PRIVACY POLICY

Golonger is a mobile app for guided pelvic floor exercises, designed to improve pelvic floor strength and flexibility for sexual health and wellness (the “App”). This Privacy Policy explains what personal data we collect, why we process it, and the rights you have over it.

We act as the controller of your personal data and process it in accordance with applicable data protection legislation (GDPR, UK GDPR, CCPA, and other applicable laws). We are committed to transparency and accountability in our data practices.

If you do not accept the terms of this Privacy Policy, please do not use the App. If you have any questions or concerns, contact us at hello@golonger.app.

As you engage with the App, we gather personal data through the following means:

• Data you provide directly: any information you input while using the App - such as your name, email address, and details you share with our support team.
• Data collected automatically: when you use the App, we collect details about your device (model, operating system, unique identifiers, IP address) and your activity within the App.
• Health-related data: your exercise history and session data. This is sensitive personal data, processed only with your explicit consent and only to provide the App’s core functionality.

We also use cookies and similar technologies to retain details about your preferences and previous interactions, enhancing your experience in the App.

Data processing is essential to enable your usage of the App. Below are the purposes for which we process your data:

• Providing the App and customer support: we may communicate with you if you have contacted our support team with any questions relating to the App.
• Improving the experience: we analyze how you interact with the App to tailor it to your needs and refine our training plans.
• Technical performance: we continuously work to improve stability and streamline features for your benefit.
• Optimizing our campaigns: we analyze the performance of our advertising campaigns to gauge interaction and reach.
• Legal obligations: we comply with pertinent laws and regulations.

Depending on which features of the App you use, we process your personal data based on one or more of the following legal bases:

• Legitimate interest: we process usage data to technically improve the App and deliver an improved service to you.
• Contract: we process usage data to fulfill our contractual duty of granting you access to the App.
• Legal obligation: we may handle personal data as mandated by law.
• Consent: we process sensitive personal data, including health data, based on your explicit consent - this consent is essential for enabling you to use the App.

The App offers in-app purchases, including subscriptions, which are processed by Apple App Store and Google Play. We do not collect or process any information related to your payment instruments, such as your bank card number or its validity term, under any circumstances. We recommend reviewing the privacy policies of the payment providers you use.

We retain your personal data for as long as your account is active or for as long as it is necessary for the purposes of its collection and processing (for example, resolving disputes, safety and security reasons, or complying with our legal obligations). After account deletion, retained data is erased within a limited period, as required by applicable law.

We may need to share your personal data with certain third parties as follows:

• Service providers: providers of systems and services we use to host, administer, and maintain the App - including hosting servers, email services, analytics, crash reporting, and customer service tools.
• Marketing partners: if you consent to marketing, certain data may be shared with providers we use to carry out marketing.
• Compliance with laws: we may disclose personal data to comply with any applicable law, regulation, or legal process, or to protect our users and the public from harm.
• Aggregated or anonymized data: we may share aggregated or anonymized information that does not directly identify you.

Among the essential processors we trust are:

• Amplitude - analytics of user behavior and app usage.
• AppsFlyer - mobile attribution and marketing analytics.
• Firebase Analytics - user interaction and performance analytics.
• Firebase Crashlytics - crash reporting and stability monitoring.
• Apple Inc. - cloud storage and app services for iOS devices.

The personal data we maintain is primarily stored and processed within the EU, on secure servers. Where we collaborate with trusted third parties located outside the EU, we have entered into Standard Contractual Clauses with non-EEA processors if there is no adequacy decision by the EU Commission for their country. We adhere to the principles of minimization and anonymization where feasible.

Ensuring the security of your data is a top priority. We employ robust technical and organizational measures, including SSL encryption (HTTPS) for all interactions involving personal data, encrypted databases, and physically secure servers protected by firewalls.

In the event of a personal data breach, we will promptly notify you with relevant details, measures taken, and an assessment of associated risks, as required by applicable law. To report a breach or seek assistance, contact us at hello@golonger.app.

We aim to ensure that you are fully informed about your data protection rights. These rights may vary depending on your location:

• Access: you can request a copy of the personal data we hold about you.
• Rectification: you can request that we correct or supplement incorrect or incomplete data.
• Objection: you can object to the collection or use of your personal data for certain purposes.
• Erasure: you can request that we erase some or all of your personal data from our systems.
• Restriction of processing: you can ask us to restrict or limit further processing.
• Portability: you can request a copy of your personal data in a machine-readable format.
• Withdrawal of consent: if we process your data based on your consent, you can withdraw it at any time.
• Right to file a complaint: you can lodge a complaint with the supervisory authority of your country.

To exercise your rights, contact us at hello@golonger.app. We typically fulfill requests within one month and may ask you to confirm your identity during the process.

If you are in the EU, you must meet the age of consent specified by the laws of your country to use the App, or use it with the consent of your parent or legal guardian. If we learn that we have inadvertently gathered personal data from a child, we will take reasonable measures to promptly erase it.

If you are in the United States, you must be at least 13 years old to use the App. If we become aware of data collected from children under 13 in violation of the Children’s Online Privacy Protection Act, we will delete the account and erase all associated information.

To delete your account, open the App and navigate to Profile → Delete account. After deletion, you will no longer have access to your account or associated subscriptions, and your progress and data cannot be restored.

We reserve the right to amend this Privacy Policy from time to time to reflect changes in the law, our data practices, the features of the App, or advances in technology. Please check this page periodically and refer to the “last updated” date at the top of the page. If we make changes that we consider material to your consent, we will notify you.

We do not sell your personal information for money, and we are not in the business of trading data. Like many companies, we work with partners to handle advertising; we may share some basic personal information with them for targeted ads, which may be considered “sharing” under the CCPA. You have the right to opt out by adjusting your privacy settings in the App.

We only process sensitive personal information when absolutely necessary to provide you with the App. You have the right to request access to the personal information we hold about you and how we use it, twice a year at no cost.

Residents of these states may have additional privacy rights. We do not sell your personal information for payment, and we do not use profiling in decisions that produce legal or similarly significant effects. The rights described above are available to you regardless of your location, and we will respond to your verifiable request within the time limit afforded under applicable law.