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CyberLiver’s Privacy Policy

Last Modified: October 31, 2018

We at CyberLiver (CyberLiver, Ltd. and our affiliates) are committed to protecting your privacy. This Privacy Policy applies to both our and partner websites ( www.portal.cyberliver.com , www.alcochange.com, www.drydays.me) and our associated mobile application Dry Days (iOS & Android) owned and controlled by CyberLiver. 

This Privacy Policy governs our data collection, processing and usage practices. It also describes your choices regarding use, access and correction of your personal information. If you do not agree with the data practices described in this Privacy Policy, you should not use the Mobile application, Platform, Websites and other online services provided by CyberLiver.

We periodically update this Privacy Policy. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice by sending you an email notification through our data processors, through Notifications in the app in your app web portal.

While we will notify you of any material changes to this Privacy Policy, we encourage you to review this Privacy Policy periodically. We will also keep prior versions of this Privacy Policy in an archive for your review.

If you have any questions about this Privacy Policy or our treatment of the information you provide us, please write to us by email at privacy@cyberliver.com or by mail to CyberLiver, First Floor, Burnells, 5 Garland Road, Stanmore, Middlesex, HA71NR, UK, Attn: Privacy

Zanec ("us", "we", or "our") operates the Dry Days App (the "Service") under limited License and approved as a data processor registered with CyberLiver is authorised to collect the information & personal data provided by the users on our website, portal, and mobile applications. This page informs you of our policies regarding the collection, use and disclosure of Personal Information when you use our Service. We will not use or share your information with anyone except as described in this Privacy Policy. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, accessible here

  1. Information We Collect
  2. How We Use Information We Collect
  3. How we Share Information we Collect
  4. International Transfer of Information
  5. Cookies and Similar Technologies
  6. How to Access & Control Your Personal Data

1. Information We Collect

When You use our Portal, App and Visit our Websites

A user has to Signup via email, Facebook or Google to CyberLiver platform to use the app or portal. Users signing up CyberLiver platform through our partner programs, apps and websites belong to CyberLiver Platform. You are free to explore the Websites without providing any Personal Information about yourself. When you visit the App store, Play Store and Websites and register for using the Services, we request that you provide Personal Information about yourself, and we collect Navigational Information.

When You Use our Mobile Application

We use mobile analytics software to allow us to better understand the functionality of our Mobile Apps on your mobile device. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. In addition to information we collect on our Websites, when you use our Mobile Apps we may also collect your city location, device model and version, device identifier (or “UDID”), OS version, and your CyberLiver account credentials.

We send push notifications from time to time in the app as motivational messages, to update you about your progress, events or promotions. If you no longer wish to receive such communications, you may turn them off at the device level.

We may link information we store within the analytics software to Personal Information you submit within the Mobile App. We do this to improve services we offer you and improve our marketing, analytics and site functionality.

"Personal Information"

This refers to any information that you voluntarily submit to us and that identifies you personally, including contact information, such as your name, e-mail address, date of birth, gender, location, Height, Weight, Weekly drinking average, and other information about yourself. Personal Information can also include information about any transactions, both free and paid, that you enter on the app, and information about you that is available on the internet, such as from Facebook, Google where you’ll use it for signing in to the app/portal.

Personal Information also includes your drinking data, sleep activity, drink location and time stamp of the activities in the app. Your payment information is stored in Google Play account, PayPal and iTunes account who are data processors and is secure. We don’t store any of your payment information in our databases and all the payments are carried out through secure 3rd party payment portal and are covered under their terms and privacy policies.

Log Files

We may also collect information that your browser or App sends whenever you visit our Service ("Log Data"). This Log Data may include information such as your computer's Internet Protocol ("IP") address, browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, mobile UDID, geo-localisation data, and other statistics. In order to process purchases made through the Websites we may pass this information to the third-party service provider, PayPal. In addition, we may use third party services such as Google Analytics, Appsflyer and Flurry that collect, monitor and analyse this type of information in order to increase our Service's functionality. These third-party service providers have their own privacy policies addressing how they use such information.

Information we collect from third parties

We don’t collect any Personal Information about you from third party sources including partners with which we offer co-branded services or engage in joint marketing activities, and publicly available sources such as social media websites.

Information About Children

The app and websites are not intended for or targeted at children under 16, and we do not knowingly or intentionally collect information about children under 16. If you believe that we have collected information about a child under 16, please contact us at privacy@CyberLiver.com, so that we may delete the information.

Google, as a third-party vendor, uses cookies to serve ads on our Service. Google's use of the DoubleClick cookie enables it and its partners to serve ads to our users based on their visit to our Service or other web sites on the Internet. You may opt out of the use of the Double Click Cookie for interest-based advertising by visiting the Google Ads Settings web page. Google uses remarketing services to advertise on third party web sites to you after you visited our Service. We, and our third-party vendors, use cookies to inform, optimize and serve ads based on your past visits to our Service. Google AdWords remarketing service is provided by Google Inc. You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: https://www.google.com/settings/ads Google also recommends installing the Google Analytics Opt-out Browser Add-on - https://tools.google.com/dlpage/gaoptout - for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: http://www.google.com/intl/en/policies/privacy/ We support Do Not Track ("DNT"). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

2. How We Use Information We Collect

Compliance with Our Privacy Policy

We use the information we collect only in compliance with this Privacy Policy. Users who subscribe to our app and platform services are obligated through our agreements with them to comply with this Privacy Policy.

We Never Sell Personal Information

We will never sell your Personal Information to any third party. 

Use of Personal Information

In addition to the uses identified elsewhere in this Privacy Policy, we may use your Personal Information to:

  • improve your browsing experience by personalizing the app and websites and to improve the Service;
  • send information or CyberLiver content to you which we think may be of interest to you by push notification, email, or other means and send you marketing communications relating to our business;
  • promote use of our services to you and share promotional and information content with you in accordance with your communication preferences;
  • we don’t share any of your personal information with third parties We might send information to you regarding changes to our Terms of Service, Privacy Policy (including the Cookie Policy), or other legal agreements to meet legal requirements.

We do not transfer your Personal Information to any third party.

We use the information collected through our App and website Premium Subscription Service by our users for the following purposes:

  • to provide the Premium Subscription Service (which may include the detection, prevention and resolution of security and technical issues);
  • to respond to user support requests; and
  • otherwise to fulfill the obligations under the CyberLiver Terms of Service. 

Legal basis for processing Personal Information (EEA visitors only)

If you are a visitor/user located in the European Economic Area ("EEA"), CyberLiver Limited is the data controller of your personal information. CyberLiver's Data Protection Officer can be contacted at privacy@CyberLiver.com

Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it. However, we will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information from you.

If we ask you to provide personal information to comply with a legal requirement, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information). Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.

User Testimonials and Comments

We post user testimonials and comments on our App pages, Play Store, App Store, Social medial promotions, Websites, and portal which may contain Personal Information. We obtain each user's consent via email prior to posting the user's name and testimonial.

Security of your Personal Information

We use a variety of security technologies and procedures to help protect your Personal Information from unauthorized access, use or disclosure. We secure the Personal Information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. All Personal Information is protected using appropriate physical, technical and organizational measures.

Social Media Features

Our Websites include Social Media Features, such as the Facebook/ Google Login, Facebook Like button and Widgets, such as the Share This button or interactive mini-programs that run in our app and portal. These features may collect your IP address, which page you are visiting on our sites, and may set a cookie to enable the feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our app and websites. This Privacy Policy does not apply to these features. Your interactions with these features are governed by the privacy policy and other policies of the companies providing them.

External Websites

Our app, portal and websites provide links to other websites. We do not control, and are not responsible for, the content or practices of these other websites. Our provision of such links does not constitute our endorsement of these other websites, their content, their owners, or their practices. This Privacy Policy does not apply to these other websites, which are subject to any privacy and other policies they may have.

Public Forums

We offer publicly accessible message boards, blogs, and community forums. Please keep in mind that if you directly disclose any information through our public message boards, blogs, or forums, this information may be collected and used by others. We will correct or delete any information you have posted on the Websites if you so request, as described in "Opting Out and Unsubscribing" below.

Retention of Personal Information

How long we keep information we collect about you depends on the type of information. as described in further detail below. After such time, we will either delete or anonymize your information or, if this is not possible, then we will securely store your information and isolate it from any further use until deletion is possible.

We retain Personal Information that you provide to us where we have an ongoing legitimate product/service/portal need to do so (for example, as long as is required in order to enable you to login to the app or portal or to access our other services, or as needed to comply with our legal obligations, resolve disputes and enforce our agreements).

When we have no ongoing product/service/portal need to process your Personal Information, we securely delete the information or anonymise it or, if this is not possible, then we will securely store your Personal Information and isolate it from any further processing until deletion is possible. We will delete this information from the servers at an earlier date if you so request, as described in "To Unsubscribe from Our Communications" below.

If you provide information to our partners as part of their use of the app or portal or services, our partners decide how long to retain the personal information they collect from you. If an user requests to terminates the use of the app or portal or services, then we will provide user with access to all information stored in our database on request, including any Personal Information, for export according to our agreement with you. After termination, we may, unless legally prohibited, delete all user information, including your Personal Information, from our databases.

If you have elected to receive marketing communications from us, we retain information about your marketing preferences until the end of that calendar year from the date you last expressed interest in our app, portal, content, products, or services, such as when you last opened the app, email from us or ceased using your CyberLiver account. We retain information derived from cookies and other tracking technologies for a reasonable period from the date such information was created.

3. How we Share Information we Collect

CyberLiver Partners & Research

We may use your Personal Information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. We will only send you marketing information by email whilst you are opted in to our marketing database.

We may share data with trusted partners to contact you based on your request to receive such communications, help us perform statistical analysis, or provide user support. Such third parties are prohibited from using your Personal Information except for these purposes, and they are required to maintain the confidentiality of your information.

We work with experts with in our organisation and trusted partners who might use the data collected from you to do analysis, research, and release the results in public domain and we ensure you that whenever the research results are published the user identity is anonymised and are not shared with any third party. We might use the collected personal data for research purposes based on the consent received during the sign up via website or app and may avoid restrictions on secondary processing and on processing sensitive categories of data (Article 6(4); Recital 50). We have implemented appropriate safeguards and may override a data subject’s right to object to processing and to seek the erasure of personal data (Article 89) in unavoidable circumstances.

We may contact you to get consent if you’re willing to be a part of future research and sign a separate privacy and research agreement at that time. As of now the terms and privacy that was available at the beginning of 2018 is in use and we are not making any changes to it in terms of how we collect and use your data until December 31, 2018.

Corporate Events

If we (or our assets) are acquired by another company, whether by merger, acquisition, bankruptcy or otherwise, that company would receive all information gathered by CyberLiver on the app, portal, websites and other services. In this event, you will be notified via email and/or a prominent notice on our website, of any change in ownership, uses of your Personal Information, and choices you may have regarding your Personal Information.

Compelled Disclosure

We reserve the right to use or disclose your Personal Information if required by law or if we reasonably believe that use or disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or comply with a law, court order, or legal process.

4. International Transfer of Information

International Transfers within CyberLiver’s Entities

To facilitate our global operations, we transfer information to India or United States and allow access to that information from countries in which the CyberLiver affiliated entities have operations for the purposes described in this policy.

This Privacy Policy shall apply even if we transfer Personal Information to other countries. We have taken appropriate safeguards to require that your Personal Information will remain protected. When we share information about you within and among CyberLiver’s affiliated entities, we make use of standard contractual data protection clauses, which have been approved by the European Commission.

International transfers to third parties

Some of the third parties described in this privacy policy, which provide services to us under contract, are based in other countries that may not have equivalent privacy and data protection laws to the country in which you reside. When we share information of users in the European Economic Area or Switzerland, we make use of the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks, European Commission-approved standard contractual data protection clauses, binding corporate rules for transfers to data processors, or other appropriate legal mechanisms to safeguard the transfer.

5. Cookies and Similar Technologies


CyberLiver and its partners use cookies or similar technologies (such as web beacons) to analyse trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base.

Single Sign-On

You can log in to our app or portal using a Single Sign-on (SSO) service using your email, Facebook or Google logins. This service will authenticate your identity and provide you the option to share certain personal information with us such as your name and email address to pre-populate our sign-up form.


We don’t partner with any third party to advertise in the app or portal or website based on your personal preferences and data. We don’t share or sell any personal information to any third party with respect to advertising or marketing.

Third Party Tracking Technologies

We use Google analytics to track the user behaviour on the app, portal and websites and tracking utilities is not covered by our Privacy Policy or Cookie Policy.

6. How to Access & Control Your Personal Data

Reviewing, Correcting and Removing Your Personal Information

You have the following data protection rights:

  • You can request access, correction, updates or deletion of your personal information.
  • You can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information.
  • If we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
  • You have the right to complain to a data protection authority about our collection and use of your personal information. Contact details for data protection authorities in the EEA, Switzerland and certain non-European countries (including the US and Canada) are available here.)

To exercise any of these rights, please contact us at privacy@CyberLiver.com. We will respond to your request to change, correct, or delete your information within a reasonable timeframe and notify you of the action we have taken.

To Unsubscribe From Our Communications

You may unsubscribe from our communications by clicking on the "unsubscribe" link located on the bottom of our e-mails, updating your communication preferences, or by sending us email us at privacy@cyberliver.com. Users cannot opt out of receiving transactional emails related to their account with us or emails & notification about the Premium Subscription.

Visit us @

Write to us @
CyberLiver Limited,
First Floor, Burnells,
5 Garland Road,

Email us @ privacy@cyberliver.com

To access the Previous Privacy Policy applicable for users with the app branded as Dry January and Beyond, click here