Privacy Policy

To use certain of our apps or websites, we may ask you to provide your first and last name, email address, weight, height, fitness level, areas for improvement, and food preferences. We may also ask you a few registration questions depending on the app or web products you choose within our ecosystem (for example, using our mental-health apps may require certain mental-health information). In some of our apps, you can skip the registration questions by tapping Skip or a similar control.

We may also automatically collect the following data from your device: language settings, IP address, time zone, device type and model, device settings, operating system details, and other technical information. We need this data to provide our services (e.g., to display a particular product element), to analyze how our customers use the app (e.g., to learn whether certain features are used), and to show advertising. In most cases, you can influence such processing by limiting it via the privacy features available on our sites and/or in our apps.

Please review our Privacy Policy below to learn more about how we handle data (Section 2) and your data-privacy rights (Section 4). Depending on the region from which you access our Services and products, different options and rights to control your privacy may be available. Examples include:

• Opting out of online tracking using the e-privacy settings in our apps and on our websites.
  
  

• Prohibiting the sale/sharing of data (as defined under certain U.S. laws).
  
  

• Requesting deletion of your data and account.
  
  

• Exercising other privacy rights.
  
  

When such features are available to you, we will clearly indicate this in the footer, menus, or profile sections of our products. We strive to provide most of these rights as self-service privacy features accessible through our service’s user-friendly interface (if you have trouble finding them or if they are unavailable, please send us a request).

If any questions remain unanswered, or if you would like to exercise your privacy rights, write to us at vivere.app.ua@gmail.com

Privacy Policy

This Privacy Policy provides explanations and transparent information about what personal data we collect when you use our mobile applications, websites, and the services provided through them (collectively, the “App” or the “Service”), as well as how such personal data is processed.

By using the Service, you confirm that: (I) you have read, understand, and accept this Privacy Policy and the data processing described herein, and (II) you are at least 18 years old. If you do not accept it or cannot make this confirmation, you must not use the Service. In such cases, you must: (a) delete your account and ask us to delete your data; (b) cancel any subscriptions via Apple (if you use iOS) or Google (if you use Android), other app stores that may be available from time to time, or via the function on our website if you purchased a subscription directly from us; and (c) delete the App from your devices.

Any translation of the English version is provided solely for convenience and transparency. If there is any discrepancy in meaning or interpretation between the English version of this Privacy Policy, available at https://www.vivere-app.com/en/privacy-policy, and any translation, the English version shall prevail. The original English text is the only legally binding version.

1. Categories of Personal Data We Collect
   We process the following data:
   
   

(I) data you provide to us directly (for example, when you choose areas for improvement or email us, or interact with our coaches),
(III) data we receive about you from third parties (for example, when you sign in with Apple or grant us access to HealthKit data),
(III) data we obtain automatically when you use our Service (for example, your IP address via cookies or SDK technologies) or our devices (e.g., BetterMe Band).

1.1. Data You Provide Directly

1. Identifiers
   This may include your first and last name, phone number, and email address. You provide this information when you register for the Service, purchase our physical products, subscribe to our newsletter, or contact us in any other way.
   
   

2. Registration Data and Product Information
   You provide information in this category when you register for the Service and/or complete the onboarding process and/or use the Service. This category includes, in particular:
   - General information about you. For example, age, date of birth, sex (gender), etc.
   - Health and fitness information. This includes physical parameters such as height and weight; data about your workouts, meditation and breathing practices; sleep patterns; and the type and duration of physical activity. In addition, we may ask you to provide information about your fitness level and dietary preferences, or invite you to track your water and food intake. We use selected portions of this data to personalize your interactions with us when providing the Service.
   - Special health data. Some pieces of information we collect may fall into a special category of personal data or constitute sensitive data under certain applicable data protection laws. In such cases—for example, when we ask whether you need a diet for people with diabetes, or whether you wish to participate in a special program for individuals with limb loss—we will ask for your consent to process such data.

3. Conversations with Coaches
   We offer the opportunity to interact with coaches within our paid services. During these interactions, we process the text of your conversations with coaches (including via our data processors—Communication Service Providers, as defined in Section 3). This category covers any information you may share during these conversations, including your progress, feedback, questions, goals, photos of meals, and any other details you wish to discuss.

4. Comments You Provide with Your Requests
   You may also provide us with certain personal information through “Contact Us” forms or in emails sent to our email addresses (including via our data processors—Communication Service Providers, as defined in Section 3). This information may include any comments you provide when submitting your request.

1.2. Data Provided by Third Parties

1. Apple ID Account
   When you use Sign in with Apple to register an account in the App, we receive personal data from your Apple ID account. This data may include, in particular, your first and last name and a verified email address. You can share either your real email address or an anonymized address using Apple’s relay service (“Hide My Email”). Apple will display detailed privacy information on the Sign in with Apple screen. Learn more about Sign in with Apple here: https://www.apple.com/legal/privacy/data/en/apple-id/.

2. Apple HealthKit (and Motion & Fitness APIs) or Google Fit (collectively, the “Health App”)
   If you grant explicit permission on your device, we may read (receive) and/or write (transmit) data to or from the Health App. In some of our Apps, you can allow us to read (receive) the following information from the Health App: step count, distance covered, weight, food calories, and other data you select on screen. If you grant us permission to write (transmit) data to the Health App, we will send information about your workouts, weight, and the caloric content of food to the Health App. The specific data elements the Health App will access are shown on Apple or Google system pop-ups that we do not control. Before you decide to share data with the Health App, we recommend reviewing its privacy policy, as it will apply to your data. To learn more about Apple HealthKit, visit http://www.apple.com/ios/health/. To learn more about Google Fit, visit https://www.google.com/fit/. You can withdraw your permission to read/write data from the Health App at any time directly within the Health App.

1.3. Data We Collect Automatically

1. Activities Online
   We record how you interact with our Service. For example, we log your interactions with specific parts of the interface, features, and content; your workouts; the time and duration of your workouts; your meditations; how frequently you use the App; your total time in the App; your progress in learning or meditation programs; and your subscription orders.

2. Device Information and Geolocation Data
   We collect data from your mobile device. Examples include: language settings, IP address, time zone, device type and model, device settings, operating system, internet service provider, mobile carrier, hardware identifier, and Facebook identifier. If you give consent in certain of our products to transmit geolocation data (for example, running routes), the App may also access that data.

3. Advertising Identifiers
   We collect Apple’s Identifier for Advertisers (“IDFA”) and Google’s Advertising ID (“AAID”) (depending on your device’s operating system). You can usually reset these identifiers in your device’s operating system settings (though we do not control this).

4. Cookies and Similar Tracking Technologies
   Our products use data processing technologies (cookies, SDKs, and similar) to improve user experience, optimize advertising, and analyze traffic. These technologies are active when you interact with our Services, visit our websites, use our apps, or enable certain features such as chats. Disabling these technologies may adversely affect the operation of certain features, although you will still be able to use our products.

In addition, we and our partners use targeting technologies to personalize advertising and, where appropriate, potentially show it to you. If enabled, your interaction with our website or app may result in our ads being displayed on social media platforms, helping us measure the effectiveness of our advertising campaigns. We respect your privacy rights and allow you to opt out of data processing that is not necessary to provide the services you request. In particular, we use the tracking technologies listed below.

Strictly Necessary
Certain technologies are required for our products and their features to function properly. These are typically activated when you visit our site or open the app. Using them allows us to (I) remember your preferences, (II) quickly load the content you request, (III) enhance security, and (IV) ensure other product features work.

Additionally, some of these technologies are activated when you enable certain features (such as chats) or contact customer support.

Functionality
We use these technologies to personalize and improve your experience. They allow us to remember the settings you choose (for example, theme or language). Your experience will also be more consistent thanks to saved preferences, sign-in state, or items in your cart.

If you disable these technologies, some features may not work properly, although you will still be able to use our products.

Performance
These technologies help us process information about how you and other users interact with our products. This helps us understand user engagement with our products and features, and determine what users like or dislike. Examples include:

• Counting visits and identifying traffic sources.
  
  

• Understanding which sections or features users like most.
  
  

• Analyzing user preferences to help us decide which new features to build.
  
  

If you disable these technologies, we will not receive certain information that we could otherwise process for analytics purposes.

Targeting
We and our partners use these technologies to personalize advertising and, where appropriate, show it to you. For example, if these technologies are enabled and you interact with our site or app, you may see ads for our products in your social media feed. They also help us measure ad campaign effectiveness and increase the relevance of ads for you.

If you decline targeting technologies, you may see less relevant advertising and miss our timely offers. It may also be more difficult for us to measure advertising effectiveness.

2. Purposes and Legal Bases for Processing Your Personal Data

We collect and use your data primarily to provide our services, improve the quality of our fitness and health services, and continuously enhance them. We also aim to attract new customers to our products. Below, we describe in detail how we use your information and provide clear illustrative examples.

Please also note that some of the information we collect—including registration and product information—may be considered a special category of personal data or sensitive data under certain applicable data protection laws. In such cases—for example, when we ask whether you need a diet for people with diabetes—we will request your consent to process such data. If the information necessary to provide the Service constitutes a special category of personal data (for example, your type of diabetes to tailor an appropriate diet, or heart rate obtained from the BetterMe Band to use the band together with the App), you will be required to provide consent to access our services, as we cannot provide them without processing this data.

1. Provision of the Service and Administration of Your Account.
   This includes verifying your identity and email address, providing you with seamless access to the Service, preventing or resolving Service errors and technical issues, and personalizing your experience. Possible outcomes of this processing include:

• Personalization of your experience. We tailor the Service’s content to your personal preferences. As a result, you may, for example, receive access to a meal plan that contains only vegetarian items or a special diet (in the in-app chat) tailored to your goals.
  
  

• Responding to your requests. We handle your requests for technical or customer support, information about the Service, or any other communications from you. This includes accessing your account to provide technical assistance, giving comprehensive answers to your questions, ensuring satisfaction with our Service, and handling any disputes related to our Service.
  
  

To do this, we may send you, for example, notifications or emails about the operation of our Service, security, payment transactions, and information about our Terms of Use or this Privacy Policy.

2. Communication with You About Your Use of the Service
   We use, for example, push notifications to communicate with you. These may include reminders and prompts to follow training and nutrition plans, other information about the Service, password resets, or account updates. As a result, you may, for example, receive daily push notifications at a specific time reminding you about a workout. To opt out of push notifications, you need to change your device settings. We may also notify you of important updates or changes to the Service, collect feedback about the Service, or respond to any questions or complaints you may have.

3. Communication Regarding Potential Collaboration
   This includes the possibility of reaching out to you to discuss potential forms of collaboration, such as partnerships or service improvements that may be of interest to you.

4. Processing and Fulfillment of Your Transactions
   This includes managing and fulfilling your orders and requests; providing customer support related to your orders; delivering Products to you; processing your payments; providing receipts, confirmations, and up-to-date order information; and handling returns or disputes.

5. Research and analysis of your use of the Service
   This helps us better understand our business, analyze our operations, maintain, improve, plan, design, and develop the Service and our new products. We also use data for statistical analysis, testing, and improving our offerings. This enables us to understand which Service features and training plans our users like most and which user categories rely on our Service. We often decide how to improve the Service based on the results of this processing. For example, if we learn that users most frequently perform leg exercises, we may develop and introduce a new workout for that body part in the Service.

6. Sending our marketing communications
   We may add your email address to our mailing list if we obtain your consent or otherwise establish a legal basis to send you marketing messages. As a result, you will receive information about our products, including special offers. If you do not wish to receive marketing emails from us, you can unsubscribe by following the instructions provided in the footer of such emails.

7. Personalization of our advertising
   Together with our partners, we use your personal data to tailor advertising and, where appropriate, show it to you. For example, if you have installed our Service, you may see ads for our products, such as in your Instagram feed.

8. Ensuring compliance with our Terms of Use and preventing and combating fraud
   We collect and store personal data to the extent necessary to protect our legitimate rights and interests in the event of legal disputes or claims. This may include using data to support our legal claims, respond to court requests, and to establish, exercise, or defend our legal position.

3. Parties to Whom We Disclose Your Personal Data

We engage partners to provide specific services or business functions on our behalf, using their technologies and resources and in accordance with our instructions. Such cooperation may, in particular, require processing your data through their software development kits (SDKs), APIs, cookies, and other technologies. Accordingly, your information is transmitted to and processed on their servers (typically without the partner having direct access to specific items of information) on our behalf for the purposes mentioned above.

This type of personal data processing may be considered a disclosure to third parties. We seek to enter into data processing agreements with all such parties to establish rules for processing your data, limiting processing to our instructions. Our partners help us operate, provide, improve, integrate, personalize, support, and market the Service.

Below are some categories of third parties with whom we share information.

1. Third-Party Service Providers
   We share personal data with third parties we engage to provide services or perform business functions on our behalf and in accordance with our instructions. We process your personal information using the types of service providers listed below (and, in some cases, their sub-processors).

Cloud Storage Providers

We use Google Cloud Platform  (GCP)—Google hosting and server service—to host personal data and to operate and deliver our Service. Additional information about Google Cloud Platform security technologies is available on the company’s website.

Monitoring Service Providers
We use Crashlytics—a monitoring service by Google—to monitor the App’s infrastructure and performance. See its data collection policy.

We also use Firebase Performance Monitoring and Firebase Crash Reporting—monitoring services by Google. For more information, see Google’s Privacy Policy and the Firebase Privacy & Security information.

Data Analytics Service Providers

We use the Amplitude analytics service to understand how customers use our Service. Amplitude collects various technical information, including time zone, device type (phone or tablet), and unique identifiers (e.g., IDFA). We also track various interactions in our App through Amplitude. As a result, Amplitude helps us decide which features to focus on (for example, if we see that most users primarily engage with walking meditation exercises, we may develop more in that direction). Amplitude is certified under the EU-US Privacy Shield. Additional information about data processing by Amplitude can be found in the company’s Privacy Policy.

To analyze how visitors use the Service and to measure the effectiveness of certain advertisements, we use Google Analytics, a web analytics program by Google. In Google Analytics, we receive, among other things, information about the data you enter on our website and see how users interact with the site. Google allows us to influence the collection and processing of information generated by Google—for example, by installing the browser add-on available here. You can read more about how Google uses this information here.

To track and analyze the behavior of our App’s users (including their reactions to changes in the structure, text, or any other component of the App), we use Firebase Remote Config. Firebase Remote Config is an A/B testing and configuration service by Google that also enables us to tailor the content displayed to users of our App (for example, it allows us to show different registration screens to different users). For additional information about Firebase’s privacy practices, see Google’s Privacy Policy and the Firebase Privacy & Security documentation.

Push Notification and Messaging Providers

We use the Apple Push Notification service (APNs)—Apple’s notification service. Using APNs, we send information to iOS devices. See Apple’s Privacy Policy.

For communications with you, we also use Firebase Cloud Messaging and Firebase Notifications—Google’s messaging services. With Firebase Cloud Messaging, we send messages and notifications to users of our Service on Android and iOS. We integrate Firebase Notifications with Google Analytics to build analytics-based audiences and track opens and conversions. As a result, we can, for example, send encouragement messages to users who have recently completed a training program. See Google’s Privacy Policy.

2. Health Apps
In some of our Apps, if you grant permission to write (transmit) data to the Health App, we will transmit information about your workouts, weight, and the caloric content of food to the Health App.

3. Law Enforcement and Other Government Authorities
We may use and disclose personal data to enforce our Terms of Use; protect the rights, privacy, safety, or property of us and/or our affiliates, you, or others; and to respond to requests from courts, law-enforcement and regulatory bodies, and other public and governmental authorities, or as otherwise required by law.

4. Third Parties as Part of a Merger or Acquisition
As we develop our business, we may buy or sell assets or business offerings. In such transactions, customer information is typically one of the transferred business assets. We may also share such information with any affiliated legal entities (e.g., a parent or subsidiary) and transfer it in connection with a corporate transaction such as a sale of the company, divestiture, merger, consolidation, or asset sale, as well as in the unlikely event of bankruptcy.

5. Affiliates
We may share your personal information with affiliated organizations within our corporate group—companies we own, that own us, or that are under common ownership or control. These affiliates will use the information in accordance with this Privacy Policy and will ensure the protection of your privacy across our health and fitness group services.

4. Exercise of Your Rights
You have the following rights to control your personal data:

• Access / review / update / correct your personal data. You have the right to review, edit, or modify the personal data you previously provided to us. If you wish to obtain a copy of the data we process, please submit a data access request or, depending on the product you use, locate the data-access privacy feature, typically available in the profile section.
  
  

• Deletion of personal data. You may request the erasure of your personal data, as permitted by law. If you submit a deletion request, we will make reasonable efforts to fulfill it. In some cases, we may be legally required to retain certain data for a period of time (for example, information about your payments and your requests to us). In that case, we will fulfill your request for part of the data within the mandatory period for handling deletion requests, and for the remaining data once the applicable retention period ends (for example, after the required retention period for payment data).
  
  

• Information about processing. You have the right to receive information about the collection and use of your personal data. This means you have the right to understand what personal data are processed, why they are processed, to whom they are disclosed, and how long they are retained. We strive to meet transparency requirements and provide most information in this Privacy Policy. If you have questions about our data-processing practices or wish to learn more about how we use your personal data, please contact us.
  
  

• Prohibit or restrict the use of your personal data. You may ask us to stop using your personal data or to restrict its use. Examples include:
  
  

• Email marketing: we provide an opt-out link in every marketing email, and you may also contact our support team.
  
  

• E-privacy settings: we provide EU-standard privacy controls to customers worldwide and allow you to make tracking choices separately for each purpose (in the e-privacy settings section, typically located in the footer, menus, or profile areas of our products).
  
  

Additional ways to influence personalized advertising

• iOS. On iPhone or iPad, go to Settings > Privacy & Security > Apple Advertising and turn off Personalized Ads. You can also reset your advertising identifier in the same section (which may further reduce personalized ads).
  
  

• Android. To opt out of interest-based ads on an Android device, open Google Settings on your phone, tap Ads, and turn off interest-based ads. You can also reset your advertising identifier in the same section (which may further reduce personalized ads).
  
  

To learn more about controlling ad choices across devices, see the information available here.

You can also find helpful information and opt out of certain interest-based advertising at:

• Network Advertising Initiative — http://optout.networkadvertising.org/
  
  

• Digital Advertising Alliance — http://optout.aboutads.info/
  
  

• Digital Advertising Alliance (Canada) — http://youradchoices.ca/choices
  
  

• Digital Advertising Alliance (EU) — http://www.youronlinechoices.com/
  
  

• DAA AppChoices — http://www.aboutads.info/appchoices
  
  

We value your right to influence the ads you see, so we disclose which service providers we work with for these purposes and how some of them allow you to manage ad settings.

• Right to lodge a complaint with a supervisory authority. We prefer to communicate directly so we can address your concerns—customer satisfaction is our highest priority, and we strive to provide the best support available on the market, which will most likely allow us to satisfy your request directly. However, you have the right to file a complaint with a competent data-protection supervisory authority.
  
  

• Right to data portability. If you wish to receive your personal data in a machine-readable format, you may do so by requesting a copy of your personal data as described above. The data will be provided to you in a .json file or another format.

• Verification
  We must verify your rights requests to process them appropriately. Depending on the type of request and the product you use, we may ask for your name, age, email address, subscription purchase date, date of last activity, account creation date, or other Service-usage data by which you can reasonably be identified as the account holder. We may also request additional proof of identity if necessary, though we strive to minimize such requirements (for example, for some requests we may send you a verification code or link).

• Authorized Agent
  You may designate an authorized agent to exercise your rights on your behalf. If you appoint an authorized agent via a power of attorney, we will work directly with your authorized agent to fulfill your request. If you do not appoint an authorized agent via a valid power of attorney or a similar method, we will contact you directly to confirm the agent’s authority and obtain verification information. The authorized agent must verify both their identity and the consumer’s identity.

California-Specific Rights
This section provides information about additional rights available to California consumers under the California Consumer Privacy Act (CCPA) and California’s Shine the Light law. Accordingly, this section applies only to residents of the State of California, USA.

For more information about the personal information we collect, including categories of sources, see Section 1 above. We collect this information for the purposes described in Section 2 of this Privacy Policy. We may also disclose your information to certain categories of third parties as described in Section 4.

In addition to the rights listed above, the CCPA grants you the following rights:

• Right to know what personal information was sold or shared and to whom. Under this right, you may ask us to provide:
  
  

• The categories of personal information we have collected about you.
  
  

• The categories of personal information about you that we sold or shared, and the categories of third parties to whom the personal information was sold or shared, by category of personal information for each category of third parties to whom it was sold or shared.
  
  

• The categories of personal information about you that we disclosed for a business purpose, and the categories of parties to whom it was disclosed for a business purpose.
  
  

• Right to opt out of the sale or sharing of personal information and to limit its use. We may share certain information about you with our partners for targeted advertising or data analytics, which, under some circumstances, may be classified as a “sale,” “sharing,” or “targeted advertising” under California law. You have the right to opt out of the sale/sharing of your personal information.
  
  Depending on the product you use, we will endeavor to provide a prominent link labeled “Your Privacy Choices” so you can exercise this right. In most cases, it will be available in the footer, menu, profile, or a similar location (depending on the product and device you use).

5. International Data Transfers

 We may transfer personal data outside the country in which it was originally collected in order to provide the Service as described in the Terms of Use and for the purposes set out in this Privacy Policy. If such countries do not have the same data-protection laws as the country where you first provided the information, we will apply appropriate safeguards, such as standard data-protection clauses adopted by the EDPB.

6. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. If we decide to make material changes, you will receive a notice within our Service or by other available means and will have the opportunity to review the updated Privacy Policy. By continuing to use the Service after such changes take effect, you agree to the revised Privacy Policy.

7. Data Retention
We will retain your personal data for as long as is reasonably necessary to achieve the purposes set out in this Privacy Policy and our Terms of Use (including providing the Service to you), including for the period during which you maintain a Service account.

We will also retain and use your personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. For example, under certain accounting and tax laws, we must retain Commercial Information for extended periods to comply with applicable laws. Therefore, even if you submit a deletion request, a small portion of data related to our legal obligations may be retained after your request has been fulfilled.