Savva

Privacy Policy

Last updated: April 2025

Updated and Effective as of April 2025

Thank you for choosing to be part of our community!

WE HOPE YOU TAKE SOME TIME TO READ THROUGH IT CAREFULLY, AS IT IS IMPORTANT.

This Privacy Policy describes how Savva Inc. (collectively, "we," "us," or "our") collects, uses, stores, transfers, and discloses personal information from our Users in connection with our Website or/and Web application (collectively referred to as "Service").

One way to protect your privacy is to learn how it will be used before you give it out. We attach great importance to your privacy rights and truthfully explain why and how we process your information.

We tried to shorten this privacy policy, so it would be easier to understand the rights of a User (referred to as "you," "yours," etc.) and our obligations to the User's data. "Personal Data" means personal data that relates to you as an identified or identifiable individual.

Where applicable, you must provide us with the relevant Personal Data to be able to use our Services completely. You should not use the Services if you disagree with this Policy, our Terms of Use, and any other agreement that governs your use.

BY USING THE SERVICE, YOU PROMISE US THAT (I) YOU HAVE READ, UNDERSTAND AND AGREE TO THIS PRIVACY POLICY, AND (II) YOU ARE OVER 16 YEARS OF AGE (OR HAVE HAD YOUR PARENT OR GUARDIAN READ AND AGREE TO THIS PRIVACY POLICY FOR YOU).

You must not use the Service if you disagree or cannot make this promise. In this case, you must (a) contact us and request deletion of your data; and (b) leave the Service and not access or use it.

We may update this Privacy Policy from time to time, so please be sure to check regularly. We will notify you of any material changes by posting the new Privacy Policy on the primary access points to the Services or as otherwise required by applicable law.

If any questions still need to be answered, please contact us at support@savva.tech.

Table of content:

  1. Categories of personal data, purposes of the processing, and legal bases
  2. Cookies
  3. Third parties processing Personal data
  4. Term of storage of your personal information
  5. Rights about personal data
  6. Age limitations
  7. CCPA rights
  8. Miscellaneous
  9. Contact information

1. Categories of personal data, purposes of the processing, and legal bases

When the User uses our Services, we can collect, use, receive, process, transfer, and share some of the User's Personal Data for different legitimate purposes. Below are explanations regarding what Personal Data we may collect or process, why we may collect this data, and the legal bases relied on in each case.

Categories of Personal Data and Examples

User-provided information

In some instances, we may require certain registration information; in other cases, we may ask you to provide such data voluntarily.

Contact Data — when the User registers for the Service and enters the contract

email; name/surname/nickname; password or passcode; last 4 digits of the card number; comment.

Location Data — we do not collect the User's precise location

country, state, or coarse location such as Approximate Location Services (general - non-precise location).

Quiz Data — during the onboarding questionnaire, the User may provide different quiz personal data

We do not collect, store, share, or transfer this quiz data or use it for identification, marketing, or advertising purposes. We are not collecting biometric information. Examples: date and place of birth, birth time, gender, weight, age, photo (arm, face, etc.), relationship status, future goals, source of stress, answers to questions, physical characteristics (e.g., height, weight, areas for improvement), etc.

Device Info (technical data)

device type and model, two-character country code, subdivision of country (e.g., state), city, language code, OS version (e.g., iOS 7.1.3, Android), hardware type, connection type (WiFi, 3G, 4G), network provider, motion parameters, and carrier.

Identity Data

IP address, IDFA (iOS only), Google Advertising ID or GPS ADID (if GAID is empty), API level (Android only), Firebase ID, and similar unique identifiers.

Usage Data (Events)

length of last and current sessions (in seconds), number of sessions recorded, push token (Android), device token (iOS), ad clicks, ad types and source apps/pages, downloads and installations.

Diagnostic Information

logs, error reports, event types, timestamps, and associated pages.

Cookies and Tracking Technologies

Cookies, tracking pixels (web beacons), embedded scripts, location-identifying technologies, fingerprinting, device recognition, in-app tracking, and other current/future tracking tools. These may be used to collect data about interactions with the Service or from third parties.

We collect personal data to ensure delivery of the Service, analyze your behavior during usage, add new features to our Service, and provide our third-party service providers with the information necessary for them to perform their tasks.

Purposes, Personal Data, and Legal Basis

  • To provide the Services according to our policies with you — Contact Data, Quiz Data, Location Data, Usage Data — Legal Basis: Contract.
  • Research and development: internal improvements, feature testing, behavior analysis, issue detection, and optimization — Automatically collected information — Legal Basis: Legitimate interest.
  • To diagnose and fix issues with the Service — Usage Data — Legal Basis: Legitimate interest.
  • To help the User choose a subscription, access entertainment, receive reports, and go through the quiz — Quiz Data — Legal Basis: Contract.
  • To communicate with you (e.g., when contacting support) — Contact Data — Legal Basis: Contract.
  • To track the performance of our marketing campaigns and optimize the Service — User ID, in-app activity data, advertising ID, IP address, location — Legal Basis: Legitimate interest.
  • Alternative registration (Facebook, Google, Apple login) — Facebook ID, Google ID, Apple ID, name, profile picture, city-level location — Legal Basis: Contract.
  • Billing and administration (incl. payment processing and invoicing) — Contact Data, billing and payment information — Legal Basis: Contract.
  • To send you marketing communications — Contact Data — Legal Basis: Consent.
  • To personalize ads — Automatically collected information, Location Data — Legal Basis: Consent.
  • To prevent fraud or harm and ensure security — Automatically collected information — Legal Basis: Legitimate interest.
  • Legal obligations (e.g., fraud investigation, age verification) — Contact Data — Legal Basis: Legal obligation.
  • To fulfill contractual obligations with third parties (e.g., analytics or payments) — Automatically collected information, Contact Data — Legal Basis: Legitimate interest.

2. Cookies

We may send one or more small data files called "cookies" to the User's computer to uniquely identify the User's browser, help the User log in faster, and enhance navigation through the website. Cookies may convey anonymous information about how Users browse the Services so we can provide a more personalized experience, but do not collect personal information about you.

We may use different types of cookies: Essential Cookies (to provide Services and enable features), Functionality Cookies (to remember login details and personalize the Service), Analytics Cookies (to understand traffic and usage trends without identifying users), and Social Media Cookies.

We may use web and mobile analytics and advertising services and technologies such as Google Analytics, Facebook Analytics, Firebase, AppStore Analytics, Tenjin, GameAnalytics, and AdMob.

For further details about cookies, including how to view and manage them, visit: https://www.allaboutcookies.org and https://www.youronlinechoices.com.

3. Third parties processing Personal data

We may share your information with third-party companies to perform services such as hosting, payment processing, analytics, and customer support, as well as to assist in our marketing efforts. These third parties may receive data directly through SDKs integrated into our Service or via sharing on our behalf. This data sharing enables us to deliver personalized and relevant content.

We commit not to disclose or transfer your Personal Data to third parties without your consent, except to the Processors listed below.

Processors of Personal Data

  • Freshworks Inc. — Customer support — Policy
  • AppLovin Corp — Policy
  • AdColony, Inc — Policy
  • TikTok (Bytedance, Ltd) — Policy
  • IronSource Mobile Ltd. — Policy
  • Snap Inc. — Policy
  • Pinterest — Policy
  • Meta Inc. — Policy
  • Amplitude, Inc. — Mobile attribution and analytics — Policy
  • Apple, Inc. — Payment processing for subscriptions — Policy
  • Facebook Ireland Ltd. — Conversion tracking and analytics — Policy
  • PayPal — Payment processing — Policy
  • Stripe — Payment service provider — Policy

4. Term of Storage of Personal Data. Security Measures.

If you are located outside of the USA and choose to provide information to us, please note that we transfer the data, including Personal Data, to the USA and process it there. We retain all Personal Data for as long as you use the Services and 24 months after you stop. If you do not use the Services for 24 continuous months, we erase Personal Data from our database and request the same erasure from any third party to whom your Personal Data may have been transferred.

Personal data may be processed by automated and non-automated means and stored at our premises and on our service providers' servers. We have implemented industry-standard security measures, which include encryption to protect your personal information. However, transmissions over the Internet are never 100% secure.

5. Rights Regarding Personal Data

  1. Withdrawal Right: You have the right to withdraw your consent at any time. You can withdraw consent by contacting support@savva.tech or using the settings in the app.
  2. Right to Be Informed: You have the right to know what Personal Data we hold and how and why we handle it.
  3. Right to Opt-Out: You can opt-out of direct or interest-based advertising through your device settings.
  4. Right to Rectification: You may request corrections to your Personal Data if it is incomplete or inaccurate.
  5. Right to Erasure: You may request deletion of your data under certain conditions.
  6. Right to Object: You may object to the processing of your Personal Data based on legitimate interest or for direct marketing purposes.
  7. Right to Restrict Processing: You may restrict processing under specific circumstances.
  8. Right to Data Portability: You may request a copy of your data in a machine-readable format.
  9. Right to Complain: You have the right to lodge a complaint with a supervisory authority.
  10. General Access Right: You may request access, update, or deletion of your data. We respond within 30 business days.

6. Age Limitations

The Service is intended for adults and has a minimum "Age Limit" in each country or region. In general, you must be 16 years of age or older to use the Service, or your age requires parental consent to process your personal data. Following the Federal Children's Online Privacy Protection Act of 1998 ("COPPA"), we will never knowingly solicit, nor will we accept, personally identifiable information from users of the Service known to be under 13 years of age.

If you believe we have information from or about anyone under thirteen (13) years of age, please notify us by email at support@savva.tech with "COPPA Concern" in the subject line.

7. CCPA Rights

Here is the additional information about how we collect, use, disclose, and otherwise process the personal data of individual residents of the State of California within the scope of the California Consumer Privacy Act of 2018 ("CCPA").

As a California resident, you have rights to: request information about how we collect and use your personal information; request a copy of your personal information; request deletion; be free from discrimination for exercising your rights; opt out of the sale of personal information (we do not sell your information); and exercise other rights described above.

To exercise these rights, please email us at support@savva.tech. We aim to respond to access or deletion requests within 45 days.

8. Miscellaneous

Conditions of the present PRIVACY POLICY may be unilaterally changed by us if required under the applicable laws or in other relevant cases with obligatory notification of the Users.

9. Contact Information

DATA CONTROLLER:

Savva Inc. is a legal entity incorporated in the United States and registered at 256 Chapman Road STE 105-4, Newark, New Castle, DE, 19702.

Email: support@savva.tech