Privacy Policy

Effective Date: 2025-08-22

Article 1: Our Commitment and Your Agreement

We are committed to being transparent about our data practices and to safeguarding the information you entrust to us. This Privacy Policy explains the personal and other information we collect, the purposes for which we use it, the limited circumstances in which we may share it, and the rights you have regarding your information. By accessing or using our Services, you acknowledge that you have read, understood, and agree to the collection and use of your information in accordance with this Privacy Policy. If you do not agree with the practices described herein, you should not use our Services.

Article 2: The Information This Policy Covers

This Privacy Policy addresses our handling of different categories of information, each of which is treated with the appropriate level of care. For clarity, we categorize the information we collect as follows:


First, we collect “Personal Information,” which is any information that can be used to identify you directly or indirectly. This currently includes your email address if you subscribe to our mailing list and will in the future include other identifiers such as your name, payment details for e-commerce transactions, and information you provide when creating a user account.


Second, we automatically collect “Usage Data,” which is technical information related to how you access and interact with our Services. This may include your device’s Internet Protocol (IP) address, browser type, device type, operating system, the pages of our Services that you visit, the time and date of your visit, and other diagnostic data. This information helps us understand user behavior and improve the performance and functionality of our Services.


Third, as our Services evolve to include features like wellness quizzes and personalized programs, we may collect information that you voluntarily provide that could be considered sensitive in nature (“Sensitive Information”). This may include your self-reported data regarding your mood, stress levels, wellness goals, or habits. We want to be unequivocally clear: the collection of any such Sensitive Information is designed to personalize and enhance your experience within the App. We treat this category of information with the highest level of care and additional security measures, and we will only collect it with your explicit consent where required by law.

Article 3: How and Why We Use Your Information

Our primary purpose in collecting your information is to provide you with a secure, effective, and personalized wellness experience. We use the information we gather for several interconnected purposes, which are integral to the operation and improvement of our Services.


First and foremost, we use your information to provide, maintain, and operate our Services. Your Personal Information, such as your name and email address, is essential for creating and managing your user account, authenticating your access, and delivering the core functionalities of the App. When you choose to provide Sensitive Information, such as your responses to a wellness quiz, we use this data to tailor the content you receive, for instance by suggesting specific meditation exercises or educational articles that align with your stated goals and needs.


Second, we are constantly working to improve, personalize, and expand our Services. We analyze Usage Data to understand user behavior, identify popular features, diagnose technical problems, and enhance the overall user interface and experience. By understanding how you and other users interact with the Services, we can make informed decisions about future developments. We may also use aggregated and anonymized information derived from User Content and Sensitive Information to identify broader wellness trends, which helps us develop new, relevant features and content for the entire HealV community.


Third, we use your information to communicate with you. This includes sending you essential administrative or transactional messages, such as updates to our Terms or this Privacy Policy, notifications about your account, or receipts for any purchases you make. With your separate, explicit consent, we will also use your email address to send you marketing communications, such as our newsletter, information about new features, or special offers we believe may be of interest to you. You will always have the ability to opt out of such marketing communications.


Finally, we use information for safety, security, and compliance. This includes monitoring for and preventing fraudulent or unauthorized activity, enforcing our Terms and Conditions, and complying with our legal obligations. For instance, we may use Usage Data like IP addresses to help protect against security breaches.

Article 4: Our Legal Basis for Collecting and Using Information

For every type of information we process, we do so under a specific legal justification as required by data protection laws. Our principal legal bases for processing your information are as follows:


When you create an account, subscribe to a paid plan, or otherwise enter into our Terms and Conditions, we process your Personal Information on the basis of performance of a contract. This processing is necessary for us to deliver the Services you have requested from us.


For certain activities, we rely on your consent. We will ask for your explicit consent before we collect and process any Sensitive Information for the purpose of personalizing your in-app experience. We will also obtain your clear consent before sending you any direct marketing materials. Where we rely on your consent, you have the right to withdraw it at any time, without affecting the lawfulness of processing based on consent before its withdrawal.


In some cases, we process your information to advance our legitimate interests, provided these interests are not overridden by your rights and freedoms. Our legitimate interests include improving and securing our Services, preventing fraud, and analyzing user engagement to enhance our business offerings. When we process data for these purposes, we conduct a balancing test to ensure our interests do not infringe upon your privacy.


Lastly, we may be required to process your information to comply with a legal obligation. This would apply, for example, if we are required to retain certain financial records for tax purposes or if we receive a lawful request for information from a law enforcement agency or court.

Article 5: How We Share and Disclose Information

We do not sell your Personal Information to third parties, and we share it only in the limited circumstances described here. Our philosophy is to share information only when necessary to operate our business and provide you with the best possible service.


We may share your information with trusted third-party service providers who perform services on our behalf. These providers are essential for our operations and include partners for website and data hosting, payment processing, customer support services, email delivery, and data analytics. We provide these partners only with the information necessary to perform their specific services, and we contractually require them to safeguard your information and prohibit them from using it for any other purpose.


We may disclose your information if we believe in good faith that it is necessary for legal reasons or to prevent harm. This includes complying with a legal obligation, such as a court order or subpoena, protecting and defending the rights or property of HealV Inc., preventing or investigating possible wrongdoing in connection with the Services, protecting the personal safety of our users or the public, and protecting against legal liability.


In the event of a business transfer, such as a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction. We will provide notice before your Personal Information is transferred and becomes subject to a different privacy policy.


Finally, we may share information with your explicit consent. For example, if we introduce a feature that allows you to share your wellness progress with a coach or friend, we would only do so with your direct authorization.

Article 6: Data Security and Retention

We take the security of your data very seriously and have implemented appropriate administrative, technical, and physical safeguards designed to protect the information we collect from accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access. We use measures such as data encryption and access controls to protect your information. However, please be aware that no security system is impenetrable, and we cannot guarantee the absolute security of our systems or that your information will not be intercepted while being transmitted to us over the Internet.


We will retain your Personal Information for as long as is necessary to fulfill the purposes for which it was collected, including for the duration your account is active and for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure, and the purposes for which we process it. We may retain anonymized Usage Data indefinitely for analytical purposes to improve our Services.

Article 7: Your Rights and Choices Regarding Your Information

We believe in giving you control over your information. Depending on your location, you may have certain rights under applicable data protection laws. These rights may include the right to access a copy of the personal information we hold about you; the right to rectification to correct any inaccurate information; and the right to erasure to request the deletion of your information. You may also have the right to restrict or object to certain processing activities and the right to data portability, which allows you to obtain your data in a structured, machine-readable format.


You can exercise some of these rights directly through the settings in your account. For all other requests, or if you do not have an account, please contact us using the details provided below. We will respond to your request in accordance with applicable law. Furthermore, you can opt out of receiving marketing emails from us at any time by clicking the “unsubscribe” link in the footer of any such email.

Article 8: International Data Transfers

Our Services are global, which means your information may be transferred to, and maintained on, computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those in your jurisdiction. As a Delaware corporation with operations based in Canada, your information will likely be processed in the United States and Canada. By using our Services, you consent to this transfer. Where required, we will ensure that such international transfers are made in compliance with applicable law by using legal mechanisms such as Standard Contractual Clauses to ensure your data receives an adequate level of protection.

Article 9: Children’s Privacy

Our Services are not directed to individuals under the age of 18, and we do not knowingly collect Personal Information from anyone under 18. If we become aware that we have inadvertently collected Personal Information from a child under the age of 18 without parental consent, we will take steps to delete that information from our servers as soon as possible.

Article 10: Changes to This Privacy Policy and Contact Us

We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. If we make material changes, we will notify you by posting the new policy on our Site and App and updating the “Effective Date” at the top. We encourage you to review this policy periodically.


If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please do not hesitate to contact us at: support@healvapp.com.