SAYVR Limited Privacy Policy
Effective Date: October 30th 2024
1. Introduction
Sayvr Limited ("we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, and share your information when you use our Sayvr app ("App") available on the App Store/TestFlight. We comply with the United Kingdom General Data Protection Regulations (“GDPR”), California Consumer Privacy Act (“CCPA”), and other relevant privacy laws globally.
2. Information We Collect
We may collect the following personal data of yours pursuant to your use of the App:
Personal Information: When you create an account, we may collect your name, email address, and other contact details.
Usage Data: We collect information about how you use the App, including interactions with features and services.
Device Information/Technical Data: We may collect information about your device, such as IP address, device type, operating system, and unique device identifiers.
Location Data: With your consent, we may collect and process information about your location and time zone setting.
Financial Data: information regarding your bank account and/or payment card details.
Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We may also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.
3. How we collect your personal data
We use different methods to collect data from and about you including through:
Your interactions with us: You may give us your personal data by filling in online forms on our App or website or by corresponding with us by post, phone, email or otherwise.
Automated technologies or interactions. As you interact with our App or website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We may collect this personal data by using server logs and other similar technologies.
4. Legal Basis for Processing
We process your personal data based on one or more of the following legal grounds:
Consent: When you provide your data voluntarily, such as when signing up for an account or opting into certain services.
Legitimate Interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to improve our App, customer support, security measures, prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Contractual Necessity: To fulfil our obligations under any contract with you, such as providing the services you request.
Compliance with Legal Obligations: When we are legally required to process your data for compliance with a legal obligation that we are subject to.
5. Purposes for Which We Use Your Information
To Provide Services: We may use your information (including identity, contact, technical and financial details) to register you as a new customer on the App, operate and improve the App, provide customer support, and process transactions including any membership fees and payments.
To Communicate and manage our relationship with you: We may use your email address to send you updates, dealing with requests or complaints, newsletters, and promotional offers. To send you relevant marketing communications and make personalised suggestions and recommendations to you about goods or services that may be of interest to you based on your Account data.
Analytics: We use aggregated data to analyse user behaviour and improve the App’s performance.
To administer and protect our business and this website: We may use your information (including identity, contact, technical and financial details) for purposes related to troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data, and we may use your technical and personal contact data to improve our App / website, products/services, customer relationships and experiences and to measure the effectiveness of our communications and marketing.
Website Content and Online Advertisements: We may use your information (including identity, contact, technical and financial details) to deliver to you and measure or understand the effectiveness of the advertising we serve to you and/or the effectiveness of the App / Website content.
Compliance and Enforcement: To ensure compliance with our terms, to protect our rights, and to comply with legal requirements.
6. Marketing
Direct marketing: During the registration process on our App or website when your personal data is collected, you will be asked to indicate your preferences for receiving direct marketing communications from us via various means (including, email, sms, telephone or post). We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.
Third-party marketing: We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.
Opting out of marketing: You can ask to stop sending you marketing communications at any time by logging into the App or website and checking or unchecking relevant boxes to adjust your marketing preferences, or by following the opt-out links within any marketing communication sent to you. If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes, for example relating to order confirmations, updates to our terms of use, confirming that your contact and account details are correct.
7. Sharing Your Information
We do not sell your personal information to third parties. We may share your data:
With Service Providers: We may share your information with third-party service providers to help us operate the App.
With Legal Authorities: We may disclose your information if required by law or to protect our rights.
In Business Transfers: In the event of a merger, sale, or other business transfer, your information may be transferred as part of that transaction.
8. International Data Transfers
Your information may be transferred to and processed in countries outside the European Economic Area (EEA). We ensure that appropriate safeguards are in place to protect your data in such transfers, in line with GDPR requirements. For transfers to the United States and other non-EEA countries, we use Standard Contractual Clauses and other legally authorised mechanisms to protect your data.
9. Data Security
We implement appropriate technical and organisational security measures to protect your information from being accidentally lost, used or accessed in an unauthorised way, altered or unduly disclosed, including encryption and secure servers. However, no method of transmission over the internet is 100% secure.
In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
10. Data Retention
We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. After that period, your data will be securely deleted or anonymized. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances you can ask us to delete your data: see paragraph 11 below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
11. Your Rights Under GDPR and CCPA
Access: Request access to your personal data (commonly known as a "subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Rectification: Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Erasure: Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Restriction of Processing: You can request to restrict the processing of your data.
Data Portability: You have the right to receive your data in a structured, commonly used, and machine-readable format.
Objection: Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
Withdrawal of Consent: Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
consent at any time.Transfers: Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Right to Know (CCPA): California residents have the right to know what personal
information is collected, used, shared, or sold, and to whom.Right to Opt-Out (CCPA): California residents have the right to opt-out of the sale of
their personal information.Right to Non-Discrimination (CCPA): We will not discriminate against you for
exercising any of your privacy rights under CCPA.
To exercise any of these rights, please contact us at sam@sayvr.ai.
If you wish to exercise any of the rights set out above, please contact us (see contact details in paragraph 14.
No fee usually required: You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you: We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond: We try to respond to all legitimate requests within a reasonable period of time, typically one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Complaints: You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
12. Children's Privacy (COPPA Compliance)
The App is not intended for users under the age of 13. We do not knowingly collect personal information from children under 13. If we become aware that we have inadvertently collected such information, we will take steps to delete it as soon as possible.
13. Changes to This Policy
We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy in the App and updating the effective date.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.
14. Contact Us
If you have any questions about this Privacy Policy, please contact us at sam@sayvr.ai.
15. Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.