Privacy Policy

1. Introduction

This Privacy Policy explains how MAMATECH LTD. (hereinafter the "Company", "we" or "us") collects, stores, uses, transfers and shares (hereinafter "processes") information, including personal data, from our users ("you") in connection with Soula mobile application (the "App"), and our website soula.care (the "Website") if applicable.

When you use the App, you are trusting us with intimate personal data and other information.

By providing to us your information, including personal data, through the App, you expressly acknowledge, agree and consent to processing of your personal information as specified in this Privacy Policy. The processing of your information is necessary for providing the services to you and supporting the App.

The purpose of our Privacy Policy is to explain what data we collect, how it is used and shared, and how you can control it.

In case of changes in this Privacy Policy, we will notify you on the e-mail address provided when you register or through the App. Your continued use of the App after the effective date of an updated version of the Privacy Policy will indicate your acceptance of the Privacy Policy as modified.

If you do not accept the terms of the Privacy Policy, please do not use the App.

2. What data we collect

We collect your information in many ways. See below what information we collect from you directly and what information we collect automatically.

Information you give us directly

General information

• Username
• E-mail address
• Date of Birth
• Password or passcode
• Minimum place of residence (state, town)
• Image (if you give us permission)

Health and well-being information

• Menstrual cycle dates
• Details of your pregnancy
• Various symptoms related to your menstrual cycle, pregnancy and health
• Other information about your health (including sexual activities), physical and mental well-being, and related activities, including personal life (if necessary)

Information collected to provide better services

• Your goals in the App
• The topics you may find interesting in the App
• Your messages in the App's chatbot

Information we collect automatically

Device Information

• Device model, ID and type
• Device storage information
• Information about the operating system and its version
• Mobile operator and network information
• App settings and characteristics
• App crashes and reports
• Advertising IDs
• Cookies or other tracking technologies that may uniquely identify a device or browser

Location Information

• IP address
• Time zone
• Information about your mobile service provider
• Geolocation (if you give us permission)

Usage information

• Activity in the App when you logged in, features you've been using, actions taken, etc.
• Areas and features of the App that you access, visit or use
• Engagement with particular features
• Information you provide to chatbot in the App
• Actions with the content of the App
• Information shown to you, referring webpages address and ads that you interacted with
• Your interactions with other members (e.g., members you connect and interact with, when you exchanged with them, number of messages you send and receive)
• Information you provide to our Support team
• Information you provide in the chats with other members

3. How we use your information

We will not collect and use your personal data without letting you know. All information is collected according to this Privacy Policy and Terms of Use. We will notify you in case we need additional information and — where applicable — ask for your consent.

The main reason we use your information is to deliver and improve our services. Additionally, we use your information to help keep you safe. We take reasonable and appropriate measures to protect your information from loss, theft, misuse or unauthorized access. See more in Section 7 hereof.

To process your personal data correctly, we rely on one or more of the following legal bases:

Consent. For example, on the registration screen when you give us permission to process your personal data, which may also include some sensitive personal data.

In some cases, you may withdraw your consent by adapting your settings or by deleting your content if possible. In any case, you may withdraw your consent at any time by contacting us at the address provided at the end of this Privacy Policy.

To provide our service to you. The reason we process your information is to let you use the App in full. We use your information to maintain your account and your profile, including but not limited to create and manage your account, to provide you support services, etc.

Legitimate interest. We may process your personal data in relation to our interests in providing the services to you, our commercial interests, including our interest in protecting the security and integrity of the services, and wider societal benefits.

Legal obligation. We may be obligated to process some of your personal data to comply with applicable laws and regulations and to assist law enforcement where it is necessary for us to comply with applicable laws and regulations and evidence our compliance with applicable laws and regulations. Note that we will not disclose your sensitive personal data if such disclosure may cause you harm. Find more about it in our Privacy Statement.

4. Principles of processing

Data minimization and purpose limitation. We will process your personal data only in accordance with the purposes for which it has been collected. For any new purpose of processing (new feature, etc.) we will ask your separate consent. We collect only that personal data from you which is necessary for the declared purposes.

No sale of personal data. We will not sell or rent your personal data. We will not disclose your personal data except as otherwise described in this Privacy Policy.

5. Disclosure of your information

As our main goal is to provide you the proper services, we can share some of your information with other users, our partners or state bodies. We will ask your separate informed consent in case we need to disclose your information to any third parties.

We will not share your personal data with third parties except as specified below.

Our service providers and partners

We may share your personal data with our service providers who are bound with us by strict contractual obligations solely as described in this Privacy Policy.

Here is the list of our main processors upon which we rely:

• Amplitude (Amplitude, Inc.) Amplitude is an analytical tool used to collect data on app usage to understand how the App is used, how you engage with particular features and what you like or dislike the most; to generate statistical reports.
• AppsFlyer (AppsFlyer, Inc.) AppsFlyer is a data integration tool used to collect data relating to device model, language and operating system.
• Firebase. Firebase is a hosting service for databases, content, social authentication, and notifications.
• OpenAI. OpenAI trains an artificial intelligence model called ChatGPT which interacts in a dialogue format. We may transfer your chatbot messages to OpenAI in order to answer your questions regarding health, pregnancy and maternity. Such messages may contain your health data. Please note that we do not transfer any other information that may identify you. DISCLAIMER: chatbot answers can not be considered any kind of special medical care.

We will update this Privacy Policy in case any other personal data processors are engaged in processing of your data in the App.

State bodies

We may disclose your information if reasonably necessary:

• to comply with a legal process, such as a court order, subpoena or search warrant, government law enforcement investigation or other legal requirements (see our Privacy Statement for more);
• to assist in the prevention or detection of crime (subject in each case to applicable law);
• to protect the safety of any person;
• if disclosure would mitigate our liability in an actual or threatened lawsuit;
• as necessary to protect our legal rights and legal rights of our members, business partners or other interested parties;
• to enforce our agreements with you;
• to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.

6. Your privacy rights

We stand by high European and international standards on personal data protection so that we comply with your personal data rights regardless of your location. You have the following rights regarding our processing of your personal data:

Access to your personal data. You have a right to request information about what personal data we process about you, to access all your personal data, and receive a copy of it, including in a structured and portable form.

Correction of your personal data. If you believe that your personal data is inaccurate, you have a right to contact us and ask us to correct such personal data.

Restriction of processing. You have a right to request that the processing of your personal data be restricted in some circumstances. For example, you have the right to request the restriction of your personal data if you contest the accuracy of your personal data and we need some time to verify its accuracy.

Erasure of your personal data. You may ask us to erase your personal data if you withdraw your consent to processing, if you believe such processing is unlawful. Please be aware that erasing some personal data may affect your experience using certain features of the App.

Right to object to the processing of your personal data. In some cases, you can object to the processing of your personal data, for example, if we process it under the legitimate interest basis, by contacting us at info@soula.care.

Uninstall. You can stop all information collection by the App by uninstalling it using the standard uninstall process for your device. Remember that uninstalling an app does NOT close your account. To close your account, please contact us at info@soula.care in free form.

7. Retention of your information

We will retain your personal data as long as needed to provide you with the services in the App or otherwise fulfill the purposes for which it was collected.

If you choose to deactivate your account, we will delete all your personal data and it will not be recoverable should you later create another account.

If you choose to delete the App from your device or your account becomes inactive, we will retain your personal data for a period of 3 years in case you decide to re-install the App.

Limitations: You should be aware that, although we will anonymize or otherwise de-identify your data where possible, we may retain certain information, including personal data, after your account has been terminated or deleted as necessary to comply with legal obligations, resolve disputes and enforce our agreements.

8. Security of your information

General security measures

We implement technical and organizational measures in an effort to protect your information, including personal data, from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the nature of the information that we process, and risks associated with special categories of personal data we collect (information about health). These measures include:

• Pseudonymization and tokenization of certain categories of your personal data.
• Encryption of your personal data in transit and in rest.
• Systematic vulnerability scanning and penetration testing.
• Protection of data integrity.
• Organizational and legal measures. For example, our employees have different levels of access to your personal data and only those in charge of data management get access to your personal data and only for limited purposes required for the operation of the App. We impose strict liability on our employees for any disclosures, unauthorized accesses, alterations, destructions, misuses of your personal data.
• Conducting periodical data protection impact assessments in order to ensure that the App fully adhere to the principles of 'privacy by design', 'privacy by default' and others. We also commit to undertake a privacy audit in the event of Company's merger or takeover.

Please understand that you can help keep your information secure by choosing and protecting your password appropriately, not sharing your password and preventing others from using your mobile device. However, no security system is perfect and, as such, we cannot guarantee the absolute security of the App, or that your information will not be intercepted while being transmitted to us.

Security breaches

If we learn of a security systems breach, we may either post a notice, or attempt to notify you by email and will take reasonable steps to remedy the breach as specified in this Privacy Policy. If we learn of a potential personal data breach, together with other actions referred to in the Privacy Policy (such as notifying you in certain cases), we will also undertake particular actions to remedy the breach as appropriate under the circumstances, which may include, logging you out from all the devices, resetting a password (sending a temporary password for you to apply) and performing other reasonably necessary activities and actions.

If you want to report a security incident related to the App please contact us at info@soula.care.

9. Contact us

If you have any questions or concerns about your privacy, you may contact us at 28 Oktovriou, 367, MEDITERRANEAN COURT, Floor 1, Flat/Office A5, 3107, Limassol, Cyprus,
or by e-mail info@soula.care.

You may also contact your local data protection authority.