Privacy policy

Last updated: 07 February 2026

This Privacy Policy describes how ZVYCHKA (“Company”, “we”, “us”, or “our”) collects, uses, stores, transfers, and otherwise processes personal data when you access or use our website and mobile application (collectively, the “Service”).

This Privacy Policy applies to users located in the European Union, Ukraine, the United States, and other jurisdictions where the Service is available.

We process personal data in accordance with:

        • Regulation (EU) 2016/679 (General Data Protection Regulation, “GDPR”)

        • applicable data protection laws of Ukraine

        • applicable U.S. federal and state privacy laws, including the California Consumer Privacy Act and California Privacy Rights Act (“CCPA/CPRA”), where applicable

1. Data Controller

The data controller responsible for processing your personal data is:

Company Name: ZVYCHKA
Email: hello@zvychka.app
Country: Ukraine

2. Scope of This Policy

This Privacy Policy applies to:

        • use of our website

        • use of our mobile application

        • all related services, features, and content

By accessing or using the Service, you acknowledge that you have read and understood this Privacy Policy.

3. Categories of Personal Data We Collect

3.1 Personal Data Provided by You

We may collect the following personal data when you voluntarily provide it:

        • name or chosen identifier

        • email address

        • account registration information

        • habit-related information, routines, preferences, and goals

        • textual content, notes, reflections, progress indicators, or other information you choose to enter into the Service

        • communications sent to us via email or in-app forms

Certain features of the Service allow users to participate in challenges and share selected progress-related information with other users, as further described below.

You are responsible for ensuring that the personal data you provide is accurate and up to date.

3.2 Data Collected Automatically

When you access or use the Service, we may automatically collect:

        • device information (device model, operating system, app version)

        • technical identifiers

        • log files

        • timestamps and session information

        • usage and interaction data related to features and performance

        • anonymized or pseudonymized IP address where technically feasible

4. Mobile Application–Specific Data

When you use our mobile application, we may collect application-related information such as:

        • diagnostic data

        • crash reports

        • error logs

        • performance and stability metrics

This data is processed for the purpose of ensuring application stability, security, and continuous improvement.

Apple App Store and Google Play Store operate independently and act as separate data controllers with respect to data processed in connection with app distribution, downloads, and payments.

5. Push Notifications

The mobile application may send push notifications related to the operation of the Service, including reminders, updates, account-related messages, and information about available features or subscription options within the Service.

Push notifications are optional and are sent only after the user has provided permission through the device operating system.

Users may disable push notifications at any time through their device settings.

Push notifications are used solely in connection with the Service and are not used for third-party advertising or cross-context behavioral advertising.

6. User-to-User Sharing and Social Features

The Service may include social or collaborative features that allow users to participate in challenges and share certain progress-related information with other users.

Information shared through these features may include selected habit data, completion status, or progress indicators, depending on the specific feature and user settings.

Any sharing of information with other users occurs solely as a result of the user’s voluntary participation in such features and is limited to the scope of the selected functionality.

Users acknowledge that any content or personal data they choose to share with other users becomes visible to those users in accordance with the Service settings.

7. Data We Do Not Intentionally Collect

The Service is not designed to collect:

        • medical or health data

        • diagnostic or therapeutic information

        • biometric or genetic data

        • data concerning physical or mental health conditions

        • advertising identifiers used for targeted advertising

        • personal data of children under the age of 13

Users are advised not to submit such data through the Service.

8. Purposes of Processing

We process personal data for the following purposes:

        • providing and maintaining the Service

        • enabling account creation, authentication, and management

        • storing and displaying user-entered data

        • enabling social and collaborative features, including challenge participation and progress sharing

        • ensuring technical functionality, stability, and security

        • analyzing usage patterns to improve features and performance

        • preventing fraud, abuse, and unauthorized access

        • complying with legal and regulatory obligations

9. Legal Basis for Processing

9.1 European Union / EEA (GDPR)

Processing is based on:

        • performance of a contract (Article 6(1)(b))

        • user consent (Article 6(1)(a))

        • legitimate interests, including service improvement and security (Article 6(1)(f))

        • compliance with legal obligations (Article 6(1)(c))

9.2 United States and Ukraine

Where applicable, processing is based on:

        • user consent

        • contractual necessity

        • legitimate business purposes

        • compliance with applicable legal requirements

10. Data Retention

Personal data is retained for the duration of the user account.

Users may delete their account and associated personal data at any time:

        • directly within the application (where available), or

        • by contacting us via email: hello@zvychka.app

Certain data may be retained for a longer period where required by law or for the establishment, exercise, or defense of legal claims.

11. Data Sharing and Disclosure

We may disclose personal data to:

        • hosting and infrastructure providers

        • analytics and monitoring service providers

        • professional advisors where legally required

        • courts, regulators, or public authorities when required by law

Personal data may also be disclosed to other users of the Service solely as a result of the user’s voluntary participation in social features, such as challenges. Such disclosure is limited to information the user chooses to share and does not constitute third-party data sharing.

We do not sell personal data and do not share personal data for advertising or cross-context behavioral advertising purposes within the meaning of the CCPA/CPRA.

12. International Data Transfers

Personal data may be transferred to and processed in countries outside the user’s country of residence.

Where required, such transfers are safeguarded by:

        • Standard Contractual Clauses approved by the European Commission

        • other lawful data transfer mechanisms

13. User Rights

13.1 GDPR Rights (EU/EEA)

Users have the right to:

        • access their personal data

        • request rectification

        • request erasure

        • restrict processing

        • data portability

        • object to processing

        • withdraw consent at any time

Users also have the right to lodge a complaint with a competent Data Protection Authority, including the authority in their country of residence, place of work, or place of alleged infringement.

13.2 United States Privacy Rights (CCPA/CPRA)

Where applicable, users have the right to:

        • Right to Know: request disclosure of categories and sources of personal data collected

        • Right to Correct inaccurate personal data

        • Right to Delete personal data

        • Right to Opt Out of the sale or sharing of personal data (not applicable, as no sale or sharing occurs)

        • Right to Non-Discrimination

We respond to verified consumer requests within 45 days, as required by applicable law.

13.3 Ukraine

Users may exercise rights provided under applicable Ukrainian data protection laws.

Requests

All privacy-related requests may be submitted via email:
hello@zvychka.app

14. Data Protection Officer

We have not appointed a Data Protection Officer, as we are not required to do so under applicable data protection laws.

15. Data Security

We implement appropriate technical and organizational measures designed to protect personal data against unauthorized access, alteration, disclosure, or destruction.

No method of transmission or storage is completely secure.

16. Children’s Privacy

The Service is not intended for children under the age of 13.
We do not knowingly collect personal data from children.

17. Changes to This Privacy Policy

We reserve the right to update this Privacy Policy at any time.

Changes will be published with an updated revision date.
Continued use of the Service constitutes acceptance of the revised Privacy Policy.

18. Contact Information

For questions or concerns regarding this Privacy Policy:

Email: hello@zvychka.app

COOKIES POLICY

This Cookies Policy applies to the use of cookies and similar technologies on our website.

1. What Are Cookies

Cookies are small text files stored on a user’s device when accessing a website. Cookies enable core functionality and support usage analysis.

2. Types of Cookies Used

2.1 Strictly Necessary Cookies

These cookies are required for:

        • basic website functionality

        • security

        • session management

2.2 Analytics Cookies

Analytics cookies are used to:

        • analyze website usage

        • monitor performance

        • improve stability and functionality

Where required by applicable law, analytics cookies are activated only after the user has provided consent through the website interface or are configured in a privacy-friendly manner.

3. Cookie Consent and Management

Users may manage or withdraw cookie consent through browser settings or available website controls.

Disabling cookies may affect website functionality.

4. Updates to Cookies Policy

This Cookies Policy may be updated periodically.
Changes will be published on this page.