Privacy Policy

Wellva is built with privacy as a core principle.

1. Your data exists to serve you.
2. We do not sell your personal data.
3. We do not sell or share your personal data as defined under applicable U.S. privacy laws.
4. We do not use your health data for advertising, profiling, or ad targeting.
5. We do not share health data with advertising platforms, data brokers, or ad networks.
6. We collect only the minimum personal data necessary to provide the functionality you choose to use.
7. We design our systems to keep as much data as possible under your control.
8. We apply privacy-by-design and data minimization principles in building Wellva.
9. You remain in control of your data and may request access, correction, or deletion as described below.

This Privacy Policy applies to personal data processed in connection with:

1. The Wellva mobile application.
2. Related backend, authentication, synchronization, and content-delivery services.
3. Customer support and operational communications.
4. Account-based features, including login and multi-device sync, where those features are available.

This Privacy Policy does not apply to third-party services, websites, or apps that may be linked from Wellva or used as sign-in providers, such as Apple or Google. Those third parties operate under their own privacy policies and terms.

Wellva is a health and wellness app. Depending on how you use it, we may process personal data relating to reproductive health, menstrual health, fertility, pregnancy, symptoms, and related wellness information.

This may include:

1. Period and cycle history.
2. Fertility-related information.
3. Ovulation-related information.
4. Pregnancy-related information.
5. Symptoms, mood, and wellness entries.
6. Sexual activity or intimacy-related tags, if you choose to log them.
7. Weight and temperature entries.
8. Medication reminders and intake information.
9. Personal notes you choose to enter.

Under some laws, this information may be treated as health data, sensitive personal data, special category data, or consumer health data.

Where required by law, we process this type of data based on your explicit consent, such as when you confirm consent in the App and choose to enter or store such information. You may withdraw your consent at any time by deleting the relevant data, deleting your account, or contacting us, subject to legal and technical limitations.

If you are a U.S. resident, including a resident of Washington State, certain health-related information may also be treated as consumer health data under applicable law. We process such data only as permitted by law, including on the basis of your consent where required, and we do not sell it or share it for advertising purposes.

For more information, see our Consumer Health Data Privacy Notice.

You are not required to provide personal data, but certain features of the App may not function properly without it.

Wellva is not a medical provider, and the App is not a substitute for medical advice, diagnosis, or treatment.

We do not require you to provide information beyond what is necessary for the features you choose to use. We collect personal data directly from you, automatically from your use of the App, from your device, and in some cases from sign-in providers.

4.1 Information you provide directly

You may provide the following categories of personal data when using Wellva:

1. Account information, such as your email address where needed for sign-in, support, or account features.
2. Sign-in information from Apple or Google if you choose those login methods.
3. Profile and preference information, such as year of birth, language, units, theme, and display settings.
4. Cycle, fertility, pregnancy, perimenopause, and reproductive health information that you choose to enter into the App.
5. Symptom, mood, body, medication, and wellness information that you choose to track.
6. Notes, logs, and other entries you make in the App.
7. Information you provide when contacting support.

4.2 Information collected automatically

When you use Wellva, we may collect or generate technical and usage information such as:

1. An app-generated installation or client identifier.
2. Device name and platform information.
3. App session and sync metadata.
4. Device activity timestamps used for account security and device management.
5. Notification permission status.
6. Cache and update state for downloaded content.
7. Technical information needed to operate, secure, and troubleshoot the App and related services.

4.3 Information from sign-in providers

If you use Apple Sign-In or Google Sign-In, we may receive information from those providers, such as:

1. A provider-specific user identifier.
2. Your email address, if provided by the sign-in provider.
3. Authentication or verification tokens needed to sign you in securely.

4.4 Information we derive or infer

We may create derived or inferred app outputs from the information you provide in order to operate the App and deliver the features you choose to use. This may include cycle predictions, fertile window estimates, ovulation estimates, pregnancy progress information, cycle trends, and similar wellness information.

We use personal data to provide, operate, maintain, secure, and improve Wellva.

We may use your personal data to:

1. Store your settings, entries, logs, and preferences.
2. Provide cycle, fertility, pregnancy, symptom, medication, and wellness tracking features.
3. Generate predictions, estimates, trends, and wellness app features.
4. Deliver educational, chat, self-care, translation, and pregnancy-related content.
5. Authenticate your account and keep you signed in.
6. Register and manage devices associated with your account.
7. Support login using available sign-in providers, such as Apple or Google.
8. Synchronize your data across devices where sync features are available.
9. Detect and manage sync conflicts.
10. Schedule and manage local reminders and notifications on your device.
11. Provide customer support.
12. Maintain service integrity, security, and reliability.
13. Detect, prevent, and investigate misuse, fraud, unauthorized access, and security incidents.
14. Comply with legal obligations and protect our legal rights.

We process personal data only to the extent necessary for the features and services you choose to use.

Wellva uses both local device storage and backend services.

Some app data is stored locally on your device so the App can work offline, remember your preferences, preserve your entries, and provide core features. Sensitive health-related records stored on your device are protected using device-based security where available. Some temporary or derived app data may also be stored locally to improve performance and app functionality.

Some information may be sent to our servers to provide important app functions. Depending on the features you use, this may include:

1. Requests for predictions, trends, and related app outputs.
2. Cycle settings, logs, and other input data needed to provide those services.
3. Requests for translations, educational content, self-care content, pregnancy tips, chat content, and similar in-app content.
4. Account authentication data, where login is available.
5. Synchronization data, where sync is available.

If you use the App without signing in, some server requests may still be associated with a pseudonymous app-generated identifier. This identifier is not directly linked to your real-world identity unless you later sign in or otherwise connect your app data to an account.

Where account features are available, Wellva may allow you to sign in using supported sign-in providers, such as:

1. Apple Sign-In.
2. Google Sign-In.

When you sign in, we may:

1. Create or link your user account.
2. Register the device you are using.
3. Issue and manage authentication tokens.
4. Maintain device records associated with your account for security and device management.
5. Use security controls to help keep account access secure.

Where account sync is available, Wellva may synchronize your app data across devices associated with your account.

Depending on the features you use, synchronized data may include cycle settings, logs, notes, ovulation test entries, medication reminders and intake records, chat state, app preferences, language, theme, onboarding status, legal consent state, and related app state needed to restore and maintain your experience across devices.

We use synchronization to:

1. Restore your data on additional devices.
2. Keep your data consistent across devices.
3. Reduce the risk of accidental data loss.
4. Detect meaningful conflicts between device data and server data.
5. Allow conflict resolution where necessary.

Wellva may request permission to send notifications.

Where available, notification features may be used for reminders you configure in the App, such as medication reminders, cycle-related reminders, fertility-related reminders, ovulation reminders, and missing-log reminders. You can control notification permissions through your device settings and, where applicable, in-app settings.

If you purchase a Wellva Premium subscription, the transaction is processed by Apple through the App Store or by Google through Google Play, depending on your platform.

The applicable store may provide the App with limited product, purchase, and subscription information needed to display subscription offers, complete or acknowledge a purchase, determine Premium access, and restore an existing subscription. This may include the product or base-plan identifier, localized price information, purchase or transaction identifier, purchase state, and restoration or ownership information.

Wellva does not receive your complete payment-card or bank-account details. Apple and Google process payment and billing information under their respective privacy policies and terms. Subscription management, cancellation, and refund eligibility are governed by the applicable store and applicable law.

We do not use your health data for advertising, ad targeting, or marketing profiling. We do not share health data with advertising platforms, ad networks, or data brokers.

We do not use third-party advertising SDKs in the App to monetize your health data or to build advertising profiles based on your health information.

We may use limited technical logs, crash reports, error logs, or operational analytics strictly for app performance, reliability, security, debugging, abuse prevention, and service improvement. Where we use such information, we do not use your health data for advertising purposes.

If we introduce new tracking, analytics, or advertising technologies that materially change how your personal data is processed, we will update this Privacy Policy and, where required, ask for your consent.

Wellva uses automated processing to generate predictions, estimates, trends, and wellness app features based on the information you choose to provide.

These predictions, estimates, trends, and wellness information are intended to support app functionality and your personal use of the App. They are not medical decisions and do not produce legal or similarly significant effects about you and are not used to make decisions that have legal or similarly significant effects about you in the sense used by applicable privacy laws.

If the GDPR, UK GDPR, or similar laws apply, we rely on one or more of the following legal bases:

1. Consent, where required for health or other sensitive data that you choose to provide.
2. Contract, where processing is necessary to provide the services and features you request.
3. Legitimate interests, where processing is necessary for service operation, security, troubleshooting, improvement, and fraud prevention, provided those interests are not overridden by your rights.
4. Legal obligation, where processing is required by applicable law or legal process.

In particular, we generally rely on explicit consent for health and other sensitive data, contract for the core operation of the App and the features you request, and legitimate interests for security, fraud prevention, service reliability, and troubleshooting.

We do not sell or share your personal data as defined under applicable U.S. privacy laws.

We may share personal data only in the following circumstances:

1. With service providers and processors acting on our behalf, such as cloud hosting providers, authentication providers, storage providers, infrastructure providers, security services, and customer support tools.
2. With sign-in providers such as Apple or Google when you choose those login methods.
3. Where required to comply with law, legal process, or enforceable government requests.
4. Where reasonably necessary to protect the rights, safety, security, or integrity of Wellva, our users, or others.
5. In connection with a merger, acquisition, restructuring, sale of assets, financing, or similar corporate transaction, subject to appropriate safeguards where required.

All processors acting on our behalf are required to process personal data under appropriate contractual protections and data protection obligations. We enter into data processing agreements with our service providers as required by applicable law.

We retain personal data for as long as reasonably necessary to provide Wellva, maintain account and sync functionality, comply with legal obligations, resolve disputes, enforce our agreements, and protect the security and integrity of our Services.

In general:

1. Data stored locally on your device may remain there until deleted, overwritten, removed when you uninstall the App, or cleared through your device or app settings where available. Some local derived caches are size-limited, such as prediction cache entries and recent chat history, and may be overwritten as the App continues to run.
2. Account and synchronization data may be retained while your account is active and for a limited period afterward, unless longer retention is required by law, security needs, fraud prevention, dispute resolution, backup management, or technical recovery processes.
3. Device and authentication records may be retained for as long as reasonably necessary for security and account management.
4. Some data may remain in backups or disaster recovery systems for a limited additional period.
5. If you request deletion or delete your account, we will delete or de-identify account-related server-side personal data as required by applicable law, subject to lawful exceptions. Some information may remain locally on your device until you log out, reset app data, clear app data where available, or uninstall the App.

Deleting your account may result in permanent loss of data that cannot be recovered.

Your personal data may be stored or processed in countries other than the country in which you live.

Where required by law, and especially where personal data is transferred from the EEA, the UK, or similar jurisdictions, we will use appropriate safeguards for international transfers, such as standard contractual clauses or other lawful transfer mechanisms.

We use technical and organizational measures designed to protect your personal data against unauthorized access, loss, misuse, alteration, and disclosure.

These measures may include account authentication controls, token-based session management, sign-in provider security controls, device management controls, restricted access to data, encryption in transit and, where appropriate, at rest, and other security measures appropriate to the nature of the data we process.

No method of transmission or storage is completely secure. You are responsible for protecting your device and sign-in account credentials, including by using a device passcode or biometric protection where available.

Wellva is not intended for children below the minimum age permitted by applicable law.

At a minimum, users must be at least 13 years old to use Wellva, unless a higher age threshold applies in the country where they live. If we learn that we have collected personal data from a child in violation of applicable law, we will take appropriate steps to delete or otherwise handle that data as required.

Depending on where you live, you may have the right to:

1. Access your personal data.
2. Correct inaccurate personal data.
3. Delete your personal data.
4. Restrict or object to certain processing.
5. Withdraw consent where processing is based on consent.
6. Request portability of your personal data.
7. Appeal a privacy-related decision where applicable.
8. Lodge a complaint with a regulator or supervisory authority.

Additional rights may apply depending on your location, including under U.S. state privacy laws and consumer health privacy laws.

To exercise your rights, contact us at contact@wellva.one. We may need to verify your identity before responding.

For instructions on deleting your Wellva account and associated personal data, see Account and Data Deletion.

If you are located in the EEA, you also have the right to lodge a complaint with your local data protection authority.

You can delete your Wellva account and associated server-side data directly in the Wellva App through Settings → Manage Account → Delete account.

If you cannot access the App, you may request deletion by emailing contact@wellva.one with the subject “Wellva account deletion request.” Where possible, contact us using the email address associated with your Wellva account. We may request limited information necessary to verify your identity.

Account deletion removes or de-identifies account-related server-side data, including synchronized health and wellness data, subject to the limited retention described in the Data Retention section and any retention required by law. Data stored locally on your device may remain until you clear the App’s data or uninstall it.

Deleting a Wellva account does not automatically cancel an App Store or Google Play subscription. Subscriptions must be managed through the applicable store:

• Manage Apple subscriptions
• Manage Google Play subscriptions

We may update this Privacy Policy periodically.

If we make material changes, we may notify you through the App, by email, or by other appropriate means, depending on the nature of the change and the legal requirements that apply.

The latest version of this Privacy Policy will always be available through Wellva and any official Wellva website where it is published.

Wellva is the provider of the Wellva App and the controller of your personal data for the purposes described in this Privacy Policy, unless stated otherwise.

If you have questions, concerns, or requests relating to this Privacy Policy or our handling of personal data, please contact us at:

Wellva OÜ
Ahtri tn 12
10151 Tallinn, Estonia

Contact: contact@wellva.one

If you live in a jurisdiction that gives you the right to contact a privacy or data protection regulator, you may also contact that authority directly.