interest in a working, secure service. Retention: security records 12 months, server logs 7 days. The diagnostics log in the app stays on your phone unless you share it with us.
- Answering your support or privacy requests. Legal basis: our legitimate interest in answering you, or a legal obligation where the request is a GDPR request. Retention: correspondence is kept for up to 24 months.
What other people can see
Incico exists to share details deliberately. A detail becomes visible to a connection only when you place that detail in a circle that the connection belongs to. Nothing in your profile is shared by default.
Once a connection has received a detail, it may be stored on their device and, if they chose to sync, in their own address book. Removing a detail later stops further updates, but we cannot reach into a copy that already left our systems.
Who processes data on our behalf
We use a small number of providers, each under a data processing agreement, each doing one job.
- Supabase: database, authentication, file storage and server functions, hosted in the European Union.
- Apple Push Notification service and Google Firebase Cloud Messaging: delivery of push notifications to your device.
- Resend: delivery of the e-mails described above.
- PostHog, on its European hosting: usage statistics and crash reports, only when you have said yes. The app talks to it directly, without a PostHog library, and sends a random install number rather than your account.
- Netlify: hosting of this website. The website itself sets no analytics or advertising cookies.
Transfers outside the European Economic Area
Your account and profile data is stored in the European Union, and so are usage statistics and crash reports. Push notification delivery involves Apple and Google, and e-mail delivery involves Resend; they may process the notification token or your e-mail address outside the EEA under the European Commission standard contractual clauses.
How long we keep your data
You can delete your account at any time, in the app or on this website.
- Account, profile, connections and circles: kept until you delete your account, then removed from the live systems immediately.
- Backups: encrypted backups are rotated out within 30 days, after which deleted data is gone from them too.
- Data exports: the download link works for 24 hours; the archive is replaced by your next export and removed with your account.
- Usage statistics: 12 months. Crash reports: 90 days.
- Security records: 12 months. Server logs: 7 days.
- Support and privacy correspondence: up to 24 months.
Your rights
Under the GDPR you can ask us to do the following, free of charge, and we will answer within one month.
Two of them you can do yourself at any moment. Export my data gives you a zip with everything in your account, and Delete account removes it. Both are in the app under Settings → Privacy, and on the account page of this website, where you sign in with a code sent to your e-mail address, for when you no longer have the app.
- Access the personal data we hold about you, and receive a copy of it.
- Correct data that is wrong or incomplete.
- Delete your data, which you can also do yourself by deleting your account.
- Restrict or object to processing that relies on our legitimate interest.
- Receive your data in a portable, machine-readable format.
- Withdraw your consent for usage statistics and crash reports.
- Complain to a supervisory authority. In the Netherlands that is the Autoriteit Persoonsgegevens.
Security
Data is encrypted in transit and at rest. Access to production systems is limited to the people who need it. Profile photos are private: they are served only to you and to the people you shared them with, never through public links.
Children
Incico is not aimed at children under 16. If you believe a child has created an account, write to privacy@incico.eu and we will remove it. A parent can keep a profile for a child inside their own account; that profile is part of the parent’s account.
What we do not do
We do not sell personal data. We do not share it with advertisers or data brokers. There is no advertising in the app, no tracking across apps or websites, and there are no analytics or advertising scripts on this website.
Changes to this policy
When this policy changes in a way that affects you, we will say so in the app before the change takes effect. The date at the top of this page always shows the current version.