This Privacy Notice for Twisted House SRL (doing business as RAUVORA) ('we', 'us', or 'our') describes how and why we might access, collect, store, use, and/or share ('process') your personal information when you use our services ('Services'), including when you:
- Download and use our mobile application (RAUVORA), or any other application of ours that links to this Privacy Notice
- Use RAUVORA - a nutrition and lifestyle tracking application for iOS and Android supporting animal-based, carnivore, and lion diet protocols. The app provides personalised daily meal guidance, recipe access, water intake tracking, activity logging, cycle-aware nutritional recommendations for women, and a gamified pride progression system.
- Engage with us in other related ways, including any marketing or events
Questions or concerns? Contact us at contact@rauvora.com - we're responsible for making decisions about how your personal information is processed.
Summary of Key Points
What personal information do we process? We may process personal information depending on how you interact with our Services, the choices you make, and the products and features you use.
Do we process sensitive personal information? Yes - health data and menstrual/cycle data, with your consent or as permitted by law.
Do we collect information from third parties? No.
How do we process your information? To provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law.
How do we keep your information safe? We have appropriate organisational and technical measures in place, though no transmission over the internet is 100% secure.
How do you exercise your rights? Email us at contact@rauvora.com. We will consider and act on any request in accordance with applicable data protection laws.
Table of Contents
- 01 What information do we collect?
- 02 How do we process your information?
- 03 Legal bases we rely on
- 04 When and with whom do we share?
- 05 AI-based products
- 06 International transfers
- 07 How long do we keep your data?
- 08 How do we keep your data safe?
- 09 Information from minors
- 10 Your privacy rights
- 11 Do-Not-Track features
- 12 US residents' rights
- 13 Other regions' rights
- 14 Updates to this notice
- 15 How to contact us
- 16 Review, update, or delete your data
01What Information Do We Collect?
Personal information you disclose to us
We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.
The personal information we collect may include:
- Names
- Email addresses
- Usernames
- Passwords
- Date of birth (used to confirm you are 18 or older and to personalise guidance by life stage)
- Profile photo (optional)
- Contact or authentication data
Sensitive information
When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:
- Health data
- Menstrual/cycle data
- Allergies and dietary restrictions
- Body metrics you provide, such as weight and activity level
Payment data
We may collect data necessary to process your payment if you choose to make purchases. All payment data is handled and stored by RevenueCat, Apple App Store, and Google Play. Their privacy notices can be found at: revenuecat.com/privacy, apple.com/legal/privacy, and policies.google.com/privacy.
Application data
If you use our application(s), we also may collect the following information if you choose to provide us access or permission:
- Mobile Device Access. We may request access to certain features from your mobile device, including storage and other features. You may change our access permissions in your device's settings.
- Push Notifications. We may request to send you push notifications regarding your account or certain features. You may turn these off in your device's settings.
All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes.
02How Do We Process Your Information?
We process your personal information for a variety of reasons, depending on how you interact with our Services, including:
- Account creation and authentication. To create and manage your account.
- Delivery of services. To provide you with the requested service.
- User support. To respond to your inquiries and solve any potential issues.
- Administrative communications. To send details about our products, services, and policy changes.
- Feedback. To request feedback and contact you about your use of our Services.
- Security. To keep our Services safe and secure, including fraud monitoring and prevention.
- Usage trends. To better understand how our Services are used so we can improve them.
- Vital interests. To save or protect an individual's vital interest, such as to prevent harm.
03What Legal Bases Do We Rely On?
We only process your personal information when we believe it is necessary and we have a valid legal reason to do so under applicable law.
If you are located in the EU or UK
The GDPR and UK GDPR require us to explain the valid legal bases we rely on:
- Consent. We may process your information if you have given us permission for a specific purpose. You can withdraw your consent at any time.
- Performance of a Contract. We may process your personal information when necessary to fulfil our contractual obligations to you.
- Legitimate Interests. We may process your information when reasonably necessary to achieve our legitimate business interests.
- Legal Obligations. We may process your information where necessary for compliance with our legal obligations.
- Vital Interests. We may process your information where necessary to protect your vital interests or those of a third party.
If you are located in Canada
We may process your information with your express or implied consent, or in exceptional cases where permitted by law without consent - such as for fraud detection, business transactions, legal proceedings, or where the information is publicly available.
04When and With Whom Do We Share Your Personal Information?
We may share your data with third-party vendors, service providers, contractors, or agents who perform services for us or on our behalf. We have contracts in place with all third parties to safeguard your personal information.
The third parties we may share personal information with are:
- Functionality and Infrastructure: Supabase
- Invoice and Billing: RevenueCat
We may also share your personal information in connection with any merger, sale of company assets, financing, or acquisition of all or a portion of our business.
05Do We Offer AI-Based Products?
As part of our Services, we offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies. These tools are designed to enhance your experience and provide you with innovative solutions, specifically for personalisation and recommendations.
All personal information processed using our AI Products is handled in line with this Privacy Notice and our agreements with third parties.
06Is Your Information Transferred Internationally?
Our servers are located in the United States and European Union. Your information may be transferred to, stored by, and processed in our facilities and in the facilities of third parties with whom we share your personal information.
If you are a resident in the EEA, UK, or Switzerland, please be aware that these countries may not have data protection laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this Privacy Notice and applicable law.
We have implemented the European Commission's Standard Contractual Clauses for transfers of personal information. Our Standard Contractual Clauses can be provided upon request.
07How Long Do We Keep Your Information?
We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law. No purpose in this notice will require us to keep your personal information for longer than the period of time in which you have an account with us.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it.
08How Do We Keep Your Information Safe?
We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. However, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure.
Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.
09Do We Collect Information from Minors?
We do not knowingly collect, solicit data from, or market to children under 18 years of age. By using the Services, you represent that you are at least 18 years of age or the equivalent minimum age as specified by law in your jurisdiction.
If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data. If you become aware of any data we may have collected from children under age 18, please contact us at contact@rauvora.com.
10What Are Your Privacy Rights?
In some regions (the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right to:
- Request access and obtain a copy of your personal information
- Request rectification or erasure of your personal information
- Restrict the processing of your personal information
- Data portability, where applicable
- Not be subject to automated decision-making
- Object to the processing of your personal information
If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you have the right to complain to your Member State data protection authority or UK data protection authority.
Withdrawing your consent: You may withdraw your consent at any time by contacting us using the details in section 15, or by updating your preferences in the app.
Account information
You can review or change the information in your account, or terminate your account, by logging into your account settings or contacting us. Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases.
Questions about your privacy rights? Email us at contact@rauvora.com.
11Controls for Do-Not-Track Features
Most web browsers and some mobile operating systems include a Do-Not-Track ('DNT') feature or setting. At this stage, no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online.
12Do United States Residents Have Specific Privacy Rights?
If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have specific privacy rights.
Categories of personal information we collect
| Category | Examples | Collected |
|---|---|---|
| A. Identifiers | Name, email address, account name, unique identifiers | Yes |
| B. Personal info (CA Customer Records) | Name, contact information, financial information | Yes |
| C. Protected classification characteristics | Gender, age, date of birth, demographic data | Yes |
| D. Commercial information | Transaction information, purchase history, payment information | Yes |
| E. Biometric information | Fingerprints and voiceprints | No |
| F. Internet or network activity | Browsing history, online behaviour | No |
| G. Geolocation data | Device location | No |
| H. Audio, electronic, or similar info | Images and audio/video recordings | Yes |
| I. Professional or employment-related info | Work history, professional qualifications | No |
| J. Education information | Student records and directory information | No |
| K. Inferences drawn from personal info | Profile or summary about individual's preferences | Yes |
| L. Sensitive personal information | Health data and account login information | Yes |
We have not sold or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months.
Your rights
- Right to know whether or not we are processing your personal data
- Right to access your personal data
- Right to correct inaccuracies in your personal data
- Right to request the deletion of your personal data
- Right to obtain a copy of the personal data you previously shared with us
- Right to non-discrimination for exercising your rights
- Right to opt out of the processing of your personal data if used for targeted advertising, the sale of personal data, or profiling
To exercise these rights, contact us at contact@rauvora.com.
California 'Shine The Light' Law
California Civil Code Section 1798.83 permits California resident users to request information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes. Please submit any such request in writing using the contact details in section 15 below.
13Do Other Regions Have Specific Privacy Rights?
Australia and New Zealand
We collect and process your personal information under the obligations and conditions set by Australia's Privacy Act 1988 and New Zealand's Privacy Act 2020. If you believe we are unlawfully processing your personal information, you have the right to submit a complaint to the Office of the Australian Information Commissioner or the Office of New Zealand Privacy Commissioner.
Republic of South Africa
At any time, you have the right to request access to or correction of your personal information. If you are unsatisfied with how we address any complaint, you can contact the Information Regulator (South Africa):
- General enquiries: enquiries@inforegulator.org.za
- Complaints: PAIAComplaints@inforegulator.org.za & POPIAComplaints@inforegulator.org.za
14Do We Make Updates to This Notice?
Yes - we may update this Privacy Notice from time to time. The updated version will be indicated by an updated date at the top of this Privacy Notice. If we make material changes, we may notify you either by prominently posting a notice or by directly sending you a notification. We encourage you to review this Privacy Notice frequently.
15How Can You Contact Us About This Notice?
If you have questions or comments about this notice, you may email us at contact@rauvora.com. We aim to respond within 5 business days.
16How Can You Review, Update, or Delete the Data We Collect?
Based on the applicable laws of your country or state of residence, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information.
To request to review, update, or delete your personal information, please contact us at: contact@rauvora.com.