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Privacy Policy

This Privacy Policy explains what personal data we collect when you use the Comeback Kegel app, the website at joinkegel.com and our checkout (together, the "Service"), why we collect it, who we share it with and what rights you have.

Effective date: 30 October 2026 Last updated: 30 October 2026

Contents

  1. Who we are
  2. Summary
  3. Data we collect
  4. How we use data
  5. Legal bases
  6. Who we share data with
  7. International transfers
  8. Retention
  9. Security
  10. Your rights
  11. Age limit
  12. Cookies
  13. Changes
  14. Contact

01Who we are

The controller of your personal data is Individual Entrepreneur Vladyslav Oleksandrovych Chvan ("we", "us", "our"), tax ID 3461107952, 15 Symona Petliury St., apt. 66, Brovary, Brovary District, Kyiv Oblast, 07403, Ukraine. Contact for any privacy question: admin@virea-apps.com.

02Summary

  • We collect only what we need to run the app, deliver your plan and manage your subscription.
  • Payments are handled by Paddle, our Merchant of Record. We never receive your full card details.
  • We do not sell your personal data.
  • You can access, correct, export or delete your data at any time by emailing us.

03Data we collect

3.1 Data you give us

  • Contact and account data: email address, login details, language.
  • Questionnaire answers: for example age range, activity level, daily routine, goals and the time you have for training. We use them to generate your training schedule.
  • Well-being information you choose to share: some questionnaire answers describe your physical well-being. This may be considered health data, see section 3.4.
  • Support messages: what you write to us and our replies.

3.2 Purchase data

Paddle processes your payment as Merchant of Record and shares with us what we need to provide the Service and support: your name and email, country and postal code, plan, price, transaction and subscription identifiers, and payment status. We do not receive or store full card numbers.

3.3 Data collected automatically

  • App usage: sessions completed, progress, streaks and settings such as reminder times.
  • Technical data: device type, operating system, app version, IP address, time zone, crash and error logs.
  • Website data: pages visited, referring link and browser type, recorded in standard server logs.

3.4 Health-related data

Information about your physical well-being is a special category of personal data in many countries. We process it only with your explicit consent, which you give when you submit the questionnaire, and only to personalise your training schedule. You can withdraw consent at any time by asking us to delete your answers; the app will then use a standard schedule. We do not use this information for advertising and do not share it with advertising partners.

04How we use data

  • to create your account, deliver access and generate your training schedule;
  • to run the app features: timer, reminders and progress tracking;
  • to manage your subscription, renewals, cancellations and refunds together with Paddle;
  • to answer your requests and provide support;
  • to keep the Service secure and prevent fraud and abuse;
  • to improve the Service using aggregated, de-identified statistics;
  • to send service emails (access details, receipts, important changes) and, if you agree, occasional product news, which you can unsubscribe from at any time;
  • to measure how our advertising performs, using limited technical data and, where required by law, only with your consent;
  • to comply with legal, tax and accounting obligations.

05Legal bases

Where the EU or UK GDPR or similar laws apply, we rely on: performance of a contract (providing the Service you bought); explicit consent (health-related questionnaire answers, marketing emails, non-essential cookies and ad measurement); legitimate interests (security, fraud prevention, improving the Service, which we balance against your rights); and legal obligation (tax and accounting records). We also process personal data in line with the Law of Ukraine "On Personal Data Protection".

06Who we share data with

We share personal data only with service providers that help us run the Service, under contracts that require them to protect it:

ProviderPurpose
Paddle.comCheckout, payments, tax, invoicing, subscription billing, refunds. Paddle acts as Merchant of Record and an independent controller for payment data under its own privacy policy.
Google FirebaseUser accounts, sign-in and app data storage.
AdaptySyncing your subscription status with the app.
CloudflareWebsite hosting, security and delivery of service emails.
Apple App Store, Google PlayApp download and updates, under their own terms.
Advertising platforms (for example Meta)Measuring ad performance with limited technical data, only where permitted and with consent where required. No health-related data is shared.

We may also disclose data if required by law, to protect our rights or users' safety, or to a successor in case of a business transfer, in which case this Policy will continue to apply.

07International transfers

Our providers may process data outside your country, including in the European Union, the United Kingdom and the United States. Where data leaves the EEA or the UK, we rely on adequacy decisions or standard contractual clauses approved by the European Commission or the UK authorities.

08Retention

  • Account, questionnaire and app data: while your account is active, and deleted within 30 days after you ask us to delete it or 24 months after your last activity.
  • Purchase and transaction records: as long as required by tax and accounting law, usually up to 5 years.
  • Support messages: up to 24 months after the conversation ends.
  • Server logs: up to 90 days.

09Security

We use encryption in transit (HTTPS/TLS), access controls and reputable infrastructure providers to protect your data. No system is perfectly secure, so please use a strong, unique password and tell us immediately if you suspect unauthorised access to your account.

10Your rights

Depending on where you live, you have the right to:

  • access the personal data we hold about you and receive a copy;
  • correct inaccurate data;
  • delete your data and your account;
  • restrict or object to certain processing, including direct marketing;
  • receive your data in a portable format;
  • withdraw consent at any time, without affecting earlier processing;
  • lodge a complaint with your local data protection authority (in Ukraine, the Ukrainian Parliament Commissioner for Human Rights).

California residents may also request to know what personal information we collect and to delete it. We do not sell your personal information. If measuring our ads counts as "sharing" under California law, you can opt out by emailing us. To exercise any right, email admin@virea-apps.com. We reply within 30 days and will not discriminate against you for using your rights.

11Age limit

The Service is intended only for adults aged 18 and over. We do not knowingly collect data from anyone under 18. If you believe a minor has given us personal data, contact us and we will delete it.

12Cookies

This website uses only technically necessary cookies and local storage needed for it to work. Paddle's checkout uses its own cookies to process payments securely and prevent fraud. If we add analytics or advertising cookies in the future, we will ask for your consent where the law requires it.

13Changes

We may update this Privacy Policy. The "Last updated" date above shows the current version. For material changes we will notify you by email or in the app before they take effect.

14Contact

Individual Entrepreneur Vladyslav Oleksandrovych Chvan
15 Symona Petliury St., apt. 66, Brovary, Brovary District, Kyiv Oblast, 07403, Ukraine
Email: admin@virea-apps.com

© 2026 Individual Entrepreneur Vladyslav Oleksandrovych Chvan. All rights reserved. Terms · Privacy · Refunds · Contact