Sapio Privacy Policy

Last Updated: December 17, 2024

This Privacy Policy describes how Sapio ("Sapio," "we," "us," or "our") collects, uses, shares, and protects your personal information when you use our mobile application, website, and related services (collectively, the "Services"). Please read this policy carefully to understand our views and practices regarding your personal data and how we will treat it.

By using our Services, you agree to the collection and use of information in accordance with this policy. If you do not agree with this policy, please do not use our Services.

TABLE OF CONTENTS

• Information We Collect
• How We Use Your Information
• Legal Basis for Processing Personal Information (EEA/UK Users)
• How We Share Your Information
• Cookies and Similar Technologies
• Data Retention and Deletion
• Your Data Protection Rights
• Data Security
• International Data Transfers
• Children's Privacy
• Third-Party Links and Services
• Changes to This Privacy Policy
• Contact Us

1. INFORMATION WE COLLECT

We collect information to provide, improve, and personalize our Services. The types of information we collect, as also declared in our App Store privacy details, include:

A. Information You Provide Directly:

• Contact Info:
  • Name: Your first or last name, or full name, provided during account creation or profile setup.
  • Email Address: Your email address, used for account creation, login, communication, and account recovery.
  • Phone Number: Your phone number, if you choose to provide it for your profile or for features such as account verification or recovery.
• Health & Fitness:
  • Fitness: Information you provide about your exercise habits or fitness-related activities as part of your profile.
• User Content:
  • Emails or Text Messages (within the app): Messages you send and receive with other users through our in-app chat feature.
  • Photos or Videos: Photos and videos you upload to your profile or share through the Services.
  • Other User Content: Any other information you generate or share on the platform, such as your profile heading, Q&A responses, interests, and other textual or media content. This may include "Sensitive Info" (see below) if you voluntarily provide it.
• Sensitive Info: Information you voluntarily provide in your profile or Q&A that may be considered sensitive under applicable laws, such as your religious beliefs, ethnicity, or relationship preferences. We collect this information only with your explicit input to enhance your profile and matching experience.
• Purchase Information: If you make in-app purchases (e.g., premium subscriptions, jokers), we and our third-party payment processors (Apple App Store, Google Play Store) collect information related to your purchase history, such as the product ID, price, and transaction details to process your payments and provide you with the purchased services. We do not directly collect or store your full payment card information.

B. Information We Collect Automatically When You Use Our Services:

• Location:
  • Precise Location: With your explicit permission, we collect your precise geolocation (e.g., latitude and longitude from GPS) to enable features such as showing nearby users or providing location-based services. You can typically control or disable precise location collection through your device settings or our app settings.
  • Coarse Location: We may collect or infer your approximate location (e.g., city, country) based on your IP address, device settings, or information you provide in your profile (like city and country).
• Identifiers:
  • User ID: A unique identifier assigned to your Sapio account (e.g., Firebase Authentication UID) to identify you within our Services.
  • Device ID: Identifiers associated with your device, such as Apple's Identifier for Advertisers (IDFA) (if you provide consent via App Tracking Transparency for non-tracking purposes like analytics or fraud prevention), Android Advertising ID, or other device-level identifiers. We also collect device tokens (e.g., FCM tokens) for delivering push notifications.
• Usage Data (Product Interaction): Information about how you interact with our Services, including app launches, features used, content viewed, users you interact with, swipes, matches, time spent on screens, frequency and duration of your activities, screen views, and other actions you take.
• Diagnostics:
  • Crash Data: Information related to app crashes and errors, including stack traces, device state at the time of crash, and other diagnostic information to help us identify and fix bugs. (Note: This data is generally not linked to your user identity unless you have explicitly enabled such linking with our crash reporting service provider).
  • Performance Data: Data about the performance of our app on your device, such as app launch time, screen rendering times, network request latency, and resource usage (e.g., battery, CPU) to help us optimize and improve our Services. (Note: This data is generally not linked to your user identity).
• Cookies and Similar Technologies: We and our service providers may use cookies, web beacons, pixel tags, SDKs, and similar technologies to collect information about your browsing activities, preferences, and to provide and improve our Services. See Section 5 for more details.

2. HOW WE USE YOUR INFORMATION

We use the information we collect for the purposes described below, consistent with our App Store privacy declarations. We do not use your personal information for "tracking" purposes as defined by Apple (i.e., linking user or device data collected from our app with user or device data collected from other companies’ apps, websites, or offline properties for targeted advertising or advertising measurement purposes, or sharing user or device data with data brokers).

• Contact Info (Name, Email Address, Phone Number):
  • Used for App Functionality: To create and manage your account, authenticate you, provide customer support, communicate important service-related notices (e.g., security alerts, updates to terms), and enable features dependent on this information.
• Health & Fitness (Fitness):
  • Used for App Functionality: To display this information on your profile as part of your self-description and to help other users understand your lifestyle.
  • Used for Product Personalization: To potentially help in matching you with users who have similar or compatible fitness interests or habits.
• Location (Precise Location, Coarse Location):
  • Used for App Functionality: To enable location-based features such as showing you nearby users, displaying your city/country on your profile, and for safety/security purposes (e.g., fraud prevention).
  • Used for Product Personalization: To personalize your experience by showing relevant local content or user suggestions based on your general or precise location.
  • Used for Analytics (primarily Coarse Location): To understand the geographic distribution of our users, analyze regional usage trends, and improve our services for different locales.
• Sensitive Info:
  • Used for App Functionality: To display this information on your profile as part of your self-description, based on your explicit choice to share it, to facilitate connections with like-minded individuals.
  • Used for Product Personalization: To help in matching you with users who share or are compatible with the sensitive information you've provided (e.g., similar religious beliefs or relationship preferences).
• User Content (Emails or Text Messages (in-app), Photos or Videos, Other User Content):
  • Used for App Functionality: To enable you to communicate with other users, create and display your profile, share your thoughts and experiences, and participate in Q&A features.
  • Used for Product Personalization: The content you provide may be used to understand your preferences and personalize your experience or suggestions.
  • Used for Analytics (often in aggregated/anonymized form): To understand how content features are used, identify popular topics, and improve content-related functionalities.
• Identifiers (User ID, Device ID):
  • Used for App Functionality (User ID, Device ID for push notifications): To uniquely identify your account, link your data and activities to your profile, manage your session, provide a consistent experience, and deliver push notifications.
  • Used for Analytics (User ID, Device ID): To measure user engagement, track feature usage, understand user flows, segment users for analysis, and improve our services. Device ID (like IDFA, with consent for non-tracking purposes) can help in attributing app installs or understanding user acquisition channels.
  • Used for Product Personalization (User ID, Device ID): To personalize your experience based on your past interactions or device characteristics.
  • Used for Developer's Advertising or Marketing (Device ID): Your Device ID may be used for our own marketing efforts, such as measuring the effectiveness of our ad campaigns (attribution) or for analytics to understand our user base for our own marketing strategies. We do not use it for targeted third-party advertising.
• Purchases (Purchase History):
  • Used for App Functionality: To provide you with access to purchased premium features, subscriptions, or jokers, and to manage your subscription status.
  • Used for Analytics: To track sales, understand purchasing behavior, analyze the performance of different subscription tiers or items, and for financial reporting.
  • Used for Product Personalization: To tailor offers or suggestions based on your purchase history.
  • Used for Developer's Advertising or Marketing: To offer relevant upgrades, promotions, or new products from Sapio based on your past purchases or subscription status.
• Usage Data (Product Interaction):
  • Used for Analytics: This is a primary use. To understand how users navigate and use our Services, identify popular features, areas for improvement, user drop-off points, and overall user engagement.
  • Used for App Functionality: To improve the user interface and user experience based on interaction patterns, and to enable certain features that rely on past interactions (e.g., "recently viewed").
  • Used for Product Personalization: To tailor the app experience, content suggestions, and feature recommendations based on your specific usage patterns.
  • Used for Developer's Advertising or Marketing: To identify segments of users based on their engagement with certain features for targeted communications about those or related features from Sapio.
• Diagnostics (Crash Data, Performance Data):
  • Used for App Functionality: To identify, diagnose, and fix bugs, crashes, and performance issues, thereby improving the stability, reliability, and speed of the Services.
  • Used for Analytics: To monitor the overall health of the app, track crash rates, identify performance bottlenecks across different devices and OS versions, and understand the impact of updates.

We may also use aggregated or de-identified information that can no longer reasonably identify you for research, analytics, and other legitimate business purposes.

3. LEGAL BASIS FOR PROCESSING PERSONAL INFORMATION (EEA/UK USERS)

If you are located in the European Economic Area (EEA) or the United Kingdom (UK), our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it. However, we will normally collect personal information from you only:

• Where we need the personal information to perform a contract with you (e.g., to provide our Services, manage your account).
• Where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms (e.g., for analytics, improving our Services, fraud prevention).
• Where we have your consent to do so (e.g., for collecting precise location, using certain non-essential cookies or tracking technologies).
• Where we have a legal obligation to collect personal information from you.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided below.

4. HOW WE SHARE YOUR INFORMATION

We do not sell your personal information. We do not share your personal information with third parties for their direct marketing purposes. We may share your information in the following circumstances:

• With Other Users: Your public profile information (name, photos, interests, Q&A, fitness info, coarse location, sensitive info you choose to share, etc.) and certain activity will be visible to other users. Messages you send will be visible to the recipients.
• With Service Providers: We share information with third-party vendors who perform services on our behalf, such as cloud hosting and database management (e.g., Firebase/Google Cloud Platform, primarily in the us-central1 region and potentially other global regions for redundancy and performance), analytics (e.g., Firebase Analytics, Google Analytics), customer support, payment processing (Apple App Store, Google Play Store), crash reporting (e.g., Firebase Crashlytics), and performance monitoring (e.g., Firebase Performance). These providers are contractually obligated to protect your information and use it only for the services they provide to us.
• For Legal Reasons & Safety: We may disclose your information if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of Sapio, (iii) prevent or investigate possible wrongdoing in connection with the Services, (iv) protect the personal safety of users of the Services or the public, or (v) protect against legal liability.
• In Connection with a Business Transfer: If Sapio is involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of all or a portion of our assets, your information may be sold or transferred as part of that transaction. We will notify you via email and/or a prominent notice on our Services of any change in ownership or uses of your personal information.
• With Your Consent: We may share your information for other purposes with your explicit consent.

5. COOKIES AND TRACKING TECHNOLOGIES

We and our service providers (like Firebase) use cookies, SDKs (Software Development Kits), device identifiers (like IDFA with your consent for non-tracking purposes such as analytics or attribution), and similar tracking technologies to collect and use information to operate and improve our Services, for analytics, and to understand user behavior. For example, Firebase SDKs help us with analytics, crash reporting, performance monitoring, and authentication. You can often control these technologies through your browser or device settings, but disabling them may affect your ability to use some features of our Services. We do not use these technologies for cross-app or cross-website tracking for third-party advertising purposes.

6. DATA RETENTION AND DELETION

We retain your personal information for as long as your account is active or as needed to provide you with the Services. We may also retain information for longer periods as necessary to comply with our legal obligations (e.g., record-keeping for financial or legal purposes), resolve disputes, enforce our agreements, or for legitimate business interests like fraud prevention and security.

When you request to delete your account via the in-app account deletion feature, we will initiate the process to permanently and irreversibly delete your personal information from our active systems. This includes your profile information, photos, messages, Q&A, fitness data, location data associated with your account, and other user content. This process will be completed within a commercially reasonable timeframe from the request, though some data may persist in backup archives for a limited period before being overwritten or deleted, in accordance with our backup policies and technical limitations. Once deleted from active systems, your personal data cannot be recovered.

Please note that we may retain certain aggregated or de-identified information that no longer reasonably identifies you for research, analytics, or product improvement purposes indefinitely.

If you have an active subscription at the time of deletion, it will be managed according to the terms of the respective app store (Apple App Store or Google Play Store) and our Terms of Use. Typically, no refunds are provided for unused portions of subscriptions.

7. YOUR DATA PROTECTION RIGHTS

Depending on your location and applicable data protection laws (such as GDPR for EEA/UK residents, CCPA/CPRA for California residents), you may have the following rights regarding your personal information:

• The right to **access** the personal information we hold about you.
• The right to request **correction** of inaccurate personal information.
• The right to request **erasure** of your personal information (the "right to be forgotten").
• The right to **object to processing** of your personal information.
• The right to request **restriction of processing** of your personal information.
• The right to **data portability** (to receive your data in a structured, commonly used, and machine-readable format and to transmit it to another controller).
• The right to **withdraw consent** at any time, where we are relying on consent to process your personal information (this will not affect the lawfulness of any processing carried out before you withdraw your consent).
• The right to **not be subject to a decision based solely on automated processing**, including profiling, which produces legal effects concerning you or similarly significantly affects you (we currently do not engage in such automated decision-making that has legal or similarly significant effects).
• The right to **lodge a complaint** with a data protection supervisory authority in your jurisdiction if you believe our processing of your personal information infringes applicable data protection law.

To exercise any of these rights, please contact us at contact@sapio.fun. We will respond to your request in accordance with applicable law. We may need to verify your identity before fulfilling your request, for security reasons.

8. DATA SECURITY

We implement robust technical and organizational security measures designed to protect the personal information we process. These measures include encryption (both in transit and at rest where appropriate), access controls, secure network architectures, and regular security assessments. We use reliable infrastructure providers like Google Cloud Platform (for Firebase) which maintain high security standards. However, no electronic transmission or storage of information can be entirely secure, so we cannot guarantee absolute security.

9. INTERNATIONAL DATA TRANSFERS

Sapio is a global service. Your personal information will be processed in and transferred to countries outside of your country of residence, including the United States (primarily the us-central1 region for Firebase Cloud Functions and Firestore database, and potentially other Google Cloud regions globally for other Firebase services and content delivery), where data protection laws may differ from those in your jurisdiction.

We take appropriate safeguards to ensure that your personal information remains protected in accordance with this Privacy Policy and applicable data protection laws when it is transferred internationally. For transfers of personal information from the European Economic Area (EEA), United Kingdom (UK), and Switzerland to countries not deemed to provide an adequate level of data protection by the European Commission or relevant authorities, we rely on appropriate legal mechanisms such as Standard Contractual Clauses (SCCs) approved by the European Commission, or other derogations or safeguards as permitted by applicable law.

10. CHILDREN'S PRIVACY

Our Services are not intended for or directed at individuals under the age of 18 (or the applicable age of majority in their jurisdiction if higher). We do not knowingly collect personal information from children. If we learn that we have collected personal information from a child without verification of parental consent, we will take steps to delete that information promptly. If you believe that we might have any information from or about a child, please contact us at contact@sapio.fun.

11. THIRD-PARTY LINKS AND SERVICES

Our Services may contain links to other websites, services, or applications that are not operated or controlled by Sapio (e.g., links shared by users within profiles or messages). This Privacy Policy does not apply to such third-party services. We encourage you to review the privacy policies of any third-party services before providing any information to or through them.

12. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. If we make material changes, we will notify you by updating the "Last Updated" date at the top of this policy and, where feasible and appropriate, by providing a more prominent notice (such as by adding a statement to our app's main screen, sending you an in-app notification, or via email to your registered email address). We encourage you to review this Privacy Policy periodically to stay informed about our collection, use, and sharing of personal information.

Your continued use of the Services after any changes to this Privacy Policy become effective will constitute your acceptance of such changes.

13. CONTACT US

If you have any questions, comments, or concerns about this Privacy Policy or our privacy practices, or if you wish to exercise your data protection rights, please contact us at:

Email: contact@sapio.fun