Privacy Policy

This Privacy Policy explains how Reya (“we,” “us,” or “our”) handles personal information when you access or use the Reya platform, including myreya.app and any related mobile application (together, the “Platform”).

Tarfion Ltd, Griva Digeni 59, Kaimakliotis Building, 5th Floor, 6043 Larnaca, Cyprus, acts as the controller of personal data that we process for our own purposes. Questions concerning personal data processed through the Platform may be sent to [email protected].

By using the Platform, you acknowledge that you have reviewed and understood this Privacy Policy.

We collect personal information that is reasonably necessary to provide, operate, and support the Platform.

2.1 Information You Provide to Us

Depending on how you use the Platform, you may provide us with:

• Account details, including the email address and password used to create your account.
• User Content.
• Billing and transaction information, such as billing address, tax-related information, subscription plan, transaction identifiers, purchase channel, payment status, renewal information, refunds, and chargeback details. We do not store full payment card numbers.
• Communications with us, including customer-support requests, emails, complaints, survey responses, feedback, and files or attachments you provide.
• Information submitted in connection with privacy requests, subscription cancellation, refund requests, or the exercise of other legal rights.

2.2 Information Collected Automatically

When you use the Platform, certain information may be collected automatically, including:

• Device and usage information, such as device type, operating system, browser information, pages visited, features used, and other interactions with the Platform.
• IP address, which may be used to determine an approximate location, such as country or region, for purposes related to providing the Service.

We may also use cookies and similar technologies, including local storage, software development kits, pixels, and comparable tools. These technologies may be used to operate and secure the Platform, authenticate users, remember settings, analyze usage and performance, investigate technical issues, test and improve functionality, measure attribution, and support advertising-related activities.

We may process personal information for purposes including:

• creating, maintaining, and administering user accounts;
• providing Platform functionality, reminders, and related services;
• processing payments and administering subscriptions;
• responding to support inquiries and other communications;
• maintaining, troubleshooting, improving, and developing the Platform; and
• complying with applicable legal and regulatory obligations.

We do not sell your personal data to third parties.

We may disclose personal information in the following circumstances:

• Service providers. We may share data with vendors and other third parties that provide services supporting the operation of the Platform, such as cloud infrastructure or payment processing. Where required, such providers are contractually restricted to processing personal data on our behalf and in accordance with applicable instructions and data-protection requirements.
• Public authorities and legal process. We may disclose information where necessary to comply with applicable law, legal process, a court order, or a regulatory requirement.
• Corporate transactions. If all or part of our business is involved in a merger, acquisition, restructuring, financing, sale, or similar transaction, personal data may be transferred as part of that transaction. Where required, we will notify you of a material change affecting the handling of your personal data.

We retain personal data for as long as reasonably necessary for the purposes described in this Privacy Policy, to perform our obligations under the Terms of Use, and to satisfy applicable legal or regulatory requirements.

Where the law requires particular information to be retained for a longer period, we will keep that information for the required retention period.

Certain information may continue to be retained after you delete your profile or Account where such retention is necessary or permitted. This may include retention for legal or regulatory compliance, financial and transaction recordkeeping, payment administration, fraud prevention, dispute resolution, anti-money laundering obligations, protection of the security and integrity of the Service, backup retention, or other legitimate legal or operational purposes.

Depending on where you live and the law that applies to the processing of your personal data, you may have rights including:

• Access. You may request information about the personal data we hold about you and, where applicable, obtain a copy.
• Correction. You may request correction of personal data that is inaccurate or incomplete.
• Deletion. You may request deletion of personal data, including where a statutory right to erasure applies.
• Portability. You may request certain personal data in a structured, commonly used, machine-readable format.
• Objection. You may object to certain processing carried out on the basis of our legitimate interests.
• Withdrawal of consent. Where we rely on consent as the legal basis for processing, you may withdraw that consent at any time.

To exercise any applicable privacy right, contact us using the support address [email protected].

We will respond within 30 days. Where permitted in exceptional circumstances, this period may be extended by up to two additional months. If an extension is required, we will inform you and explain the reason for the delay.

We use commercially reasonable technical and organizational safeguards designed to protect personal data against unauthorized access, use, disclosure, alteration, loss, or destruction.

No internet transmission or electronic storage system can be guaranteed to be completely secure. Accordingly, we cannot guarantee absolute security of personal information.

Your personal data may be stored or processed in countries other than the country in which you reside. Some of those countries may have data-protection laws that differ from those applicable in your home jurisdiction.

Where personal data is transferred internationally, we take appropriate measures as required by applicable law to protect the information and provide an appropriate level of data protection.

The Platform is intended only for users aged 18 or older. We do not knowingly collect personal data from individuals under the age of 18.

If we learn that personal data has been provided by a minor, we will take steps to delete that information promptly.

We may send communications to the email address associated with your Account.

You may unsubscribe from marketing emails at any time by using the unsubscribe mechanism included in the relevant message or by contacting our Support Team at [email protected].

Opting out of marketing messages does not affect operational or transactional communications that are necessary to provide or administer the Service. These may include communications concerning billing and payments, security, Account administration, legal or regulatory notices, or services you have specifically requested.

We may revise this Privacy Policy from time to time. If we make material changes, we will post the updated version on myreya.app and, where appropriate, may also notify you by email.

The date of the latest revision will be identified at the top of the applicable Privacy Policy.

If you have questions about this Privacy Policy or would like to exercise applicable privacy rights, please contact us at [email protected].