This Privacy & Cookies Policy explains how IAORANA LTD ("Soa," "we," "our," or "us") collects, uses, and protects your personal data when you use our mobile application ("App") and website ("Site"). It also describes how we use cookies and similar technologies.

1. Who We Are

• Company Name: IAORANA LTD
  
  
• Legal Form: Private Company Limited by Shares, Registration no. HE 474716
  
  
• Address: 2 Kimonos Street, Limassol 3095, Cyprus
  
  
• Email: support@joinsoa.app
  
  

We are the data controller responsible for your personal data under applicable data protection laws, including the EU General Data Protection Regulation (GDPR).

2. Data We Collect

• Account Data: Name, email address, login credentials, language preferences.
  
  
• Subscription Data: Payment details (via Stripe or app stores), billing history, subscription status.
  
  
• Usage Data: App interactions, session history, progress tracking, reflection responses, preferred voices and sounds.
  
  
• Well-being Data (Sensitive Data): Emotional states, mood tracking, responses during onboarding and protocols.
  
  
• Device Data: Device type, operating system, app version, IP address, browser type.
  
  
• Cookies & Tracking Data: For analytics, personalization, and marketing (see Section 7 below).
  
  

3. How We Use Your Data

We use your personal data to:

• Provide and improve our services (personalized programs, notifications, user support).
  
  
• Process payments, manage subscriptions, and provide invoices.
  
  
• Customize your experience using AI-driven onboarding and recommendations.
  
  
• Communicate important updates, offers, and service-related information.
  
  
• Ensure compliance with legal obligations and enforce our Terms.
  
  

4. Legal Basis for Processing (GDPR)

We process your personal data based on:

• Contract: To provide the services you subscribe to.
  
  
• Consent: For processing sensitive well-being data, cookies, and marketing communications.
  
  
• Legitimate Interest: To improve and secure our services.
  
  
• Legal Obligation: To comply with tax, accounting, and regulatory requirements.
  
  

5. Data Sharing

We may share your personal data with:

• Service Providers: Hosting (Webflow, AWS), CMS, Firebase (notifications), Stripe (payments), AI/voice providers (OpenAI, ElevenLabs).
  
  
• Analytics & Marketing Tools: For performance measurement and personalization.
  
  
• Legal Authorities: When required by law or to protect our rights.
  
  

We do not sell your personal data.

6. International Data Transfers

Your data may be transferred to service providers outside the EU/EEA (e.g., US). We ensure such transfers are safeguarded by Standard Contractual Clauses (SCCs) or equivalent legal mechanisms.

7. Cookies & Tracking

7.1 What Are Cookies?

Cookies are small text files placed on your device when you visit a website. They help us recognize your device, remember preferences, and improve browsing.

7.2 Types of Cookies We Use

• Essential Cookies: Required for the operation of the Site/App (authentication, security, language settings).
  
  
• Performance & Analytics Cookies: Collect information on usage (e.g., Google Analytics, Amplitude).
  
  
• Functional Cookies: Remember preferences (sessions, language).
  
  
• Marketing Cookies: Track activity to deliver relevant advertising and measure effectiveness.
  
  

7.3 Third-Party Cookies

Trusted third parties may place cookies, including:

• Analytics providers (Google Analytics, Amplitude)
  
  
• Payment providers (Stripe, App Stores)
  
  
• Hosting and service providers (Webflow, AWS, Firebase)
  
  

7.4 How We Use Cookies

We use cookies to:

• Ensure the Site/App functions properly.
  
  
• Improve performance and user experience.
  
  
• Personalize content and recommendations.
  
  
• Deliver relevant advertising (where applicable).
  
  

7.5 Your Choices

• Consent Banner: On first visit, you can accept or reject non-essential cookies.
  
  
• Browser Settings: You can block or delete cookies. Some features may not work without cookies.
  
  
• Opt-Out Links: You may opt out of certain analytics or advertising cookies via third-party tools (e.g., Google opt-out add-ons).
  
  

7.6 Data Retention

• Session cookies: Deleted when you close your browser.
  
  
• Persistent cookies: Remain until expiry or manual deletion.
  
  

8. Data Retention

We keep personal data only as long as necessary for the purposes outlined here, to comply with legal obligations, resolve disputes, and enforce agreements.

9. Your Rights

Under GDPR and other laws, you have the right to:

• Access, correct, or delete your personal data.
  
  
• Withdraw consent at any time.
  
  
• Request restriction or objection to processing.
  
  
• Request data portability.
  
  
• File a complaint with your local Data Protection Authority.
  
  

To exercise your rights, contact us at support@joinsoa.app.

10. Security

We use technical and organizational measures (encryption, access control, secure hosting) to protect personal data against unauthorized access, alteration, disclosure, or destruction.

11. Children’s Privacy

Soa is intended for users aged 18 and above. We do not knowingly collect data from children. If you believe we collected such data, please contact us.

12. Changes to This Policy

We may update this Policy from time to time. Significant changes will be notified via the App, Site, or email.

13. Contact Us

IAORANA LTD
2 Kimonos Street, Limassol 3095, Cyprus
Email: support@joinsoa.app

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