DRAFT — NOT LEGAL ADVICE. This is a starting draft to be reviewed, corrected, and finalized by a licensed attorney before it is published or relied upon. It is not live. Every [bracketed] value needs your real details, and the whole document must be checked against how the apps actually handle data.
Privacy Policy
Effective date: [date] · Last updated: [date]
This Privacy Policy explains how [Legal Entity Name, LLC] ("Happy Computer," "we," "us") collects, uses, and shares information when you use our apps and websites — Sanavva, Tohvva, Viavva, Mesavva, and Operativva (each, a "Service"). Where a practice applies to only one app, we say so.
1. Who we are
[Legal Entity Name], [mailing address]. Questions: [privacy@your-domain].
2. Information we collect
We collect only what a Service needs to work. Depending on the app, that includes:
- Account & contact — name/handle, email, and authentication identifiers.
- Content you create — e.g. Viavva trip ideas, itineraries, journals and uploaded photos; Sanavva care entries, notes and photos; Tohvva workouts; Mesavva meal photos, captions and cook notes.
- Health & fitness data — Sanavva: medications, doses, observations and care summaries you enter, including information about other people in your household. Tohvva: heart rate, HRV, sleep, readiness and activity, including from Apple Health / connected services where you allow it.
- Operational & financial records — Operativva: the projects, expenses, allocations, providers and uploaded receipts you enter to track what your own products cost. This is your business/operational data; it is not payment-card data.
- Purchase data — subscription status (handled by the app stores / [payment processor]; we don't store full card numbers).
- Device & usage — app version, device type, diagnostics/crash data, and usage events. [List analytics tool, if any.]
[Confirm this list exactly matches your data inventory / store privacy labels. If it isn't here, it can't be in the app.]
3. How we use information
- To provide and operate the Service and your account.
- To sync your data across your devices and, where you choose, share it with people you invite (household caregivers, trip members).
- To turn what you capture into a structured record — e.g. Mesavva sends your meal photo and caption to an automated (AI) parser [server-side / third-party AI provider — name it] to fill in fields you can edit or ignore. We do not use your content to train third-party models [confirm with your provider's terms, then keep this line].
- To keep the Service secure, debug problems, and improve it.
- To communicate with you about the Service. [Marketing messages, if any, only with your opt-in — see §7.]
4. When we share information
We share information only as described here:
- People you choose — e.g. caregivers you invite (Sanavva) or trip members and read-only link recipients (Viavva).
- Service providers that run the Service on our behalf, under contract: [hosting/backend — e.g. Supabase], [crash/diagnostics], [payments], [push], and any others in your inventory.
- Connected services you enable — e.g. Apple Health / [Strava] (Tohvva), subject to their own terms.
- Legal & safety — when required by law or to protect rights and safety.
- Business transfers — in a merger or acquisition, subject to this policy.
We do not sell your personal information, and we do not "share" it for cross-context behavioral advertising (as those terms are defined under California and other state laws). [Confirm true, then keep this line.]
Health data — special handling (Sanavva, Tohvva)
We treat health and fitness data as sensitive. We do not use it for advertising or marketing, do not sell it, and do not disclose it to third parties except to provide the Service or with your permission. Data obtained through Apple HealthKit [/ Google Health Connect] is used only to provide health/fitness features, consistent with those platforms' requirements. [Confirm against actual HealthKit usage.]
5. Data retention
We keep information for as long as your account is active or as needed to provide the Service, then delete or de-identify it within [retention period], except where longer retention is required by law. [Describe backups.]
6. Security
We use reasonable technical and organizational measures to protect your information ([encryption in transit / at rest, access controls, etc.]). No system is perfectly secure.
7. Your choices & rights
- Access & deletion — you can access and delete your data, including deleting your account [in-app: Settings → …].
- Permissions — you control device permissions (Health, notifications, photos) in your OS settings.
- Marketing — you can opt out of marketing messages at any time; transactional messages (e.g. a trip invite you send) are not marketing.
- State privacy rights — depending on where you live, you may have rights to access, delete, correct, or limit use of your data. To exercise them, contact [privacy@your-domain]. [Add any state-specific mechanisms your counsel requires.]
8. Children's privacy
Our Services are intended for adults and are not directed to children under 13, and we do not knowingly collect personal information from children under 13. Sanavva is used by adults (parents and caregivers) who may enter care information about family members of any age; we do not ask for a patient's age. In Viavva, an account holder may add other trip participants by name — non-paying participants whose age and relationship we do not ask for or store. If you believe a child under 13 has provided us personal information directly, contact [privacy@your-domain] and we will delete it. [Confirm this framing with counsel — see the legal checklist re: COPPA vs. adult-entered third-party data.]
9. International users
[If you have EU/UK users, GDPR/UK-GDPR terms go here — a separate conversation with counsel.]
10. Changes
We may update this policy; we'll post the new date above and, for material changes, [notify you in-app / by email].
11. Contact
[Legal Entity Name] · [mailing address] · [privacy@your-domain]