Privacy Policy

1. Introduction

Welcome to the Privacy Policy for Thrive, created by Zavana.co ("we," "our," or "us"). At Zavana.co, we are dedicated to safeguarding your privacy and ensuring the protection of your personal information. This Privacy Policy is intended to clarify how we collect, use, disclose, and secure your data when you use our Thrive app.

Please take a moment to carefully read through this Privacy Policy to gain an understanding of how we handle your data. By using the Thrive app, you signify your agreement to the practices outlined in this policy.

If you have any questions, concerns, or requests related to your privacy or this Privacy Policy, please don't hesitate to reach out to us using the contact information provided in the "Contact Information" section of this document.

2. Information We Collect

We collect various types of information to provide you with a personalized and enriching experience. The data we collect includes:

a. Personal Information:

When you use the Thrive app, we may collect personal information such as your name, email address, and age. This information is only provided by you voluntarily and it helps us improve the content provided to you by the app.

b. User-Generated Content:

We collect content that you generate or share within the app, such as text, images, and feedback. This content is used to enhance your user experience and provide relevant features.

c. Device Information:

We automatically gather information about the device you use to access the Thrive app. This includes device type, operating system, and unique device identifiers. This data helps us optimize the app's performance on various devices.

Our collection of this information is primarily aimed at improving the functionality and user experience of the Thrive app. We are committed to safeguarding your data and using it responsibly, as outlined in this Privacy Policy.

3. How We Use Your Information

We use the information we collect to provide you with a better, more personalized experience. Here's how we utilize your data:

a. Personalization:

We use your personal information to tailor your experience within the Thrive app. This includes customizing content recommendations, user interfaces, and features to suit your preferences.

b. Communication:

We may use your email address to send you important updates, notifications, and announcements related to the Thrive app. You can opt-out of these communications as outlined in the "Your Choices and Rights" section of this Privacy Policy.

c. User-Generated Content:

Content you generate or share within the app may be used to improve app functionality, display content to other users as intended, and gather feedback to enhance our services.

d. Analytics and Insights:

We analyze user data, including device information and app usage patterns, to gain insights into app performance and user preferences. This information is used to make data-driven improvements to the Thrive app.

e. Legal Compliance:

In some cases, we may need to use your information to comply with legal obligations or respond to legal requests, such as in the case of a legal dispute or government inquiry.

f. Security and Protection:

Your data is essential for the security of the Thrive app and the prevention of fraudulent or unauthorized activities.

Rest assured that we handle your data with care and only use it for the purposes outlined in this Privacy Policy. We do not sell or share your personal information with third parties for their marketing purposes.

4. Data Sharing and Disclosure

We take your privacy seriously. We are committed to safeguarding your data and only share it under specific circumstances:

a. Third-Party Service Providers:

We may engage third-party service providers to assist with various aspects of our operations, such as hosting, analytics, advertising, and customer support. These service providers may have access to your data only as necessary to perform their functions and are bound by confidentiality agreements. In some cases, this may include sharing for cross-context behavioral advertising, as defined under the California Consumer Privacy Act (CCPA).

b. Legal Requirements and Compliance:

We may share your data if required by law, legal process, or government authorities. This includes responding to court orders, subpoenas, or other legal requests.

c. Business Transfers:

In the event of a merger, acquisition, or sale of all or part of our company or assets, your data may be transferred to the acquiring entity. We will notify you of any such transfer and any changes to data handling practices.

d. User-Generated Content:

Content you generate or share within the app may be visible to other users in accordance with app features and settings. Please consider your privacy preferences when sharing content.

We do not sell or rent your personal information to third parties for their marketing purposes. Our data sharing practices are designed to meet our operational needs and legal obligations while ensuring the security and integrity of your data.

e. Your Right to Know

If you are a resident of California, you have the right to know about the personal data we collect, use, and share. This includes:

• The categories of personal information we collect.
• The purposes for which your data is collected.
• Whether your personal information has been shared with third parties, and if so, the categories of those third parties and the purposes for sharing, including for cross-context behavioral advertising.

f. Opt-Out Rights (Applicable for U.S. Users)

We do not engage in targeted advertising, the sale of personal data, or profiling that results in legal or similarly significant effects on users. However, we respect your rights under various data protection laws, including the Virginia Consumer Data Protection Act (VCDPA), and provide the following information about your opt-out rights:

• Targeted Advertising: As of now, we do not use your personal data for targeted advertising. Should this practice change in the future, we will provide you with the option to opt out.
• Sale of Personal Data: We do not sell your personal information. If we ever decide to engage in the sale of data, you will have the right to opt out, and we will provide a clear mechanism to do so.
• Profiling: We do not use your data for profiling that leads to decisions with legal or similarly significant consequences. Should this change, we will provide you with an opt-out option. You can exercise your rights by contacting us at info@zavana.co or through the app’s support chat found in the app settings, where applicable.

g. Data Retention

We retain personal data for as long as necessary to provide the services within the app or as otherwise required for legal, regulatory, or compliance purposes. Specifically:

• Functional Data: Personal data that is necessary for the app to function (such as account information, preferences, and user-generated content) is retained for as long as you maintain an active account or continue using the app. If you deactivate or delete your account, we will delete or anonymize your personal data within a reasonable timeframe, unless otherwise required by law.
• Other Personal Information: Personal information that is not required for the continued operation of the app is retained only as long as necessary to fulfill the purposes outlined in this policy or as required by applicable law. After that period, it will either be securely deleted or anonymized so that it can no longer be linked back to you.
• Legal Obligations: In some cases, we may need to retain your personal data for a longer period to comply with legal obligations, resolve disputes, or enforce our agreements.

If you would like more information about specific data retention periods or request deletion of your data, please contact us at info@zavana.co.

5. Your Choices and Rights

We respect your privacy and provide you with choices and rights concerning your data:

a. Access and Correction of Personal Information:

You have the right to access and correct inaccuracies in your personal information stored in the Thrive app. You can do this by accessing your account settings or by contacting our support team.

b. Data Deletion:

You can request the deletion of your account and associated data by contacting us through the methods outlined in the "Contact Information" section. Please note that some data may be retained as required by law or for legitimate business purposes. In addition it is possible to delete your personal data through your profile settings in the Thrive App.

c. Data Portability:

You have the right to request a copy of your data in a structured, commonly used, and machine-readable format, subject to legal and technical limitations.

d. Opt-Out Options:

You can opt out of receiving certain communications from us, such as promotional emails. Instructions for opting out are provided within the communication itself or in your account settings.

e. Revoking Consent:

If you have previously given your consent for specific data processing activities, you can revoke that consent at any time. Revoking consent will not affect the lawfulness of processing based on consent before its withdrawal.

Please be aware that exercising your rights may affect your ability to use certain features or services within the Thrive app. We will respond to your requests promptly and in accordance with applicable data protection laws.

6. Cookies and Tracking Technologies

We use user preference storage (or cookies) and tracking technologies to enhance your experience and collect data about your interactions with the app. Here's how we use these technologies:

a. Types of Technologies:

Preference Storage consists of small text files that are placed on your device collect important information that determines how the app is personalized on your device for longer-term functionality, such as remembering your preferences.

b. How We Use Preference Storage:

We use Preference Storage to keep track of your interaction with notifications to make sure the data presented to you in the app is the best reflection of your preferences.

7. Third-Party Links and Content

Thrive may include links to third-party websites or content. These links are provided for your convenience and may lead to websites or services that are not operated or controlled by us. Please be aware of the following:

a. Third-Party Websites or Services:

Clicking on third-party links within the Thrive app may direct you to websites or services that have their own privacy policies. We encourage you to review the privacy policies of these third-party sites or services, as we do not have control over their practices.

b. Third-Party Integrations:

The Thrive app may integrate with third-party services, such as social media platforms or payment processors, to enhance your experience. Your interactions with these integrated services are governed by their respective privacy policies.

c. User-Generated Content:

User-generated content within the Thrive app, including comments and contributions from other users, may contain links to third-party websites or services. Exercise caution and review the privacy policies of any linked sites.

Thrive strives to provide a safe and enriching experience, but we cannot be responsible for the privacy practices or content of third-party websites or services. Your interactions with such sites or services are at your own risk, and any data you provide to them is subject to their respective privacy policies.

8. Data Security

We take data security seriously and implement measures to protect your information:

a. Measures to Protect Your Data:

We employ industry-standard security practices and technologies to safeguard your data from unauthorized access, disclosure, alteration, and destruction. These measures include encryption, access controls, and regular security assessments.

b. Data Breach Notification:

In the unlikely event of a data breach that compromises your personal information, we will promptly notify you as required by applicable data protection laws.

While we take all reasonable steps to secure your data, it's important to keep in mind that no method of data transmission or storage can be guaranteed as 100% secure. Therefore, we encourage you to take appropriate precautions to protect your personal information, such as using strong, unique passwords and keeping your login credentials confidential.

9. Children's Privacy

Thrive is intended for use by individuals who are at least 8 years old (or the minimum age applicable in your jurisdiction) or older. We are committed to protecting the privacy of children. Here's what you should know:

a. Age Restrictions:

Users of the Thrive app must meet the minimum age requirement specified in our Terms of Service. We do not knowingly collect or maintain personal information from individuals under this minimum age.

b. Parental Consent:

If you believe that we have inadvertently collected personal information from a child without appropriate parental consent, please contact us immediately using the contact information provided in this Privacy Policy. We will take steps to promptly delete such information.

c. Responsible Use:

If you are a parent or guardian and allow your child to use the Thrive app, please supervise their activities and help them understand the importance of responsible and safe online behavior.

We are dedicated to complying with applicable laws and regulations related to children's privacy. If you have any concerns or questions about children's privacy within the Thrive app, please contact us using the provided contact information.

10. Legal Basis for Data Processing

We process your information under various legal grounds as required by applicable data protection laws, including the General Data Protection Regulation (GDPR). These legal bases include:

a. Contractual Necessity:

We process your data to administer our contractual relationship with you. This includes setting up your requested services, handling payments, managing renewals, and facilitating related processes.

b. Legitimate Interests:

It is in our legitimate interest to run a successful and efficient business, providing you with high-quality services and valuable content. We ensure that our legitimate interests are balanced with your data privacy rights.

c. Legal Obligations:

We may process your data to fulfill legal obligations imposed upon us, such as collecting specific information required by law.

d. Consent:

In some cases, we rely on your explicit consent to process your data for specific purposes. When you provide consent, you have the right to withdraw it at any time. These legal bases allow us to collect and process your data in compliance with applicable laws and regulations while ensuring transparency and fairness in our data processing practices.

11. International Data Transfers

Thrive may involve the transfer of your personal information to countries outside of your own, including countries with data protection laws that may differ from those in your jurisdiction. Here's what you should be aware of:

a. Data Transfers Outside Your Country:

Your use of the Thrive app may result in the transfer of your personal information to servers or third-party service providers located in other countries. We take steps to ensure that your data is treated securely and in accordance with this Privacy Policy, regardless of where it is processed.

b. Data Protection Standards:

We only transfer your personal information to countries that offer an adequate level of data protection or to third parties who have demonstrated compliance with robust data protection standards.

c. Consent and Agreement:

By using the Thrive app and agreeing to this Privacy Policy, you consent to the transfer of your data as described herein. We will not transfer your personal information to third parties for purposes inconsistent with those outlined in this Privacy Policy.

d. Privacy Shield Framework (if applicable):

In cases involving data transfers to the United States, we may rely on the EU-U.S. Privacy Shield Framework as a lawful mechanism for data transfer, where applicable.

We are committed to ensuring that your personal information is treated securely and in accordance with applicable data protection laws, regardless of where it is processed or transferred.

12. Changes to the Privacy Policy

We may update and revise this Privacy Policy from time to time to reflect changes in our practices and legal requirements. Here's what you should know:

a. Notification of Changes:

When we make significant changes to this Privacy Policy, we will revise the "Effective Date" at the beginning of the document to indicate the date of the most recent update. We will also make reasonable efforts to notify you of such changes through the app or via email.

b. Reviewing Changes:

We encourage you to review the updated Privacy Policy carefully to understand how any changes affect your use of the Thrive app. Your continued use of the app following the posting of updated terms constitutes your acceptance of those changes.

c. Opt-Out Option:

If you do not agree with the updated Privacy Policy, you have the option to discontinue your use of the Thrive app.

d. Retroactive Changes:

Changes to this Privacy Policy are prospective and do not alter the handling of your personal information prior to the effective date of the changes.

e. Consistency with Terms of Service:

In the event of any inconsistencies between this Privacy Policy and the Terms of Service, the terms of the Privacy Policy shall prevail.

f. Contact for Questions:

If you have any questions or concerns regarding changes to this Privacy Policy, please contact us using the contact information provided in this document.

We are committed to keeping you informed about any updates to this Privacy Policy to ensure transparency and clarity regarding your data privacy within the Thrive app.

13. Contact Information

If you have any questions, concerns, or requests related to your privacy or this Privacy Policy, please do not hesitate to contact us. You can reach out to Zavana.co, the company behind the Thrive app, using the following contact information:

Mailing Address: Zavana.co Wilhelminastraat 58 Meppel, 7941HW Netherlands

Email: support@zavana.co

We value your privacy and take your inquiries seriously. Our team is available to address any privacy-related questions or concerns you may have.

14. Governing Law and Jurisdiction

This Privacy Policy and your use of the Thrive app shall be governed by and construed in accordance with the laws of the Netherlands, without regard to its conflict of law principles.

a. Applicable Laws:

The interpretation, validity, and enforcement of this Privacy Policy, as well as any disputes arising from or related to it, shall be subject to the laws of the Netherlands.

b. Dispute Resolution:

Any disputes, claims, or controversies arising out of or in connection with this Privacy Policy, including disputes related to data privacy, shall be subject to the exclusive jurisdiction of the competent courts in the Netherlands.

By using the Thrive app, you agree to submit to the jurisdiction of the Dutch courts and consent to the application of Dutch law to any disputes or claims that may arise in connection with this Privacy Policy.

15. Miscellaneous

a. Entire Agreement:

This Privacy Policy, together with the Terms of Service, constitutes the entire agreement between you and Zavana.co regarding your use of the Thrive app, including all related activities, and supersedes any prior understandings or agreements, whether oral or written.

b. Severability:

If any provision of this Privacy Policy is found to be invalid, illegal, or unenforceable under applicable law, the remaining provisions will continue to be valid and enforceable to the fullest extent permitted by law.

c. Updates to Privacy Policy:

The most current version of this Privacy Policy will always be available within the Thrive app. We encourage you to review it regularly to stay informed about our data practices.

d. Language:

This Privacy Policy may be provided in multiple languages for your convenience. In the event of any inconsistencies between different language versions, the English version shall prevail.

e. Effective Date:

This Privacy Policy is effective as of the effective date stated at the top of this document. Your continued use of the Thrive app following any updates to this Privacy Policy signifies your acceptance of those changes.

16. Conclusion

Thank you for entrusting Zavana.co and using the Thrive app as a part of your personal growth journey. We are dedicated to safeguarding your privacy and providing a secure, enriching environment for your personal development.

By using the Thrive app, you acknowledge and agree to the practices outlined in this Privacy Policy. We respect your privacy choices and are committed to ensuring transparency and compliance with applicable data protection laws.

If you have any questions, concerns, or feedback regarding this Privacy Policy or any privacy-related matters, please do not hesitate to contact us using the information provided in the "Contact Information" section. We value your input and are here to assist you.

Thank you for being a valued member of the Thrive community and for your dedication to personal growth and well-being.