Privacy Policy
Last Updated: October 2, 2020

Welcome to the NERVY Inc. (“NERVY”, “we”, “our” or “us”) Privacy Policy (the “Policy”).

This Policy explains how we handle your personal information, including how we collect, protect, store, use, and share your personal information.

We suggest you read this Policy in combination with our Terms and Conditions of Use. This Policy is incorporated into the Terms of Use. If you have any questions or comments about this Policy, or any other policies or practices at NERVY, please feel free to contact us at: hello@nervy.io
OUR COMMITMENT TO YOU
At NERVY users come first. Maintaining user trust is at the heart of what we do, and that includes taking care in protecting your privacy. NERVY is committed to safeguarding your personal information and maintaining your trust. Privacy is our priority at NERVY. We take a proactive approach to protecting your personal information rather than treating it as an afterthought. We strive to integrate privacy protection measures at every stage in the development, build and design of our products and services.

The purpose of this Privacy Policy is to inform you of our privacy practices and explain how we handle your personal information, including:

• how we collect, store and protect your personal information;
• the purposes for we collect or share your personal information;
• how we intend to use your personal information;
• with which parties we may share your personal information; and
• to provide you with NERVY’s contact information should you have questions or concerns about our practices.
NOTICE TO CALIFORNIA CONSUMERS
If you are resident of California, the California Consumer Privacy Act (CCPA) provides you with privacy rights regarding our use of your personal information. To learn more about our data collection practices and your California privacy rights, visit section 9 of this Policy and the CCPA Privacy Notice
CONTENTS OF THIS POLICY
Click the links below for more information regarding how we handle your privacy:
1. Who We Are2. Application of This Privacy Policy 3. Information We Collect4. Purpose of Collection And Use of Your Information5. When and Why We Share Your Information6. Data Storage and Cross Border Transfers of Your Information7. Security8. Your Privacy Rights 9. How Long We Keep Your Information10. Children's Privacy11. Privacy Policy Updates And Changes12. How To Contact Us
1. WHO WE ARE
The company that is responsible for your personal information under this Privacy Policy (the “data controller”) is:

NERVY INC.

hello@nervy.io
2. APPLICATION OF THIS POLICY
This Privacy Policy applies to our websites, the NERVY mobile application (“App”), and other services operated by NERVY. In order to be transparent and ensure you’re always informed about how your personal information is handled across all our services, we make sure this Privacy Policy is available and easily accessible on all applicable platforms and services.
3. WHAT INFORMATION DO WE COLLECT?
Personal information can be collected in the following contexts:

• Information you provide us;
• Information generated from your devices;
• Information derived from your usage of our services; and
• Information we receive about you from third parties.

When you sign up to use our services, we collect the information needed to register for your NERVY account (what are the minimum data elements), which are your basic profile details. We also collect additional information you choose to provide us as you fill out the details of your NERVY profile. As you use our services, we also collect certain inference information about your activity in the NERVY app, such as access logs, and information about the devices you use to access our service. We may also collect information sent to us about you from third parties.

See the explanations below for more information:
INFORMATION YOU GIVE US
Registration: We collect information that is reasonably necessary to use our services. When you register for a NERVY account, we may collect certain information about you, such as:

• Name;
• Login information (username, password, security questions and answers);
• Email address;
• Mobile telephone number;
• Gender identity;
• Job or position title;
• Education;
• Date of birth;
• Age;
• Dating preferences;
• Hometown or city raised in;
• Photographs and videos uploaded to our platform;
• Diet, drinking or smoking habits;
• Religious beliefs;
• Height; and
• Location Information.

Additional Information
: You may choose to provide additional details about yourself as you fill out your profile, such as information relating to your lifestyle, smoking or drinking habits, hobbies, interests and other personal information about you. We advise you to use your judgement and discernment and think critically about the information you choose to share in your profile, including your written bio, photos and videos.

Sensitive Information
: Please note that some of the information you choose to provide us may be considered “sensitive” personal information, such as information relating to your racial or ethnic background, sexual orientation, and religious beliefs. By choosing to provide this information, you consent to our processing of that information. Even though we take diligent care in protecting all types of personal information, including higher protection measures for categories of personal information deemed sensitive, we encourage you to be careful about posting sensitive information about yourself such as your religious background or health information. While you may choose to voluntarily provide such information, please remember that providing such sensitive or confidential information is entirely optional.
Advisory: We strongly advise against providing your personal contact details in your profile such as your email address, phone number, address, When you post sensitive or confidential information about yourself in your profile, including any information you choose to share in the chat function, please know that you are doing so at your own risk. A good rule of thumb is to not share anything on your personal profile you wouldn’t want to share in public.Geolocation: If you gave us your consent, we may collect your precise geolocation data. Please be aware that if you consented, collection of your geolocation data may occur in the background of your device even when you aren’t using the NERVY App. If you only want the App to collect your geolocation data while using our services, you may configure your settings to allow the collection of your geolocation only while using the NERVY App. You may also decline consent for us to collect your geolocation data in your App settings.

Customer Support: If you contact our customer support team through email, or telephone, we collect the information you provide us during each interaction, for verification and support purposes. We may monitor or record your customer support interactions for training purposes and for quality assurance. This means we may maintain recordings of our telephone, email or chat conversations with you, in accordance with our data retention practices. For more information of our data retention practices, see section 12 of this Policy.
Information Collected From Your Usage Activity And Device
As you use the NERVY App, certain information about you can be inferred and generated based on your activity on the App and from the devices you use to access our services.

Device Information: We may collect information about your device when you use the App including IP address, the unique device identifier and type, device model, browser type and version, language setting, operating system, MAC address, app crash reports, and internet and network activity information, your Bluetooth, wireless and mobile network connection.

Usage Information: We may collect information regarding your activity on the NERVY App, such as the date and time you logged in, the number of times you log-in, app features you used, searches, click path and pages you visited, external links like advertising that you have clicked on, interaction with other users like the time, date and frequency of messages sent and received.
Information We Receive From Third Parties
In addition to the information you choose to share with us, we may also receive information about you from others (third parties), including:

Other Users: Other users may provide information about you as they use our services. For instance, we may collect information about you from other users if they contact us about you.

Our Third-Party Advertising Partners:
We may receive information about you from our third-party advertising partners.

Social Media Accounts:
When you connect your social media account (such as Instagram or Facebook) to your NERVY profile, we may collect certain information including access to your friend lists and your social media posts (photos and videos).
4. Purpose of Collection and Use of Your Information
NERVY collects and uses the Personal Information that you supply to us or that is collected through your use of our App, website or from the emails we send for the following purposes:

• To provide our services and features to you;
• To improve our services;
• To contact you in connection with services you have requested and your inquiries;
• To provide customer support, and detect and prevent technical issues;
• To protect us and those visiting our App and website against fraud or other illegal or unauthorized activities;
• To conduct research and analytics about how you use the App;
• To notify you in connection with any changes to our services or this Policy;
• To ensure legal compliance with applicable laws and regulations including requests from law enforcement;
• To enforce our Terms & Conditions;
• To provide you with relevant offers and ads;
• If you opted in to allow us to do so, to send you marketing communications about our offers and services;
• To verify your identity and prevent fraud and ensure the safety of others;
• To facilitate payment for our paid services;
• To link your social media account to the NERVY App;
• To serve advertisements on third-party networks; and
• To defend legal claims and protect legal rights.

We may share your Personal Information we collect for the above purposes with our authorized employees, agents, service providers and legal representatives, and may also share this information with third parties engaged to provide products and services on our behalf. Such persons may only use your Personal Information for the purposes for which such information may be used by us under this Policy as identified above.

For more information about how we share your data, please see section 6 of this Policy
5. WHEN AND WHY WE SHARE YOUR INFORMATION
We will keep Personal Information that you provide to us private and will disclose such Personal Information only in accordance with this Policy.

NERVY does not sell, rent, or lease to third parties any Personal Information we collect from you. We may disclose or share Personal Information with our authorized employees, agents, legal representatives and service providers, for the purposes described in this Policy.

Please note that third party providers may change from time to time. We also share your Personal Information with service providers who assist with administering, hosting and supporting our App and Website services. These service providers may be located outside of Canada and data in transit may pass through other Countries (see section 7 on Cross-Border Transfers for more information).

If NERVY is involved in the sale or transfer of some or all of its business, NERVY may disclose your Personal Information In connection with the transfer or sale but will require the acquiring organization to agree to protect the confidentiality of your Personal Information in a manner that is consistent with this Policy.

If you choose to sign up for a paid subscription, NERVY will share your payment information to payment processing service providers.

NERVY will not otherwise share your Personal Information with third parties without your consent, unless authorized or required by law or as disclosed to you when the information is collected. We may disclose your Personal Information to a government institution or agency that has asserted its lawful authority to obtain the information or where we have reasonable grounds to believe the information could be useful in the investigation of unlawful activity, or to comply with a subpoena or warrant or an order made by a court, person or body with jurisdiction to compel the production of information, or to comply with court rules regarding the production of records and information, or to protect our rights and property.
THIRD PARTY PROCESSORS
We employ third-party service providers and companies with whom we share personal data. Those service providers will only have access to data to perform tasks on our behalf. The third parties that are mentioned in this Privacy and Cookie policy operate their respective services independent from us. Our website or application may have links to their respective websites.  

We strongly advise you to review the Privacy Policy of every third-party by visiting their respective websites. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party website.
Sub-Processing Activities
Organization
Country of Operations
Privacy Policy
Google Analytics (Google LLC)
Visitor's/User's data and analytics
USA
Firebase Inc.
Visitor's/User's data and analytics
USA
Apple Pay (In-App Purchase) (Apple Payments Inc.)
Subscribed User’s data and analytics
USA
SMS Sign Up User’s Phone Number
USA
Stripe Inc.
Twilio Inc.
Payment Processing
USA
6. DATA STORAGE AND CROSS-BORDER TRANSFERS
NERVY is a global app, with global reach. We are operating through servers located in a number of countries around the world, including the United States. This means that your information may be transferred, stored and maintained on servers located outside of your country, where different privacy and data protection laws may apply. If you live in a country with data protection laws, the storage of your personal data may not provide you with the same protections afforded to you in the country where you reside.

We only transfer, store and maintain your information to cross-border jurisdictions, when it is necessary or when we are subject to a legal duty or judicial order. We will take all measures that are reasonably necessary to ensure that all personal information is treated according to the highest standards of data protection, and in accordance with this Privacy Policy.

We represent and warrant that no transfer of your Personal Data will occur to any organization or jurisdiction unless we are confident there are adequate technical and legal control mechanisms in place that will guarantee the security of your (personal) data.

When we share information outside the European Economic Area (EEA) we use standard contract clauses approved by the European Commission to permit data transfers to other countries. Those Standard contractual clauses are commitments between companies transferring personal data, binding them to the security and protection of your data.
7. SECURITY
We keep the Personal Information we collect about you confidential and have adopted reasonable physical, technical and organizational procedures appropriate to the sensitivity of the data to safeguard the Personal Information you provide to us. Notwithstanding these measures, no collection, storage or transmission of information over the Internet on websites or otherwise can be guaranteed to be absolutely secure, and therefore we cannot ensure, warrant or guarantee the security of any such information.

A “breach of security safeguards” is defined as the loss of, unauthorized access to or unauthorized disclosure of personal information resulting from a breach of an organization’s security safeguards or from a failure to establish those safeguards.

To help keep your data secure, we suggest logging out of your account after use, never share your NERVY login credentials with anyone, and change your password from time-to-time. While these strategies cannot be guaranteed to prevent a breach from happening, they may offer some security.

In case of a breach of security safeguards involving your Personal Information under our control, we will notify you and the appropriate Privacy Commissioner(s) if it is reasonable in the circumstances to believe that the breach creates a real risk of significant harm to you, including physical, financial or reputational harm. We will also notify any other organization or government institution that can reduce the risk or mitigate the harm from the breach.
8. YOUR PRIVACY RIGHTS
You may withdraw your consent to the collection, storage, use, disclosure and retention of Personal Information about you at any time. To do this, please contact us at hello@nervy.io.
Withdrawal of your consent to the collection, storage, use, disclosure and retention of Personal Information may result in us being unable to contact you or you being unable to continue use of our Website or services.
EU AND UK USERS
In the EU, the General Data Protection Regulation (GDPR) gives users numerous privacy rights. Users may exercise these rights regarding their personal information stored and processed by us.

We extend these rights apply to all of our users:

• Right of access to the personal information we hold about you, in a data portable format.
• Right to correction: if the information we have about you in inaccurate, you have the right to have it updated.
• Right to deletion: you have the right to have your personal information deleted, subject to certain exceptions.
• Right to restrict processing of your personal information: in some scenarios, you can ask us to stop processing your personal information while retaining it.
• Right to data portability: you can request a copy of your personal information in a machine-readable form and, if technically feasible, have it transferred to another provider without any hindrance.
• Right to object: you may object to us processing your personal information if it is carried out on a legal basis other than consent (you can always withdraw your consent).
• Right to withdraw consent where previously given in the processing of your personal information.

Users in the UK and EU have the right to file a complaint with competent data protection authority in the EU, and the Information Commissioners’ Office (ICO) in the UK.

We will make every reasonable effort to keep your Personal Information accurate and up to date. It is your responsibility to notify us of any changes to your Personal Information, including contact information, so we can contact you and inform you about updates to this Policy and any other relevant information with respect to your use of our Website or services.
CALIFORNIA USERS
If you are resident of California, the California Consumer Privacy Act (CCPA) provides you with privacy rights regarding our use of your personal information, listed in the CCPA Privacy Notice.

Additionally, California's "Shine the Light" law, Civil Code section 1798.83 allows California users to learn if a business has shared their personal information with third parties for direct marketing purposes. If you wish to find out about any rights you may have under California Civil Code section 1798.83, you can write to us at hello@nervy.io
9. How long we keep your information – our Retention practices
We will keep and retain your Personal Information in accordance with our data retention policy. Your personal information will only be kept for as long as it necessary for the purposes for which it was collected, and as permitted or required by law.

We will delete, erase, securely destroy or anonymize your data once we no longer have a necessary business purpose for keeping it, except in situations where:

• We need to retain your personal information in order to comply with applicable legal, regulatory or compliance obligations;
• We need it to demonstrate evidence our compliance with applicable law;
• If there is there is an active issue, claim or dispute requiring us to keep the relevant information until it is resolved; or
• The information must be kept for our legitimate business interests, such as fraud prevention and enhancing users' safety and security.

Please note that once the retention period has expired, we may delete your (personal) data permanently, and as a result your right to access, delete and correct your (personal) data cannot be exercised by you.
10. CHILDREN’S PRIVACY
Our services are restricted to users who are 18 years of age or older. We do not permit users under the age of 18 on our platform and we do not knowingly collect personal information from anyone under the age of 18. If you suspect that a user is under the age of 18, please use the reporting mechanism available through the service.
11. Policy Changes and Updates
This Policy will be reviewed from time to time and we may need to update it. We will let you know by posting changes on our Website and in the NERVY App. Changes will be effective at the time of posting. It is your responsibility to review our Privacy Policy to ensure you are up to date on any changes that may affect you. If we make a change to this Policy that we consider to be a significant or material change, we will notify you, for example, via an email to the email associated with your Account or by posting a notice within the NERVY App.

Your continued use of our services constitutes your consent to the contents of any updates to our Privacy Policy. If you have any questions or concerns regarding any updates to our Privacy Policy, please contact us by e-mail us at: hello@nervy.io
12. HOW TO CONTACT US
If you would like more information about this Policy or the Personal Information collection, storage, use, disclosure and retention policies and practices of NERVY, please contact us by e-mail at: hello@nervy.io

Please let us know your questions or concerns and we will do our best to assist you.