Privacy Policy

This Privacy Policy explains how Pruvi App (“we”, “us”, or “our”) collects, uses, shares, and protects your personal data when you use our app, Telegram bot and website. We are committed to complying with applicable data protection laws, including:

EU General Data Protection Regulation (GDPR)
United Kingdom General Data Protection Regulation (UK GDPR), Data Protection Act 2018, Privacy and Electronic Communications Regulations (PECR), and Data (Use and Access) Act 2025 (DUAA)
California Consumer Privacy Act (CCPA)
Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA), Canada’s Anti-Spam Legislation (CASL), and substantially similar provincial laws (including Quebec Law 25, Alberta PIPA, and British Columbia PIPA).

Pruvi acts as the data controller for the personal data described in this policy.

1. Information We Collect

We may collect the following categories of personal data:

Personal identifiers: name, email address, account details
Device information: IP address, device type, operating system
Usage data: tracks played, frequency, duration of sessions
Log and crash data
Analytics data: collected via third-party services (e.g. Firebase, Amplitude, Google Cloud)
Session replay data: recordings of how you interact with the app, collected via Amplitude Session Replay (see Section 7)
Marketing and preference data: opt-ins, communications history
Location data (if you choose to enable location-based features)

2. Legal Bases for Processing

EU/EEA (GDPR): contract, legitimate interests, consent, legal obligations
UK (UK GDPR, DUAA): as above, plus recognised legitimate interests (e.g. safety, crime prevention); expanded transparency for automated decision-making and “stop-the-clock” rights in access requests
Canada (PIPEDA, provincial laws): meaningful consent, identified purposes, accountability
California (CCPA): collection, use, disclosure, and rights as described in Section 5

3. How We Use Information

We use your personal data to:

Provide and personalize the service, including activity recommendations
Improve services, fix bugs, and develop new features
Send service and marketing communications (with appropriate consent/opt-out options)
Ensure security, prevent fraud, and comply with law enforcement requests
Conduct analytics and improve app performance
Manage age-appropriate experiences for children

We do not sell your personal data.

We may share personal data with:

Service providers (e.g. Firebase, Amplitude, Google Cloud, analytics and crash reporting tools)
Advertising/marketing partners (only where you consent)

International Transfers

EU/EEA: SCCs or equivalent safeguards
UK: ICO-approved transfer mechanisms
Canada: we remain accountable and use contractual protections; in Quebec, we disclose international transfers and third-party categories

5. Your Rights

Access, rectification, erasure, restriction, portability, objection, withdraw consent, lodge complaints

The same rights as under the GDPR, plus:

Right to human review of solely automated decisions with significant effect
Stronger transparency around profiling
Right to refuse cookies/SDKs except strictly necessary ones
Children’s rights under AADC (high-privacy by default, no manipulative design)

Canada (PIPEDA + provincial laws)

Access and correction
Withdraw consent
Information about international transfers and third-party disclosures
Quebec: right to data portability, disclosure of profiling/automated decisions, high-privacy defaults
Alberta/BC: right to know policies/practices, right to complain to provincial commissioners

California (CCPA)

Right to know, access, delete, opt out of sale/sharing (we do not sell data), non-discrimination

How to Exercise Rights

Contact: contact@pruvi.app. We may verify your identity.

6. Cookies, Tracking & Marketing

Cookies & SDKs: We use cookies and similar technologies for analytics, crash reporting, session replay, and (with consent) advertising. Under PECR/UK GDPR, non-essential cookies require consent. In Canada, we follow CASL and Law 25 disclosures.
Marketing (UK): consent or soft opt-in, with opt-out at any time
Marketing (Canada): CASL requires express or implied consent, clear sender identification, and unsubscribe mechanisms
Marketing (California): opt-out rights apply even though we do not sell data

7. Session Replay (Amplitude)

We use Amplitude Session Replay, provided by Amplitude, Inc., to understand how people use Pruvi so we can find and fix bugs, spot confusing screens, and improve the product.

What session replay records

When session replay is active, the Amplitude SDK captures a reconstruction of your session rather than a video of your screen. This may include:

Screens and pages you view, and the order in which you view them
Taps, clicks, scrolls, swipes, and navigation between screens
The layout and visible state of the interface, such as which elements are shown
Technical context, such as device type, operating system, app version, screen size, and session timing
Errors or crashes that occur during the session

What session replay does not record

We configure session replay to mask text you type and other sensitive fields by default. Passwords, payment details, and the contents of text inputs are not captured. Session replay does not record audio, your camera, or anything outside the Pruvi app or website.

How we use session replays

We use session replays only to diagnose technical issues, improve usability and app performance, and investigate suspected fraud or abuse. We do not use session replays for advertising, and we do not sell them.

Session replays are recorded for a sample of sessions, not every session. They are linked to the same pseudonymous identifiers we use for analytics, so authorised members of our team can review a replay alongside related analytics events when investigating an issue.

Legal basis and your choices

EU/EEA and UK: where session replay relies on non-essential storage or access to your device, we only enable it with your consent, which you can withdraw at any time. Otherwise we rely on our legitimate interest in keeping Pruvi reliable and usable.
Canada: we rely on your consent, which you can withdraw at any time.
California: session replay data is used only as a service provider function on our behalf. We do not sell or share it for cross-context behavioural advertising.

You can opt out of analytics and session replay at any time by contacting contact@pruvi.app or, where available, through the privacy settings in the app.

Storage and retention

Session replay data is processed and stored by Amplitude on our behalf under a data processing agreement. It may be processed in the United States, using the transfer safeguards described in Section 4. Replays are kept for a limited period and then deleted automatically.

8. Garmin Data

If you choose to connect your Garmin account to Pruvi, we may receive and process activity and fitness data from Garmin Connect with your explicit authorization.

What Garmin data we collect

Depending on the Garmin APIs enabled for your account and the permissions you grant, Pruvi may collect the following Garmin data:

Activity summaries, including activity type, start time, duration, distance, elevation, speed, pace, calories, and related workout metrics.
Activity details, including GPS route data, heart rate, cadence, power, splits/laps, and other sensor-based performance data where available.
User profile or athlete information provided by Garmin, such as Garmin user identifier and basic account-related data needed to connect your Garmin account.
Wellness or fitness data, if enabled, such as daily activity, steps, body battery, sleep, stress, heart rate, or similar metrics made available through Garmin APIs.

We only collect Garmin data that is necessary to provide Pruvi features and only after you authorize the Garmin connection.

How we use Garmin data

We use Garmin data to:

Import and verify your cycling, running, and other endurance activities.
Display your activities, statistics, progress, rankings, challenges, streaks, and competition results inside Pruvi.
Calculate performance-related metrics, points, leaderboards, achievements, and team or seasonal progress.
Improve app reliability, detect sync issues, prevent fraud or abuse, and support user requests.
Develop and improve Pruvi features using aggregated or de-identified insights where possible.

We do not sell Garmin data.

How we process Garmin data

Garmin data is processed by Pruvi systems to synchronize activities, normalize activity metrics, calculate in-app results, and display user-facing features. Some processing may be automated, such as calculating points, rankings, challenge progress, streaks, or activity eligibility.

Garmin data is not used for advertising profiling.

Where and how long we store Garmin data

Garmin data is stored in Pruvi’s secure cloud infrastructure and databases, including service providers used to operate the app, such as Google Cloud / Firebase and related hosting, database, analytics, monitoring, or crash-reporting tools.

We retain Garmin data for as long as your Pruvi account remains active or as long as needed to provide the service, maintain competition history, comply with legal obligations, resolve disputes, prevent abuse, and enforce our agreements.

If you disconnect Garmin or request deletion of your account, we will delete or anonymize Garmin data unless we are required or permitted to retain certain records for legal, security, fraud prevention, backup, or legitimate business purposes. Backup copies may remain for a limited period before automatic deletion.

We may share Garmin data only with service providers that help us operate Pruvi, such as cloud hosting, database, analytics, crash reporting, monitoring, customer support, and infrastructure providers. These providers process data on our behalf and are not permitted to use Garmin data for their own independent purposes.

We may also disclose Garmin data if required by law, court order, regulatory request, or to protect the rights, safety, and security of Pruvi, our users, or others.

We do not sell Garmin data and do not share Garmin data with advertising partners.

AI and third-party processing of Garmin data

Pruvi does not use Garmin data with third-party AI services, large language models, or external AI providers for automated analysis, training, profiling, or decision-making.

If Pruvi introduces any AI-based processing of Garmin data in the future, we will update this Privacy Policy and obtain any required approvals from Garmin before implementing such changes.