1.Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

• You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.
• Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to AIVA HEALTH.
• Application means the software program provided by the Company downloaded by You on any electronic device, named P.C.
• Account means a unique account created for You to access Our Service or parts of Our Service.
• Service refers to the Application.
• Third-party Social Media Service refers to any website or any social network website through which a user can log in or create an Account to use the Service.
• Personal Data is any information that relates to an identified or identifiable individual.
• Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
• Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
• Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.

2. What information do We collect?

The information We collect and process depends on how You use Our Service. In order to make certain features work, some information is required. For example, to help You track your menstrual cycle, dates of your recent menstrual cycle are fundamental. Other information may be optional, but the quality of your experience might be affected without it.

The information You provide and your activity
On Our App, You can track periods, menstruation, ovulation, steps and so on. Everything You can interact with on Our App is called "your activity." We collect your activity and information You provide to provide You personal service and improve Our App, including general settings You make (such as your choice of preferred language) and the time and duration of your activities on Our Service (which can help Us improve features that You may pay less attention to). When You use the App, You may choose to provide personal information about your health to gain personalized tips or track health changes. We collect health data such as weight, height, menstrual cycle, symptoms, and other information (including sexual activities) and related activities, the amount of water you drink and the number of steps you take.

Technical information We collect about You
In order to provide a better user experience, We have integrated data statistics tools into the App. They won't collect users’ health data or private data and are only used for CRASH targeting and AB-testing for new features and UI design, such as your IP address, mobile carrier, system language, country area, time zone, model of your Device, the system of your Device, your Device IDs (such as IDFA), your screen size and density, your operation system, Device mute status (related to reminder feature), your browser type and version (related to Forum feature), app version number and build, SDK name and version. Information from third-party social media services.
If You choose to use the login service (for Our backup feature) using a third-party social network Account (such as Google), in that case, We may collect some third-party data automatically, such as your Account name, email address, public profile, and other possible information associated with that Account.
Quick link: Where can You control the information We collect about You and how to do that?

3. How do We use the information?

We use the information We collect about You to provide you with a personalized experience, including healthy tips, recommended informational content, and so on. Our App doesn’t require real-name registration to use Our Service; You can remain completely anonymous in the use of Our Service.

We highly value your experience with Our App and are always trying to improve current features and keep adding new features that Our users want from time to time. Information We collect will help Us understand what to improve and how We can improve. By creating a profile to use Our App, You expressly agree to:

• We may process the health data You provide by using the App to import or export the data with third-party services, such as Apple HealthKit
• We may process the Account data You provide by using the App and create it through your Account only for the purposes of login and third-party services, such as Apple ID or Google Account, Facebook.
• Except as provided in this Privacy Policy, We will not transfer any of your Personal Data to third parties. We may use the information for the following purposes:
• To provide and improve Our Service, such as personalize the content You receive in the App;
• To see if Our App is working correctly and troubleshoot and fix it when it’s not;
• To provide You with helpful user support if You send Us feedback about any questions You may have while using Our App;
• For the performance of a contract: the development, compliance, and undertaking of the purchase contract for the products, items, or services You have purchased or of any other contract with Us through the Service;
• To communicate with You, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products, or contracted services, including the security updates, when necessary or reasonable for their implementation;
• To provide You with news, special offers, and general information about other goods, services, and events which We offer that are similar to those that You have already purchased or enquired about unless You have opted not to receive such information.
• With service providers: We may share your information with Service providers to analyze the use of Our Service, to show advertisements to You to help support and maintain Our Service, to advertise on third-party websites to You after You visit Our Service, for payment processing, to contact You.
• For example, as your consent at the registration screen, We may import into the App personal data about your health and activities from third-party services such as Apple HealthKit. The imported personal data may include: weight, body temperature, calories burnt, heartbeat rate, number of steps/distance traveled, and other data about your health. We will handle any such third-party information in accordance with this Privacy Policy.
• Ads Settings Google aims to show you relevant ads based on your interests. Use this tool to select interest categories so that the ads we show you are more related to your interests.
• Forums cookies (Webview browser cookies) - Forum cookies generally are used to deliver or optimize Our Services, to communicate with users or manage their forum Accounts, to develop content, or for the purposes of research and analysis. You may refuse to accept browser cookies by activating the appropriate setting.
• Third-party advertisers - We may use third-party advertising companies to serve ads when You visit the Application. These companies may use information about your visits to the App that is contained in cookies in order to optimize the performance of the marketing campaigns and provide ads about goods and services of interest to You. We NEVER share any data You are tracking in the App (e.g. your health data) with third-party advertisers.
• Analytics - We use third-party analytics tools, Google Analytics, to help Us measure traffic and usage trends for the Service. Google Analytics collects information such as Device, location, and app usage data. We may use the information get from Google Analytics only to customize and personalize your app experience for statistical purposes and analytics.
• For business transfers: We may share or transfer your information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company. However, before the formal business transfer could take place, You have Our promise that We will give You 2-week notice of the proposed the transfer and the basic details of the transferee company and the different Privacy Policy You will be subject to, and You will have at least two weeks to decide whether You wish to keep your Account or to delete your Account and data completely before business transfer settlement.
• Law enforcement: We share information with law enforcement agencies, public authorities, or other organizations if We’re required by law to do so or if such use is reasonably necessary. We will carefully review all such requests to ensure that they have a legitimate basis and are limited to data that law enforcement is authorized to access for specific investigative purposes only.

Detailed information on how We process the information We collect
Service providers have access to your information only to perform their tasks on Our behalf and are obligated not to disclose or use it for any other purpose.

Analytics

We may use third-party service providers to analyze the use of Our Service.

• Google Analytics
  Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track the use of Our service. This data is shared with other Google services. Google may use the collected information to contextualize and personalize the ads of its own advertising network. You may opt-out from certain Google Analytics features through your mobile Device settings, such as your Device advertising settings, or by following the instructions provided by Google in their Privacy Policy: https://policies.google.com/privacy?hl=en
  For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en

Advertising

We may use service providers to show advertisements to You to help support and maintain Our Service.

• Google AdSense & DoubleClick Cookie
  Google, as a third-party vendor, uses cookies to serve ads on Our Service. Google's use of the DoubleClick cookie enables it and its partners to serve ads to Our users based on their visit to Our Service or other websites on the Internet. You may opt out of the use of the DoubleClick Cookie for interest-based advertising by visiting the Google Ads Settings web page: http://www.google.com/ads/preferences/
• AdMob by Google
  AdMob by Google is provided by Google Inc. You can opt-out from the AdMob by Google service by following the instructions described by Google: https://support.google.com/ads/answer/2662922?hl=en

For more information on how Google uses the collected information, please visit the "How Google uses data when you use our partners' sites or app" page: https://policies.google.com/technologies/partner-sites or visit the Privacy Policy of Google: https://policies.google.com/privacy

Behavioral Remarketing

The Company uses remarketing services to advertise on third-party websites to You after You visited our Service. We and Our third-party vendors use cookies to inform, optimize and serve ads based on your past visits to Our Service.

• Google Ads (AdWords)
  Google Ads (AdWords) remarketing service is provided by Google Inc. You can opt-out from Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads Google also recommends installing the Google Analytics Opt-out Browser Add-on - https://tools.google.com/dlpage/gaoptout - for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en
• Twitter
  Twitter remarketing service is provided by Twitter Inc. You can opt-out from Twitter's interest-based ads by following their instructions: https://support.twitter.com/articles/20170405 You can learn more about the privacy practices and policies of Twitter by visiting their Privacy Policy page: https://twitter.com/privacy
• Facebook
  Facebook remarketing service is provided by Facebook Inc. You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950 To opt-out from Facebook's interest-based ads, follow these instructions from Facebook: https://www.facebook.com/help/568137493302217 Facebook adheres to the Self-Regulatory Principles for Online Behavioural Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings. For more information on the privacy practices of Facebook, please visit Facebook's Data Policy: https://www.facebook.com/privacy/explanation

Payments

We may provide paid products and/or services within the Service. In that case, we may use third-party services for payment processing (e.g. payment processors).

We will not store or collect your payment card details. That information is provided directly to Our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

• Apple Store In-App Payments
  Their Privacy Policy can be viewed at https://www.apple.com/legal/privacy/en-ww/
• Google Play In-App Payments
  Their Privacy Policy can be viewed at https://www.google.com/policies/privacy/ When You use Our Service to pay for a product and/or service via bank transfer, We may ask You to provide information to facilitate this transaction and to verify your identity.

4. Retention of the information

How long We will keep your information depends on a case-by-case basis.

• If You only store your data on your Device or backup your data without signing in with a third-party social network Account (such as Google), your data will be permanently erased (no recoverable) after You use the “Delete all data” feature in Our App;
• If You choose to backup your data using a third-party social network Account (such as Google), your data will be permanently erased (no recoverable) after You use the “Delete account” feature in Our App.
• We will retain your data only for as long as is necessary, for example, to comply with Our contractual relationship or to provide You with Our service. Where We do not need your information in order to provide the service to you, We retain it only for so long as We have a legitimate business purpose in keeping such data, as may be allowed by applicable laws.
• We will also retain the information for internal analysis purposes. This is generally retained for a shorter period of time, except when this information is used to strengthen the security or to improve the functionality of our Service, or We are legally obligated to retain this data for longer time periods.

5. Why and how do We transfer the information?

Your information is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this 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 of your jurisdiction. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer. The Company will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy, and no transfer of your personal data will take place to an organization or a country unless there are adequate controls in place, including the security of your data and other personal information.

6. How do We protect the security of your information?

We use administrative, technical, and physical security measures to help protect your information. We use the following information security measures to protect:

• Encrypt your personal data during transport and rest;
• System vulnerability scanning and penetration testing;
• Protect data integrity;
• Organizational and legal measures;
• Perform regular data protection impact assessments

The security of your information is important to Us, but please note that all Internet-based methods of data transfer and storage are not 100% secure. There are risks associated with any transfer of personal information. We keep working to develop additional techniques to protect your information, but it is difficult for Us to guarantee the absolute security of the Internet.

GDPR Privacy

Legal Basis for Processing Personal Data under GDPR
We may process personal data under the following conditions:

• Consent: You have given your consent for processing personal data for one or more specific purposes.
• Performance of a contract: Provision of personal data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.
• Legal obligations: Processing personal data is necessary for compliance with a legal obligation to which the Company is subject.
• Vital interests: Processing personal data is necessary in order to protect your vital interests or of another natural person.
• Public interests: Processing personal data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.
• Legitimate interests: Processing personal data is necessary for the purposes of the legitimate interests pursued by the Company. In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Your Rights under the GDPR

The Company undertakes to respect the confidentiality of your Personal Data and to guarantee You can exercise your rights.

You have the right under this Privacy Policy, and by law if You are within the EU, to:

• Request access to your personal data. The right to access, update or delete the information We have on You. Whenever made possible, You can access, update or request deletion of your personal data directly within your Account settings section. If You are unable to perform these actions yourself, please contact Us to assist You. This also enables You to receive a copy of the personal data We hold about You.
• Request correction of the personal data that We hold about You. You have the right to to have any incomplete or inaccurate information We hold about You corrected.
• Object to processing of your personal data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about your particular situation, which makes You want to object to Our processing of your personal data on this ground. You also have the right to object where We are processing your personal data for direct marketing purposes
• Request erasure of your personal data. You have the right to ask Us to delete or remove personal data when there is no good reason for Us to continue processing it.
• Request the transfer of your personal data. We will provide to You, or to a third-party You have chosen, your personal data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.
• Withdraw your consent. You have the right to withdraw your consent on using your personal data. If You withdraw your consent, We may not be able to provide You with access to certain specific functionalities of the Service.

Exercising of Your GDPR Data Protection Rights

You may exercise your rights of access, rectification, cancellation and opposition by contacting Us. Please note that We may ask You to verify your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.

You have the right to complain to a Data Protection Authority about Our collection and use of your personal data. For more information, if You are in the European Economic Area (EEA), please contact your local data protection authority in the EEA.

CCPA Privacy

Your Rights under the CCPA
Under this Privacy Policy, and by law if You are a resident of California, You have the following rights:

• The right to notice. You must be properly notified which categories of personal data are being collected and the purposes for which the personal data is being used.
• The right to access / the right to request. The CCPA permits You to request and obtain from the Company information regarding the disclosure of your personal data that has been collected in the past 12 months by the Company or its subsidiaries to a third-party for the third party's direct marketing purposes.
• The right to say no to the sale of personal data. You also have the right to ask the Company not to sell your personal data to third parties. You can submit such a request by visiting Our "Do Not Sell My Personal Information" section or web page.
• The right to know about your personal data. You have the right to request and obtain from the Company information regarding the disclosure of the following:
• The categories of personal data collected
• The sources from which the personal data was collected
• The business or commercial purpose for collecting or selling the personal data
• Categories of third parties with whom We share personal data
• The specific pieces of personal data We collected about You
• The right to delete personal data. You also have the right to request the deletion of your personal data that have been collected in the past 12 months.
• The right not to be discriminated against. You have the right not to be discriminated against for exercising any of your consumer's rights, including by:
• Denying goods or services to You
• Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
• Providing a different level or quality of goods or services to You
• Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services.

Exercising Your CCPA Data Protection Rights

In order to exercise any of your rights under the CCPA, and if You are a California resident, You can email or call Us or visit Our "Do Not Sell My Personal Information" section or web page. The Company will disclose and deliver the required information free of charge within 45 days of receiving your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonable necessary and with prior notice.

Do Not Sell My Personal Information

We do not sell personal information. However, when You use the Service, third-party advertising companies may display interest-based advertising (also called online behavioral advertising) using information collected about your online activities over time across multiple websites, applications, and other online service sites. You can opt-out of interest-based advertising by selecting "Do Not Allow" in the system's ad tracking options if You have any concerns about this or other targeted content.

If You wish to opt out of the use of your personal information for interest-based advertising purposes and these potential sales as defined under CCPA law, You may do so by following the instructions below.
If You do not want to receive ads targeted to your interests from Apple's advertising platform in those apps, You can choose to disable Personalized Ads, which will opt your Apple ID out of receiving such ads regardless of what Device You are using. On your iOS or iPadOS Device, You can disable Personalized Ads by going to Settings > Privacy > Apple Advertising and tapping to turn off Personalized Ads.

More information as below.
https://www.apple.com/legal/privacy/en-ww/
Please note that any opt out is specific to the browser You use. You may need to opt out on every browser that You use.

Website

You can opt out of receiving ads that are personalized as served by Our service providers by following Our instructions presented on the Service:

• From Our "Cookie Consent" notice banner
• Or from Our "CCPA Opt-out" notice banner
• Or from Our "Do Not Sell My Personal Information" notice banner
• Or from Our "Do Not Sell My Personal Information" link

The opt out will place a cookie on your computer that is unique to the browser You use to opt out. If You change browsers or delete the cookies saved by your browser, You will need to opt out again.

Mobile Devices

Your mobile Device may give You the ability to opt out of the use of information about the apps You use in order to serve You ads that are targeted to your interests:

• "Opt out of Interest-Based Ads" or "Opt out of Ads Personalization" on Android Devices
• "Limit Ad Tracking" on iOS Devices

You can also stop the collection of location information from your mobile Device by changing the preferences on your mobile Device.

"Do Not Track" Policy as Required by California Online Privacy Protection Act (CalOPPA)

We do not track Our customers over time and across third party websites to provide targeted advertising therefore Our Service does not respond to Do Not Track signals.
However, some third party websites do keep track of your browsing activities. If You are visiting such websites, You can set your preferences in your web browser to inform websites that You do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of your web browser.

Children's Privacy

Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that your child has provided Us with personal data, please contact Us. (link)
If We become aware that We have collected personal data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.

Your California Privacy Rights (California Business and Professions Code Section 22581)

California Business and Professions Code section 22581 allow California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted.

To request removal of such data, and if You are a California resident, You can contact Us using the contact information provided below, and include the email address associated with your Account. Be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

7. How do We notify You of the changes to this Privacy Policy?

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page. We will let You know via email and/or a prominent notice on Our Service prior to the change becoming effective and update the "Last Updated" date at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

8. How to contact Us if You have any questions?

It should be noted that whether or not to send Us your feedback or bug report is a completely voluntary initiative upon your own decision. If You have a concern about your personal data being misused, or if You want further information about Our Privacy Policy and what it means, please feel free to email Us at policy@aivahealth.group. We will endeavor to provide clear answers to your questions in a timely manner.