Politique de Confidentialité

Last updated: 22 may 2025

1. Introduction
2. Information We Collect
3. How We Use Your Information
4. Data Sharing and Disclosure
5. Data Storage and Security
6. Children's Privacy
7. Data Retention
8. International Data Transfers
9. Your Rights
10. GDPR Compliance
11. CCPA/CPRA Compliance
12. Cookies and Tracking
13. Third Parties and Subprocessors
14. Changes to This Policy
15. Contact Us

1. Introduction

Your privacy matters to us. At Zenvy, we are committed to respecting your privacy and complying with all applicable laws and regulations regarding any personal data we may collect from you—through our mobile app, website, and related services.

Personal information refers to data that can be used to identify you as an individual. This includes, but is not limited to, your name, contact details, device information, and usage behavior within our app.

This Privacy Policy does not extend to external sites or services we may link to. We recommend reviewing the privacy policies of any third-party services you interact with through our app.

2. Information We Collect

We collect two main types of data:

2.1 Information You Provide Directly

This includes any personal details you enter during registration, communication with us, or when participating in features like surveys, feedback forms, or rewards.

2.2 Data Collected Automatically

We may gather details such as your device type, IP address, OS, app usage stats, error logs, and general behavioral data when you interact with Zenvy.

2.3 Log and Device Data

Our servers may log data automatically, such as:

• IP address
• Browser or app version
• Pages visited and time spent
• Error events and associated metadata

Device-specific information may include:

• Device type and OS
• App settings
• Usage preferences

2.4 Personal Information

We may request information such as:

• First name
• Email address (with optional anonymized option via Apple sign-in)
• Profile customization (e.g., avatar)

2.5 App Usage and Activity Data

Zenvy may collect:

• Screen time tracking data
• User-defined app block settings or goals
• Quiz responses or earned reward data
• Feedback submitted through the app

3. How We Use Your Information

We use your information to:

• Provide and personalize app features
• Improve functionality and user experience
• Communicate with users for support or updates
• Conduct internal research and app analytics
• Ensure security and prevent misuse
• Send optional newsletters and reward notifications

We do not sell your personal data. We only share information when necessary for the core functioning of our services (e.g., analytics or hosting), always under strict data protection agreements.

4.1 Transparency on Data Sharing

We may share your data with:

• Service providers that help us operate the app (e.g., hosting, analytics, customer support)
• Legal authorities if required by law
• Affiliates and subcontractors under data protection agreements

We ensure that any third parties handling your data are contractually bound to protect it under applicable data protection standards.

5. Data Storage and Security

5.1 Storage Location

Your data is primarily stored on servers located within the European Union. We apply industry-standard safeguards including:

• Encrypted data transmission (HTTPS)
• Role-based access control
• Regular security audits and updates

5.2 Security Measures

We apply reasonable technical and organizational safeguards to protect your data from unauthorized access or misuse. No method of transmission is 100% secure, so we cannot guarantee absolute security.

While we strive to protect your data, no system is completely immune to risks. We encourage you to use strong passwords and keep your account credentials private.

6. Children's Privacy

Zenvy is designed for family use, including child participation under supervision. We do not knowingly collect identifiable information from children under 13 without parental consent. Parents or guardians control child profile data.

7. Data Retention

We retain personal data only as long as necessary to provide our services. If you delete your account, we will erase or anonymize your data within a reasonable time unless retention is legally required.

8. International Data Transfers

Your data may be processed outside your country of residence. We ensure appropriate safeguards are in place, such as hosting within the EU or applying standard contractual clauses. Zenvy is accessible globally, and data may be transferred to countries with differing data protection standards, but always under legally accepted mechanisms.

9. Your Rights

Depending on your location (e.g., EU, UK, California), you may have rights to:

• Access or update your data
• Request deletion
• Restrict or object to processing
• Withdraw consent
• Receive a copy of your data in portable format
• File a complaint with a supervisory authority

To exercise these rights, contact us at privacy@zenvy.io.

If you reside in the EU or EEA:

• We act as Data Controller when processing your personal information.
• Our legal basis for processing includes consent, contract fulfillment, legitimate interests, or compliance with legal obligations.
• You may withdraw consent at any time. This does not affect prior lawful processing.
• You may request restriction, objection, deletion, or portability as per Articles 12–23 GDPR.
• Transfers outside the EEA are protected using SCCs or other approved safeguards.

11. CCPA/CPRA Compliance

If you reside in California, you have the right to:

• Know what personal data we collect and how we use it
• Request access to your data
• Request deletion of your data
• Opt-out of data sharing or selling (we do not sell personal data)
• Receive equal service regardless of exercising your privacy rights

To exercise these rights, email us at privacy@zenvy.io with "California Privacy Request" in the subject line.

We honor Do Not Track (DNT) signals where legally required. We do not offer CCPA-permitted financial incentives.

12. Cookies and Tracking Technologies

Zenvy uses limited cookies or similar technologies for session management, preference storage, and analytics. You can control cookies through your browser settings.

13. Third Parties and Subprocessors

We work with trusted third parties (subprocessors) to deliver key functionality:

• Hosting: Digital Ocean (EU servers)
• Analytics: Amplitude
• Error tracking: Bugsnag
• Customer support: Crisp
• Email services: SendGrid

All subprocessors operate under strict contractual terms to protect your data.

14. Changes to This Policy

We may update this Privacy Policy to reflect legal, technical, or operational changes. Significant updates will be communicated through the app or via email.

Continued use of our services after changes implies acceptance. If required, we will seek your explicit consent for major updates.

15. Contact Us

For questions, concerns, or privacy-related requests, contact us at:

Email: privacy@zenvy.io

Zenvy is a product of BrightLab B.V., based in the Netherlands.

This international privacy policy is designed to meet the requirements of major jurisdictions including the EU, UK, US (California), and other applicable data protection laws worldwide.

Table of Contents