Privacy Policy

Introduction

This Privacy Policy (“Policy”) describes how Valagar Limited (“ZIVO,” “Company,” “we,” “us,” or “our”), a private limited company incorporated in the Republic of Cyprus under registration number HE 451841, with its registered office at 34 Nikou Pattichi, Niki Court, Floor 4, 3071 Limassol, Cyprus (the “Registered Office”), collects, uses, discloses, and protects personal information when you use the ZIVO mobile application and any related website at https://zivo.valagar.com (together, the “Services”).

The Services are made available to users globally, including in the European Union, the United States, the United Kingdom, and the rest of the world. Wherever you access the Services from, this Policy applies to you, and Section 12 explains how your rights may vary depending on where you are located.

By accessing or using the Services, you acknowledge that you have read and understood this Policy. If you do not agree with this Policy, please do not use the Services.

If you have questions about this Policy or our data practices, contact us at contact@valagar.com.

1. Who We Are

Valagar Limited is the data controller responsible for your personal information processed in connection with the Services. Valagar Limited is registered in the Republic of Cyprus under registration number HE 451841, with its Registered Office at 34 Nikou Pattichi, Niki Court, Floor 4, 3071 Limassol, Cyprus.

For all privacy questions, requests, or complaints, contact us at contact@valagar.com.

2. What Information We Collect

2.1 Information You Provide to Us

• Account information: your name and email address, received from Apple or Google when you sign in using Sign in with Apple or Google Sign-In. We do not use passwords; authentication is handled entirely by Apple or Google.
• Uploaded Content: screenshots, images, and text of conversations you choose to upload so that we can generate message suggestions (“Uploaded Content”). Uploaded Content may incidentally include personal information about you and third parties (for example, a match’s name, photo, or messages).
• Communications: information you provide when you contact us for support, including your name, email address, and the content of your message.
• Payment confirmation data: if you purchase a subscription, payment is handled by RevenueCat together with the Apple App Store and/or Google Play, who act as merchant of record. We do not store your full payment card details or invoices ourselves; we receive limited confirmation data from these providers (such as transaction status and subscription tier).

2.2 Information Collected Automatically

• Device and log data: device identifiers, model, operating system, browser type, IP address, mobile carrier, and crash or diagnostic data.
• Usage data: features used, screens viewed, timestamps, and interactions with the Services.
• Location data: approximate location inferred from your IP address. We do not request or collect precise device location.

2.3 Permissions

• Camera and Photo Library Access: with your permission, the app accesses your device’s camera and photo library so you can upload screenshots of conversations for the app to analyze and generate suggestions. This access is used solely to enable that feature. You may withdraw permission at any time in your device settings, which may limit the feature’s functionality.
• Push Notifications: with your permission, we send notifications about your account and app features. You may disable these in your device settings.

2.4 Sensitive Information

We do not intentionally request special categories of personal data as defined under Article 9 GDPR (for example, data revealing sexual orientation, religious beliefs, or health). However, because Uploaded Content is user-generated dating-app material, it may incidentally reveal such information about you or the people you are messaging. We process Uploaded Content solely to provide the requested feature and do not use it to infer or categorize sensitive attributes.

3. How We Use Your Information

We process your information to:

• Provide and operate the Services, including generating AI-based message suggestions from your Uploaded Content;
• Create and manage your account;
• Process payments and manage subscriptions;
• Respond to support requests and communicate with you about the Services;
• Monitor, maintain, and improve the Services, including troubleshooting and analytics;
• Detect, investigate, and prevent fraud, abuse, and security incidents;
• Comply with our legal obligations; and
• With your consent, send you marketing communications, which you may opt out of at any time.

4. Legal Bases for Processing

Where the GDPR or UK GDPR applies, we rely on the following legal bases to process your personal information:

• Performance of a contract: to provide the Services you have requested, including account creation and AI-generated suggestions.
• Consent: for optional features such as camera/photo access, push notifications, and marketing communications. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.
• Legitimate interests: to secure and improve the Services, prevent fraud, and understand usage, provided these interests do not override your rights and freedoms.
• Legal obligation: to comply with applicable law, respond to lawful requests from public authorities, and enforce our terms.

5. AI-Powered Features and Automated Processing

The core feature of the Services uses artificial intelligence to analyze Uploaded Content and generate personalized message suggestions. To provide this feature, Uploaded Content and related account information are transmitted to Google (Google LLC and/or Google Ireland Limited), which provides the underlying AI models, and processed in data centers located in the European Union and the United States.

Google processes this information as our processor under a data processing agreement and is contractually restricted from using it for its own purposes, including training its general-purpose models, except as required to provide the service to us or as required by law.

The suggestions generated by our AI features do not produce legal or similarly significant effects concerning you and do not constitute solely automated decision-making within the meaning of Article 22 GDPR: a suggestion is provided for your own review, and you decide whether and how to use it.

6. When and With Whom We Share Your Information

We do not sell your personal information. We may share your information with:

• Hosting and infrastructure: Cloudflare, which hosts our application, website, database, and uploaded images on its global network (see Section 7).
• AI processing: Google, which provides the AI models used to generate message suggestions (see Section 5).
• Subscription and payment processing: RevenueCat, Apple App Store, and Google Play, who process subscription payments as merchant of record.
• Legal and safety purposes: where required to comply with law, respond to legal process, or protect the rights, property, or safety of ZIVO, our users, or the public.
• Business transfers: in connection with a merger, acquisition, financing, or sale of assets, subject to this Policy or a substantially similar policy.
• With your consent: in other circumstances disclosed to you at the time of collection.

We do not use any third-party analytics, marketing, or advertising services, so your information is not shared with, or used by, ad networks or analytics platforms.

A current list of our sub-processors is available on request at contact@valagar.com.

7. International Data Transfers

The Services are offered globally, including to users in the European Union, the United States, the United Kingdom, and the rest of the world, and our servers and processing infrastructure are located and operated globally rather than in any single country or region. Our infrastructure runs on Cloudflare, a US-headquartered provider. Application requests are processed on Cloudflare’s global edge network, at whichever location is nearest to the user — including data centers in the EU, the US, and other regions worldwide. Stored data — including our database and uploaded images — is currently placed automatically across Cloudflare’s global network and is not pinned to a specific region (for example, the EU).

Because the Services are used globally, your information may be processed in a country other than the one in which you reside — including the European Union, the United States, and other countries — regardless of where you access the Services from. Some of these countries may not have data protection laws equivalent to those of your home jurisdiction. Regardless of where your information is processed, we apply the protections described in this Policy.

As a result, your personal information, including Uploaded Content, is expected to be transferred to and processed in the European Union, the United States, and other countries worldwide, in addition to the transfers to Google described in Section 5. Where we transfer personal information outside the EEA or UK to a country that has not been recognized by the European Commission (or UK authorities) as providing an adequate level of protection, we rely on appropriate safeguards, including the European Commission’s Standard Contractual Clauses and Cloudflare’s Data Processing Agreement (and the UK International Data Transfer Addendum, where applicable).

A copy of the relevant safeguards is available on request at contact@valagar.com.

8. Cookies and Similar Technologies

We use cookies on an essential-only basis. We do not use analytics, marketing, or advertising cookies or trackers of any kind, anywhere in the app or website.

• Analytics cookies: none.
• Marketing cookies: none.
• Advertising cookies: none.

We use exactly two strictly-necessary/functional cookies:

• A login session cookie that keeps you signed in.
• A cookie on our website that remembers whether a UI panel is open or closed.

Because these cookies are strictly necessary for the Services to function, they do not require consent under applicable cookie laws, and there are no optional or third-party cookies to opt out of. You can still clear or block cookies through your browser settings, but doing so will sign you out and reset the UI panel state.

9. How Long We Keep Your Information

We retain personal information as follows:

• Account data: retained for as long as your account exists. We delete it on request — email contact@valagar.com to request deletion of your account and associated data.
• AI uploads (screenshots and Uploaded Content): retained for up to 180 days from upload, after which they are automatically deleted. You may request earlier deletion at any time by emailing contact@valagar.com.
• Login sessions: kept for up to 400 days.
• Invoices and payment records: not stored by us. Subscriptions are processed by RevenueCat, Apple, and Google, who act as merchant of record and hold these records under their own retention policies.

You may request deletion of your account and data at any time by emailing contact@valagar.com.

10. How We Keep Your Information Safe

We implement appropriate technical and organizational measures designed to protect your information, including encryption in transit, access controls, and vendor due diligence. No method of transmission or storage is 100% secure, and we cannot guarantee absolute security.

11. Children's Privacy

The Services are intended for users who are at least 18 years old. We do not knowingly collect personal information from anyone under 18. If we learn we have collected such information, we will delete it and deactivate the associated account. If you believe a child has provided us with personal information, contact us at contact@valagar.com.

12. Your Privacy Rights

12.1 If You Are Located in the EEA, UK, or a Jurisdiction With Similar Data Protection Laws

If the GDPR, UK GDPR, or another applicable data protection law grants you rights over your personal information, you may have the right to:

• Access a copy of your personal information;
• Rectify inaccurate or incomplete information;
• Erase your personal information, in certain circumstances;
• Restrict or object to our processing of your information;
• Receive your information in a portable format; and
• Withdraw consent at any time, without affecting the lawfulness of processing before withdrawal.

If you are in the EEA or UK and believe we have processed your information unlawfully, you have the right to lodge a complaint with a supervisory authority, including the Cyprus Office of the Commissioner for Personal Data Protection (www.dataprotection.gov.cy) or the data protection authority of your country of residence.

12.2 If You Are Located Anywhere Else in the World

The Services are used by people worldwide, including in jurisdictions that do not have a GDPR-equivalent data protection law (for example, the CCPA/CPRA in California, PIPEDA in Canada, or the LGPD in Brazil). Regardless of where you are located, we extend the same core rights described in Section 12.1 to you on a best-efforts basis: you may ask us to provide access to, correct, or delete your personal information, and to stop processing it, by contacting us at contact@valagar.com.

To exercise any of the rights described in this Section 12, contact us at contact@valagar.com. We will respond in accordance with applicable law.

13. Do-Not-Track Signals

Our Services do not currently respond to Do-Not-Track browser signals.

14. Third-Party Websites and Links

The Services may link to third-party websites or services not operated by us, including the Apple App Store and Google Play. We are not responsible for the privacy practices of those third parties, and we encourage you to review their privacy policies.

15. Changes to This Policy

We may update this Policy from time to time. We will post the revised Policy with an updated “Last updated” date and, for material changes, provide additional notice (for example, an in-app notification or email).

16. How to Contact Us

If you have questions, concerns, or requests regarding this Policy or our data practices, contact us at:

Valagar Limited, 34 Nikou Pattichi, Niki Court, Floor 4, 3071 Limassol, Republic of Cyprus. Email: contact@valagar.com.