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.

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)

• 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

4. Data Sharing & International Transfers

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

EU/EEA (GDPR)

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

UK (UK GDPR, DUAA, PECR, AADC)

• Same as 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, 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

  • Canada: CASL requires express or implied consent, clear sender identification, and unsubscribe mechanisms

  • California: opt-out rights apply even though we do not sell data

7. 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.

Sharing Garmin data with third parties

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.