This Privacy Notice for Evoogen Ltd (“we”, “us”, or “our”) describes how and why we might access, collect, store, use, and/or share (“process”) your personal information when you use our services (“Services”), including when you download and use our mobile application (Improven).
Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have questions, you may contact us at support@evoogen.com.
Summary of Key Points
This summary provides key points from our Privacy Notice. You can find more details about any of these topics in the full notice below.
- What personal information do we process? We may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use.
- Do we process any sensitive personal information? Yes. When you use our AI coaches — for example the mood check-in or the Reflection Guide — we may process information about your emotional and mental wellbeing. This is treated as special category (health) data and is processed only with your explicit consent.
- Do we receive any information from third parties? If you sign in with Apple or Google, we receive basic profile information (such as your name and email address) from those providers.
- How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law.
- In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties.
- How do we keep your information safe? We have adequate organisational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure.
- What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.
1. What Information Do We Collect?
Personal information you disclose to us
We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.
Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include:
- Names
- Email addresses
- Passwords
Sensitive Information. When you interact with our AI coaches — for example by using the mood check-in or describing how you feel in a coaching or reflection session — we may process information that reveals your emotional state or mental health. Under UK GDPR (Article 9) this is “special category” data. We process it only on the basis of your explicit consent (Article 9(2)(a)), which you provide by choosing to use the coaching and reflection features. You can withdraw this consent at any time by stopping use of those features or by contacting us at support@evoogen.com.
Payment Data. In-app purchases and subscriptions are planned for a future version of the app (version 1.1) and are not active in the current version, so we do not currently collect or store any payment card details. When subscriptions launch, payments will be handled through the Apple App Store and managed via RevenueCat, and we will not receive or store your full card number. RevenueCat’s privacy notice is available here: https://www.revenuecat.com/privacy
Social Login Data. We offer you the option to create an account or sign in using Sign in with Apple or your Google account. If you choose this, we collect limited profile information — such as your name and email address — from Apple or Google, as described in the section called “How Do We Handle Your Social Logins?” below.
Application Data. If you use our application(s), we also may collect the following information if you choose to provide us with access or permission: Mobile Device Data (device information such as your mobile device ID, model, and manufacturer, operating system, version information, system configuration information, device and application identification numbers, browser type and version, hardware model, Internet service provider and/or mobile carrier, and Internet Protocol (IP) address), and Push Notifications (we may request to send you push notifications regarding your account or certain features of the application(s)).
2. How Do We Process Your Information?
We process your personal information for the reasons set out below. Where UK GDPR applies, the legal basis we rely on for each purpose is shown in brackets — the performance of our contract with you, your consent, our legitimate interests, or compliance with a legal obligation.
- To create and authenticate your account and otherwise manage it. (Performance of a contract.)
- To provide and operate the Services, including our AI coaching, habit, and reflection features. (Performance of a contract.)
- To process the emotional and wellbeing information you choose to share with our coaches. (Your explicit consent.)
- To respond to your enquiries and provide support. (Performance of a contract; legitimate interests.)
- To send you service and administrative messages, including changes to our terms and policies. (Legitimate interests; legal obligation.)
- To send push notifications you have enabled. (Your consent.)
- To manage your subscription, once in-app purchases become available in a future version of the app. (Performance of a contract.)
- To keep the Services secure and to monitor and prevent fraud and abuse. (Legitimate interests.)
- To analyse usage trends and to evaluate and improve our Services and your experience. (Legitimate interests.)
- To comply with our legal obligations and to establish, exercise, or defend legal claims. (Legal obligation; legitimate interests.)
3. When and With Whom Do We Share Your Personal Information?
We share your personal information only in the following situations and with the following categories of third parties:
- Service Providers (Sub-processors). We share information with trusted providers who help us run the Services. These currently are: OpenAI (to generate AI coach responses from the messages you send), Supabase (hosting of our database and storage of your account data and coaching conversations), Apple (Sign in with Apple and delivery of push notifications), and Google (Google Sign-in). Subscription billing through RevenueCat will be added in a future version of the app.
- 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.
- Legal and Safety. We may disclose information where required to comply with the law, enforce our terms, or protect the rights, safety, and security of our users or others.
4. Do We Use Cookies and Tracking Technologies?
Improven is a mobile application and does not use website cookies, web beacons, or advertising pixels. We do rely on a limited set of mobile technologies: a device identifier and push token, used only to deliver the notifications you have enabled, and crash and error diagnostics, used to detect bugs and keep the app stable.
We do not use advertising trackers, we do not display third-party advertising inside the app, and we do not sell your information or share it with advertising networks.
5. How Do We Handle Your Social Logins?
Our Services let you create an account and sign in using Sign in with Apple or your Google account. When you do, we receive limited profile information from that provider — typically your name and email address. With Sign in with Apple you may choose to hide your email, in which case we receive only a private relay address. We do not receive your contacts or friends list, and we never post anything on your behalf.
We use the information we receive only for the purposes described in this Privacy Notice. We do not control, and are not responsible for, other uses of your personal information by Apple or Google. We recommend you review their privacy notices to understand how they collect, use, and share your personal information.
6. Is Your Information Transferred Internationally?
Your account data and your conversations with our AI coaches are stored on servers operated by Supabase in the United Kingdom (West Europe / London region). This is our primary place of storage.
To generate AI coach responses, the content of your messages is sent to OpenAI, which processes it on servers in the United States. Where personal information is transferred from the UK to the United States, we rely on a recognised UK transfer mechanism — the UK International Data Transfer Agreement (IDTA) or the UK Addendum to the EU Standard Contractual Clauses — to keep your information protected.
If you are located in the UK, EEA, or Switzerland, we take the measures required by applicable law to ensure your personal information remains protected whenever it is transferred internationally.
7. How Long Do We Keep Your Information?
We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
8. How Do We Keep Your Information Safe?
We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.
Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.
9. Do We Collect Information From Minors?
We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at support@evoogen.com.
10. What Are Your Privacy Rights?
In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information.
We will consider and act upon any request in accordance with applicable data protection laws.
If you are located in the EEA or UK and believe we are unlawfully processing your personal information, you have the right to lodge a complaint with a data protection authority. In the United Kingdom this is the Information Commissioner’s Office (ICO), which you can contact at ico.org.uk or on 0303 123 1113. In the EEA, you may complain to your Member State’s supervisory authority.
Withdrawing your consent: If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us at support@evoogen.com.
Account Information: If you would at any time like to review or change the information in your account or terminate your account, you can contact us using the contact information provided. Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.
11. Controls for Do-Not-Track Features
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online.
12. Do United States Residents Have Specific Privacy Rights?
If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information.
You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To exercise these rights, you can submit a request by contacting us at support@evoogen.com.
13. Do We Use AI Products?
We offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies (collectively, “AI Products”). These tools are designed to enhance your experience and provide you with innovative solutions. The terms in this section apply when you use our AI Products.
Use of AI Technologies. We provide the AI Products through third-party service providers (“AI Service Providers”), including OpenAI. As outlined in their terms, we will not use your data for training or improving their AI models unless you specifically request that we share your data with them for this purpose.
Our AI Products are designed for the following functions: AI coaching, AI bots, and natural language processing. You may interact with our AI Products through the Services. Please review the terms of the relevant AI Service Providers before using the AI-powered features.
14. Do Other Regions Have Specific Privacy Rights?
Australia and New Zealand
We collect and process your personal information under the obligations and conditions set by Australia’s Privacy Act 1988 and New Zealand’s Privacy Act 2020 (Privacy Act).
Republic of South Africa
At any time, you have the right to request access to or correction of your personal information. You also have the right to object to the processing of your personal information. If you are unsatisfied with the manner in which we address any complaint with regard to our processing of personal information, you can contact the office of the regulator.
15. Do We Make Updates to This Notice?
We may update this Privacy Notice from time to time. The updated version will be indicated by an updated “Last updated” date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.
16. How Can You Contact Us About This Notice?
If you have questions or comments about this notice, you may email us at support@evoogen.com.
17. How Can You Review, Update, or Delete the Data We Collect From You?
Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. To request to review, update, or delete your personal information, please contact us at support@evoogen.com.