Privacy Policy
Apparent Group Limited (“we,” “us,” or “our”) operates the Evolve mobile application (the “App”). We are committed to protecting your privacy and ensuring you understand how we collect, use, and safeguard your personal data.
This Privacy Policy applies to users of the Evolve App and is designed to comply with the General Data Protection Regulation (GDPR) for users in the European Economic Area (EEA) and the UK, as well as other applicable privacy laws.
1. Data Controller
The entity responsible for your personal data is:
Apparent Group Limited
FLAT/RM 05-06, 18/F, HOLLYWOOD PLAZA
610 NATHAN ROAD, KL
Hong Kong
Contact Email: hello@apparentgroup.co
2. Personal Data We Collect
On iOS: We collect data to provide account access, optional onboarding summaries, progress tracking, saved content lists, and meditation and spiritual content delivery.
On Android: We collect data to provide the App’s features, such as personalized meditation journeys, progress tracking, and spiritual content delivery.
2.1 Information You Provide to Us
- On iOS: Account Data: When you sign up via Email, Google, or Apple, we collect your name, email address, account identifier, authentication information, and profile photo when provided by you or your sign-in provider.
- On Android: Account Data: When you sign up via Email, Google, or Apple, we collect your name, email address, and authentication tokens.
- On iOS: Profile & Onboarding Data: Optional profile fields include nationality, gender, date of birth, phone number and country code, and street address. With your explicit consent, onboarding collects your answers about mental wellbeing, sleep, wellness goals, time available for practice, and spiritual or learning interests, together with a record of your consent.
- On Android: Profile & Onboarding Data: Information you provide during the personalization quiz, such as your meditation experience level, wellness goals, mental challenges, preferred session times, and spiritual interests.
- On iOS: Saved Content and Feedback: Your favorites, saved-list names, ratings, and feedback you choose to send. This version does not provide a journal-entry saving feature.
- On Android: User-Generated Content: Notes, journal entries, or other content you create within the App.
- Support Communications: Details you provide when contacting our support team.
2.2 Information Collected Automatically
- Usage Data: Details of your visits to the App, including content viewed (meditations, courses), lessons completed, time spent, streaks, quiz results, and feature interactions.
- Technical Data: Internet Protocol (IP) address, device type, operating system version, unique device identifiers, and App crash reports.
2.3 Special Categories of Data
On iOS: Optional onboarding answers may reveal information about your health, mental state, or spiritual beliefs. Before these questions are shown or saved on iOS, we ask for your explicit consent to store the answers with your account using Firebase, display your quiz summary, and resume onboarding. You can choose Skip questions and still continue to the app and subscription options. You can withdraw consent and delete these answers through Settings > Delete onboarding answers, without deleting your account or subscription.
On Android: By using an app focused on spirituality and mental wellness, you may voluntarily provide data that reveals information about your health, mental state, or spiritual beliefs. We process this Sensitive Personal Data only with your explicit consent, which is obtained when you onboard and use these specific features, for the sole purpose of personalizing your experience.
3. How We Use Your Data
We rely on the following legal bases to process your data:
- Contractual Necessity: To provide the App’s core services, manage your subscription, and track your progress.
- Legitimate Interests: To improve the App, analyze user engagement, ensure security, and prevent fraud.
- Consent: For processing sensitive data (health/spiritual preferences) and sending marketing communications (where required).
- Legal Obligation: To comply with applicable laws and regulations.
Specific purposes include:
- Creating and managing your user account.
- On iOS: Showing your optional onboarding summary and resuming your onboarding answers, and displaying recently played content and saved items.
- On Android: Delivering personalized content recommendations based on your quiz results and usage.
- Processing subscription payments (facilitated by third-party stores).
- Tracking your streaks, achievements, and learning progress.
- Sending service updates, reminders (e.g., meditation alerts), and promotional messages.
- Debugging and fixing technical issues.
4. Data Sharing and Processors
We do not sell your personal data. We share data with trusted third-party service providers (“Processors”) who assist us in operating the App. These include:
- On iOS: Infrastructure & Database: Google Firebase (USA/Global) for authentication, database hosting, cloud storage, remote configuration, and crash reporting through Firebase Crashlytics.
- On Android: Infrastructure & Database: Google Firebase (USA/Global) for authentication, database hosting, cloud storage, and analytics.
- Subscription Management: Adapty (USA/Global) for managing in-app purchases and paywalls.
- On iOS: Diagnostics: Firebase Crashlytics collects crash reports and diagnostic information to help us identify and fix technical problems. This version does not integrate Google Analytics for Firebase.
- On Android: Analytics: Google Analytics for Firebase to help us understand how the App is used.
We ensure these providers act only on our instructions and have appropriate security measures in place.
5. International Data Transfers
As an entity based in Hong Kong, your personal data will be processed outside the EEA/UK. Furthermore, our service providers (like Google) operate globally.
To ensure your data remains protected when transferred outside the EEA/UK, we rely on: Standard Contractual Clauses (SCCs) approved by the European Commission; Adequacy Decisions where applicable.
By using the App, you acknowledge that your data may be transferred to, stored, and processed in jurisdictions with different data protection laws than your country of residence.
6. Your Rights (GDPR)
If you are located in the EEA or UK, you have the following rights regarding your personal data:
- Right to Access: Request a copy of the personal data we hold about you.
- Right to Rectification: Request correction of inaccurate or incomplete data.
- Right to Erasure (“Right to be Forgotten”): Request deletion of your account and data, subject to legal retention requirements.
- Right to Restriction: Request that we limit the processing of your data.
- Right to Portability: Receive your data in a structured, machine-readable format.
- Right to Object: Object to processing based on legitimate interests or direct marketing.
- Withdraw Consent: Withdraw consent at any time where processing is based on consent (e.g., for sensitive data or marketing).
On iOS: To exercise these rights, please contact us at hello@apparentgroup.co. On iOS, Settings > Delete onboarding answers withdraws consent and deletes your optional onboarding answers. You can also delete your account directly via the “Danger Zone” in the App Settings.
On Android: To exercise these rights, please contact us at hello@apparentgroup.co. You can also delete your account directly via the “Danger Zone” in the App Settings.
7. Data Retention
On iOS: We retain your personal data only for as long as necessary to fulfill the purposes outlined in this policy. Account Data: Retained while your account is active. Usage Data: Listening history, progress, favorites and saved lists are linked to your account to provide these features. Optional onboarding answers are deleted when you use Delete onboarding answers in Settings. If you request account deletion, we will delete your personal data within 30 days, unless a longer retention period is required by law.
On Android: We retain your personal data only for as long as necessary to fulfill the purposes outlined in this policy. Account Data: Retained while your account is active. Usage Data: Anonymized or aggregated for analytical purposes. If you request account deletion, we will delete your personal data within 30 days, unless a longer retention period is required by law.
8. Security
We implement appropriate technical and organizational measures to protect your data against unauthorized access, loss, or alteration. These include encryption of data in transit and at rest, and strict access controls for our internal systems. However, no method of transmission over the internet is 100% secure.
9. Children’s Privacy
On iOS: The App is intended for adults (18+). We do not knowingly collect personal data from children under 18. If we discover we have collected data from a child, we will delete it immediately.
On Android: The App is intended for adults (18+). We do not knowingly collect personal data from children under 16. If we discover we have collected data from a child, we will delete it immediately.
10. Changes to This Policy
We may update this Privacy Policy from time to time. We will notify you of significant changes through the App or via email. The “Last Updated” date at the top of this policy indicates when the latest changes were made.
11. Contact Us
If you have questions about this Privacy Policy or our data practices, please contact our Data Protection Officer equivalents at:
Apparent Group Limited
Email: hello@apparentgroup.co
Address: FLAT/RM 05-06, 18/F, HOLLYWOOD PLAZA, 610 NATHAN ROAD, KL, Hong Kong