Dry Days Privacy Policy - Version 2.0
Last updated date: 28 Jul 2025
๐ฏ Your Data Protection Rights
โ๏ธ Your Rights Under GDPR and UK Data Protection Law
As a data subject, you have the following rights regarding your personal data:
๐ Right of Access (Article 15)
You can request a copy of all personal data we hold about you.
- ๐ฑ In-App Access: View and export your data directly from the DryDays app settings menu
- ๐ง Email Request: Contact [email protected] for a comprehensive data report
- โฑ๏ธ Response Time: Within 30 days (may extend to 60 days for complex requests)
- ๐ฐ Cost: Free for the first request per year
โ๏ธ Right to Rectification (Article 16)
Correct inaccurate or incomplete personal data.
- ๐ฑ Most data can be updated directly in the app
- ๐ง Email us for data you cannot change yourself
- โฑ๏ธ Updates processed within 72 hours
๐๏ธ Right to Erasure / "Right to be Forgotten" (Article 17)
Request deletion of your personal data when:
- ๐ซ Data is no longer necessary for the original purpose
- โ You withdraw consent and there's no other legal basis
- ๐ฑ In-App Deletion: Delete account and data from app settings
- ๐ง Email Request: Contact [email protected]
- โฑ๏ธ Processing Time: Immediate for app deletion, 30 days for complete data erasure
- ๐ Note: Some data may be retained for legal compliance (e.g., medical device safety reporting)
โธ๏ธ Right to Restriction of Processing (Article 18)
Limit how we process your data when:
- ๐ You contest the accuracy of the data
- โ๏ธ Processing is unlawful but you don't want erasure
- ๐ก๏ธ You need the data for legal claims
- โฑ๏ธ During verification of legitimate grounds for processing
DryDays Privacy Policy - Version 2.0
๐ DryDays Privacy Policy ๐ก๏ธ
๐
Last Updated: July 28, 2025 | Version 2.0
๐๏ธ Who We Are and Our Commitment to Privacy
๐ข Data Controller and Service Provider
๐ก๏ธ At DryDays, we are committed to protecting your privacy and ensuring transparent handling of your personal data. This Privacy Policy explains how we collect, use, share, and protect your information when you use the DryDays app powered by AlcoChangeยฎ technology.
๐ก DryDays is a comprehensive goal-setting and behavior change app that helps users achieve various wellness objectives using evidence-based Digital Behavior Change Techniques (DBCTs). As a Class I Medical Device, DryDays supports general wellness goals while incorporating UKCA Class IIa AlcoChangeยฎ technology - a prescription-only digital therapeutic for alcohol-related liver disease with clinically proven efficacy (57% abstinence rates, 28% reduction in hospital re-admissions).
โ ๏ธ Important Notice for Children
DryDays is not intended for individuals under 18 years of age. We do not knowingly collect personal information from children under 18. If you believe we have collected information about a child under 18, please contact us immediately at [email protected].
๐ Information We Collect
๐ Types of Data We Collect
๐น Account Information
- ๐ง Email address
- ๐ Date of birth (to verify age 18+)
- ๐ค Name (first and last)
- ๐ Encrypted password
- ๐ Country/region
- ๐ฑ Profile photo (optional)
๐น Health and Wellness Data
- ๐ฏ Goal Tracking: Various wellness objectives (fitness, nutrition, habits, financial, etc.)
- ๐บ Alcohol Moderation: Consumption tracking, sobriety milestones (when applicable)
- ๐ช Fitness Data: Exercise routines, activity levels, workout progress
- ๐ Nutrition Tracking: Food intake, dietary goals, meal planning
- ๐ฐ Financial Goals: Spending patterns, savings targets, budget tracking
- ๐
Habit Formation: Daily routines, streak tracking, behavior patterns
- โ๏ธ Biometric Data: Weight, height, body measurements (optional)
- ๐ด Lifestyle Factors: Sleep patterns, stress levels, mood tracking
- ๐ฏ Personal Goals: Custom objectives, milestones, achievement data
- ๐ญ Progress Notes: Personal reflections, journal entries, insights
- ๐ Achievement Data: Badges, rewards, milestone celebrations
๐น Technical Data
- ๐ฑ Device type, model, and operating system
- ๐ IP address and general location
- ๐ App usage analytics and crash reports
- ๐ข Unique device identifier (UDID)
- ๐ Battery level and performance data
- ๐ก Network connection type
๐น Location Data (Optional)
- ๐ Precise location (only with explicit consent)
- ๐บ๏ธ General location (city/region level)
- ๐ Location-based triggers and insights
โ๏ธ Legal Basis for Processing Your Data
๐ How We Justify Processing Your Data
Purpose
Legal Basis
Description
๐ Account Management
Contract Performance
Necessary to provide app services
๐ฏ Goal Tracking
Explicit Consent
You actively choose to set and track goals
๐บ Alcohol Data
Explicit Consent
Special category health data requiring consent
๐ฑ App Improvement
Legitimate Interest
Enhancing user experience and fixing bugs
๐ง Marketing
Consent
Only with your explicit permission
๐ Analytics
Legitimate Interest
Understanding usage patterns (anonymized)
โ๏ธ Legal Compliance
Legal Obligation
Required by applicable laws
๐ฏ How We Use Your Information
๐ง Core App Functionality:
- ๐ฏ Providing personalized goal-setting and tracking across multiple life areas
- ๐ Generating progress insights and behavior change recommendations
- ๐ Tracking achievements, milestones, and habit formation
- ๐ Creating detailed analytics and trend reports
- ๐ Sending motivational notifications, reminders, and behavioral interventions
- ๐ฌ Enabling community features, peer support, and coaching
- ๐ง Delivering evidence-based Digital Behavior Change Techniques (DBCTs)
- ๐จ Personalizing user experience based on goal types and preferences
๐ Service Improvement:
- ๐ Analyzing goal completion patterns to enhance success rates
- ๐ Identifying and fixing technical issues across different goal categories
- โก Optimizing app performance for various tracking features
- ๐จ Developing new goal types and behavior change interventions
- ๐ก๏ธ Improving security and fraud prevention for user data
- ๐ฌ Researching behavior change effectiveness (anonymized data)
๐บ Advertising (Free Version):
- ๐ฏ Displaying relevant wellness, lifestyle, and goal-achievement advertisements
- ๐ Measuring ad effectiveness using anonymized behavioral data
- ๐ซ Respecting opt-out preferences for personalized advertising
- ๐ Providing completely ad-free experience for premium subscribers
๐ค How We Share Your Information
๐ก๏ธ WE NEVER SELL YOUR PERSONAL DATA
๐ฅ We may share your information with:
๐ง Service Providers
- โ๏ธ Cloud hosting and storage providers
- ๐ Analytics and performance monitoring services
- ๐ณ Payment processors (for premium subscriptions)
- ๐ง Email and notification services
- ๐ก๏ธ Security and fraud prevention services
๐ Research Partners (Anonymized Data Only)
- ๐ Academic institutions studying addiction recovery
- ๐ฅ Healthcare organizations (with IRB approval)
- ๐ Public health research initiatives
- ๐ฌ Clinical trial organizations (separate consent required)
โ๏ธ Legal Requirements
- ๐๏ธ Government authorities when legally required
- ๐ฎ Law enforcement for valid legal requests
- โ๏ธ Courts for compliance with legal proceedings
- ๐ก๏ธ Protection of rights, property, or safety
๐ International Data Transfers
๐ Cross-Border Data Protection
DryDays operates globally and may transfer your data to countries outside your residence. We ensure adequate protection through:
- ๐ช๐บ EU Adequacy Decisions for transfers to approved countries
- ๐ Standard Contractual Clauses (SCCs) approved by EU Commission
- ๐ข Binding Corporate Rules for intra-group transfers
- ๐ก๏ธ Additional safeguards including encryption and access controls
- โ๏ธ Legal compliance with destination country privacy laws
Primary Data Processing Locations:
- ๐ฌ๐ง United Kingdom (Primary)
- ๐ช๐บ European Union (GDPR compliant)
- ๐บ๐ธ United States (with adequate safeguards)
- ๐จ๐ฆ Canada (with adequate safeguards)
๐ Data Retention
โฐ How Long We Keep Your Data
Data Type
Retention Period
Rationale
๐ Account Information
Until account deletion + 30 days
Account management and legal compliance
๐ฏ Goal & Wellness Data
Until deletion request + 90 days
Continuity of behavior change and user insights
๐ Analytics Data
26 months (anonymized)
App improvement and trend analysis
๐ณ Payment Data
7 years (encrypted)
Tax and regulatory compliance
๐ก๏ธ Security Logs
2 years
Security monitoring and fraud prevention
๐ง Marketing Consent
Until withdrawn + 1 year
Consent record keeping
๐๏ธ Data Deletion: When retention periods expire, we securely delete or anonymize your data using industry-standard methods.
๐ Data Security
๐ก๏ธ We protect your data using multiple security layers:
๐ Technical Safeguards
- ๐ Encryption: AES-256 encryption for data at rest and in transit
- ๐ Access Controls: Multi-factor authentication and role-based access
- ๐ Monitoring: 24/7 security monitoring and threat detection
- ๐ง Firewalls: Advanced network security and intrusion prevention
- ๐ Backups: Encrypted, geographically distributed backups
๐ฅ Organizational Safeguards
- ๐ Training: Regular security awareness training for all staff
- ๐ Policies: Comprehensive data protection and security policies
- ๐ Audits: Regular security audits and penetration testing
- ๐ Incident Response: 24-hour breach response procedures
- โ
Compliance: ISO 27001 and SOC 2 Type II certified
๐ฏ Your Privacy Rights
โ๏ธ Your Legal Rights Under GDPR and Other Privacy Laws
๐ Right to Access
Request a copy of all personal data we hold about you, including data sources and processing purposes.
โ๏ธ Right to Rectification
Correct inaccurate or incomplete personal data. Most data can be updated directly in the app.
๐๏ธ Right to Erasure ("Right to be Forgotten")
Request deletion of your personal data when it's no longer necessary or you withdraw consent.
โธ๏ธ Right to Restriction
Limit how we process your data in specific circumstances, such as while verifying accuracy.
๐ค Right to Data Portability
Receive your data in a structured, machine-readable format or transfer it to another service.
๐ซ Right to Object
Object to processing based on legitimate interests, including direct marketing.
๐ Right to Withdraw Consent
Withdraw consent for any processing activities that require your consent.
๐ฅ Right to Human Review
Request human review of any automated decision-making that significantly affects you.
โฑ๏ธ Response Timeframes
- ๐ช๐บ GDPR: 30 days (extendable to 60 days for complex requests)
- ๐บ๐ธ CCPA: 45 days (extendable to 90 days)
- ๐จ๐ฆ PIPEDA: 30 days
- ๐ฌ๐ง UK GDPR: 30 days (extendable to 60 days)
๐ช Cookies and Tracking Technologies
๐ช We use limited tracking technologies:
๐ฑ In-App Analytics
- ๐ Usage analytics to improve app functionality
- ๐ Crash reporting for bug fixes
- โก Performance monitoring for optimization
- ๐ฏ Feature usage tracking for development priorities
๐บ Advertising (Free Version Only)
- ๐ฏ Personalized ad targeting (opt-out available)
- ๐ Ad performance measurement
- ๐ซ No third-party advertising cookies in premium version
๐ง Managing Tracking Preferences
- โ๏ธ Access tracking settings in the app
- ๐ฑ Use device-level privacy controls
- ๐ซ Opt out of personalized advertising
- ๐ Upgrade to premium for ad-free experience
๐ Regional Privacy Information
๐บ๏ธ Specific Rights by Region
๐ช๐บ European Union (GDPR)
- ๐๏ธ Contact your local Data Protection Authority
- โ๏ธ Right to lodge complaints with supervisory authorities
- ๐ Enhanced transparency and consent requirements
- ๐ฐ Financial penalties for non-compliance
๐บ๐ธ United States
- ๐ด California (CCPA/CPRA): Right to know, delete, opt-out of sale
- ๐๏ธ Virginia (VCDPA): Similar rights to GDPR
- ๐๏ธ Colorado (CPA): Consumer privacy rights
- ๐ Connecticut (CTDPA): Data protection rights
๐จ๐ฆ Canada (PIPEDA)
- ๐ง Right to complain to Privacy Commissioner
- ๐ Right to access and correct personal information
- โ๏ธ Consent requirements for collection and use
๐ฆ๐บ Australia (Privacy Act)
- ๐๏ธ Complaints to Office of the Australian Information Commissioner
- ๐ Australian Privacy Principles compliance
- ๐ Right to access and correct personal information
๐จ Data Breach Notification
๐จ Our Breach Response Commitment
In the unlikely event of a data breach affecting your personal information:
- ๐ง Within 72 hours: We'll notify relevant supervisory authorities
- ๐ฑ Without undue delay: We'll inform affected users via app notification and email
- ๐ Full transparency: Details about what data was affected and our response actions
- ๐ก๏ธ Immediate action: Steps to secure systems and prevent further unauthorized access
- ๐ฌ Support: Dedicated support team to address your concerns
๐ถ Age Verification and Child Protection
๐ Strict Age Requirements:
- ๐
Age verification required during registration
- ๐ซ Automatic rejection of users under 18
- ๐ก๏ธ Additional protections for users 18-21 in some jurisdictions
- ๐ฅ Parental notification systems where legally required
- ๐ Regular audits to ensure compliance
๐ Privacy Policy Updates
๐ How we handle policy changes:
- ๐
30-day notice for material changes via email and in-app notification
- ๐ฑ Version control with clear change logs
- โฐ Historical versions available upon request
- โ
Re-consent required for significant changes affecting your rights
- ๐ Multiple channels for important updates (email, SMS, push notifications)
๐ Contact Us
๐ฌ Privacy and Data Protection Contacts
๐ Privacy Team:
๐ง Email: [email protected]
โฐ Privacy inquiries responded to within 24 hours
๐ฌ General Support:
๐ง Email: [email protected]
โฐ Hours: Monday-Friday, 9 AM - 6 PM GMT
๐ Website: drydays.me/privacy
๐ Summary of Key Privacy Points
- ๐ก๏ธ Your data is never sold - we're committed to your privacy
- ๐ Bank-level security with AES-256 encryption
- โ๏ธ Full compliance with GDPR, CCPA, and other privacy laws
- ๐ฏ Transparent processing - you always know how your data is used
- ๐ซ Easy opt-out from any data processing activities
- ๐ค Data portability - take your goal data with you anytime
- ๐ฌ Responsive support - we answer privacy questions within 24 hours
- ๐ Regular audits - third-party security and privacy assessments
- ๐ฏ Multi-goal support - comprehensive behavior change tracking
- ๐ฌ Evidence-based - built on validated behavior change research
ZANEC Inc. operates DryDays as the service provider, while CyberLiver Limited (Company Registration: 08052630) acts as the data controller for personal data processing under GDPR and other applicable privacy laws.
CyberLiver Limited
๐ First Floor, Burnells, 5 Garland Road
Stanmore, Middlesex, HA7 1NR, United Kingdom
Data Protection Officer: [email protected]
๐ DryDays Privacy Policy ๐ก๏ธ
๐๏ธ Who We Are and Our Commitment to Privacy
๐ข Data Controller and Service Provider
๐ก๏ธ At DryDays, we are committed to protecting your privacy and ensuring transparent handling of your personal data. This Privacy Policy explains how we collect, use, share, and protect your information when you use the DryDays app powered by AlcoChangeยฎ technology.
๐ก DryDays is a comprehensive goal-setting and behavior change app that helps users achieve various wellness objectives using evidence-based Digital Behavior Change Techniques (DBCTs). As a Class I Medical Device, DryDays supports general wellness goals while incorporating UKCA Class IIa AlcoChangeยฎ technology - a prescription-only digital therapeutic for alcohol-related liver disease with clinically proven efficacy (57% abstinence rates, 28% reduction in hospital re-admissions).
โ ๏ธ Important Notice for Children
DryDays is not intended for individuals under 18 years of age. We do not knowingly collect personal information from children under 18. If you believe we have collected information about a child under 18, please contact us immediately at [email protected].
๐ Information We Collect
๐ Types of Data We Collect
๐น Account Information
- ๐ง Email address
- ๐ Date of birth (to verify age 18+)
- ๐ค Name (first and last)
- ๐ Encrypted password
- ๐ Country/region
- ๐ฑ Profile photo (optional)
๐น Health and Wellness Data
- ๐ฏ Goal Tracking: Various wellness objectives (fitness, nutrition, habits, financial, etc.)
- ๐บ Alcohol Moderation: Consumption tracking, sobriety milestones (when applicable)
- ๐ช Fitness Data: Exercise routines, activity levels, workout progress
- ๐ Nutrition Tracking: Food intake, dietary goals, meal planning
- ๐ฐ Financial Goals: Spending patterns, savings targets, budget tracking
- ๐ Habit Formation: Daily routines, streak tracking, behavior patterns
- โ๏ธ Biometric Data: Weight, height, body measurements (optional)
- ๐ด Lifestyle Factors: Sleep patterns, stress levels, mood tracking
- ๐ฏ Personal Goals: Custom objectives, milestones, achievement data
- ๐ญ Progress Notes: Personal reflections, journal entries, insights
- ๐ Achievement Data: Badges, rewards, milestone celebrations
๐น Technical Data
- ๐ฑ Device type, model, and operating system
- ๐ IP address and general location
- ๐ App usage analytics and crash reports
- ๐ข Unique device identifier (UDID)
- ๐ Battery level and performance data
- ๐ก Network connection type
๐น Location Data (Optional)
- ๐ Precise location (only with explicit consent)
- ๐บ๏ธ General location (city/region level)
- ๐ Location-based triggers and insights
โ๏ธ Legal Basis for Processing Your Data
๐ How We Justify Processing Your Data
| Purpose | Legal Basis | Description |
|---|---|---|
| ๐ Account Management | Contract Performance | Necessary to provide app services |
| ๐ฏ Goal Tracking | Explicit Consent | You actively choose to set and track goals |
| ๐บ Alcohol Data | Explicit Consent | Special category health data requiring consent |
| ๐ฑ App Improvement | Legitimate Interest | Enhancing user experience and fixing bugs |
| ๐ง Marketing | Consent | Only with your explicit permission |
| ๐ Analytics | Legitimate Interest | Understanding usage patterns (anonymized) |
| โ๏ธ Legal Compliance | Legal Obligation | Required by applicable laws |
๐ฏ How We Use Your Information
๐ง Core App Functionality:
- ๐ฏ Providing personalized goal-setting and tracking across multiple life areas
- ๐ Generating progress insights and behavior change recommendations
- ๐ Tracking achievements, milestones, and habit formation
- ๐ Creating detailed analytics and trend reports
- ๐ Sending motivational notifications, reminders, and behavioral interventions
- ๐ฌ Enabling community features, peer support, and coaching
- ๐ง Delivering evidence-based Digital Behavior Change Techniques (DBCTs)
- ๐จ Personalizing user experience based on goal types and preferences
๐ Service Improvement:
- ๐ Analyzing goal completion patterns to enhance success rates
- ๐ Identifying and fixing technical issues across different goal categories
- โก Optimizing app performance for various tracking features
- ๐จ Developing new goal types and behavior change interventions
- ๐ก๏ธ Improving security and fraud prevention for user data
- ๐ฌ Researching behavior change effectiveness (anonymized data)
๐บ Advertising (Free Version):
- ๐ฏ Displaying relevant wellness, lifestyle, and goal-achievement advertisements
- ๐ Measuring ad effectiveness using anonymized behavioral data
- ๐ซ Respecting opt-out preferences for personalized advertising
- ๐ Providing completely ad-free experience for premium subscribers
๐ค How We Share Your Information
๐ก๏ธ WE NEVER SELL YOUR PERSONAL DATA
๐ฅ We may share your information with:
๐ง Service Providers
- โ๏ธ Cloud hosting and storage providers
- ๐ Analytics and performance monitoring services
- ๐ณ Payment processors (for premium subscriptions)
- ๐ง Email and notification services
- ๐ก๏ธ Security and fraud prevention services
๐ Research Partners (Anonymized Data Only)
- ๐ Academic institutions studying addiction recovery
- ๐ฅ Healthcare organizations (with IRB approval)
- ๐ Public health research initiatives
- ๐ฌ Clinical trial organizations (separate consent required)
โ๏ธ Legal Requirements
- ๐๏ธ Government authorities when legally required
- ๐ฎ Law enforcement for valid legal requests
- โ๏ธ Courts for compliance with legal proceedings
- ๐ก๏ธ Protection of rights, property, or safety
๐ International Data Transfers
๐ Cross-Border Data Protection
DryDays operates globally and may transfer your data to countries outside your residence. We ensure adequate protection through:
- ๐ช๐บ EU Adequacy Decisions for transfers to approved countries
- ๐ Standard Contractual Clauses (SCCs) approved by EU Commission
- ๐ข Binding Corporate Rules for intra-group transfers
- ๐ก๏ธ Additional safeguards including encryption and access controls
- โ๏ธ Legal compliance with destination country privacy laws
Primary Data Processing Locations:
- ๐ฌ๐ง United Kingdom (Primary)
- ๐ช๐บ European Union (GDPR compliant)
- ๐บ๐ธ United States (with adequate safeguards)
- ๐จ๐ฆ Canada (with adequate safeguards)
๐ Data Retention
โฐ How Long We Keep Your Data
| Data Type | Retention Period | Rationale |
|---|---|---|
| ๐ Account Information | Until account deletion + 30 days | Account management and legal compliance |
| ๐ฏ Goal & Wellness Data | Until deletion request + 90 days | Continuity of behavior change and user insights |
| ๐ Analytics Data | 26 months (anonymized) | App improvement and trend analysis |
| ๐ณ Payment Data | 7 years (encrypted) | Tax and regulatory compliance |
| ๐ก๏ธ Security Logs | 2 years | Security monitoring and fraud prevention |
| ๐ง Marketing Consent | Until withdrawn + 1 year | Consent record keeping |
๐๏ธ Data Deletion: When retention periods expire, we securely delete or anonymize your data using industry-standard methods.
๐ Data Security
๐ก๏ธ We protect your data using multiple security layers:
๐ Technical Safeguards
- ๐ Encryption: AES-256 encryption for data at rest and in transit
- ๐ Access Controls: Multi-factor authentication and role-based access
- ๐ Monitoring: 24/7 security monitoring and threat detection
- ๐ง Firewalls: Advanced network security and intrusion prevention
- ๐ Backups: Encrypted, geographically distributed backups
๐ฅ Organizational Safeguards
- ๐ Training: Regular security awareness training for all staff
- ๐ Policies: Comprehensive data protection and security policies
- ๐ Audits: Regular security audits and penetration testing
- ๐ Incident Response: 24-hour breach response procedures
- โ Compliance: ISO 27001 and SOC 2 Type II certified
๐ฏ Your Privacy Rights
โ๏ธ Your Legal Rights Under GDPR and Other Privacy Laws
๐ Right to Access
Request a copy of all personal data we hold about you, including data sources and processing purposes.
โ๏ธ Right to Rectification
Correct inaccurate or incomplete personal data. Most data can be updated directly in the app.
๐๏ธ Right to Erasure ("Right to be Forgotten")
Request deletion of your personal data when it's no longer necessary or you withdraw consent.
โธ๏ธ Right to Restriction
Limit how we process your data in specific circumstances, such as while verifying accuracy.
๐ค Right to Data Portability
Receive your data in a structured, machine-readable format or transfer it to another service.
๐ซ Right to Object
Object to processing based on legitimate interests, including direct marketing.
๐ Right to Withdraw Consent
Withdraw consent for any processing activities that require your consent.
๐ฅ Right to Human Review
Request human review of any automated decision-making that significantly affects you.
โฑ๏ธ Response Timeframes
- ๐ช๐บ GDPR: 30 days (extendable to 60 days for complex requests)
- ๐บ๐ธ CCPA: 45 days (extendable to 90 days)
- ๐จ๐ฆ PIPEDA: 30 days
- ๐ฌ๐ง UK GDPR: 30 days (extendable to 60 days)
๐ช Cookies and Tracking Technologies
๐ช We use limited tracking technologies:
๐ฑ In-App Analytics
- ๐ Usage analytics to improve app functionality
- ๐ Crash reporting for bug fixes
- โก Performance monitoring for optimization
- ๐ฏ Feature usage tracking for development priorities
๐บ Advertising (Free Version Only)
- ๐ฏ Personalized ad targeting (opt-out available)
- ๐ Ad performance measurement
- ๐ซ No third-party advertising cookies in premium version
๐ง Managing Tracking Preferences
- โ๏ธ Access tracking settings in the app
- ๐ฑ Use device-level privacy controls
- ๐ซ Opt out of personalized advertising
- ๐ Upgrade to premium for ad-free experience
๐ Regional Privacy Information
๐บ๏ธ Specific Rights by Region
๐ช๐บ European Union (GDPR)
- ๐๏ธ Contact your local Data Protection Authority
- โ๏ธ Right to lodge complaints with supervisory authorities
- ๐ Enhanced transparency and consent requirements
- ๐ฐ Financial penalties for non-compliance
๐บ๐ธ United States
- ๐ด California (CCPA/CPRA): Right to know, delete, opt-out of sale
- ๐๏ธ Virginia (VCDPA): Similar rights to GDPR
- ๐๏ธ Colorado (CPA): Consumer privacy rights
- ๐ Connecticut (CTDPA): Data protection rights
๐จ๐ฆ Canada (PIPEDA)
- ๐ง Right to complain to Privacy Commissioner
- ๐ Right to access and correct personal information
- โ๏ธ Consent requirements for collection and use
๐ฆ๐บ Australia (Privacy Act)
- ๐๏ธ Complaints to Office of the Australian Information Commissioner
- ๐ Australian Privacy Principles compliance
- ๐ Right to access and correct personal information
๐จ Data Breach Notification
๐จ Our Breach Response Commitment
In the unlikely event of a data breach affecting your personal information:
- ๐ง Within 72 hours: We'll notify relevant supervisory authorities
- ๐ฑ Without undue delay: We'll inform affected users via app notification and email
- ๐ Full transparency: Details about what data was affected and our response actions
- ๐ก๏ธ Immediate action: Steps to secure systems and prevent further unauthorized access
- ๐ฌ Support: Dedicated support team to address your concerns
๐ถ Age Verification and Child Protection
๐ Strict Age Requirements:
- ๐ Age verification required during registration
- ๐ซ Automatic rejection of users under 18
- ๐ก๏ธ Additional protections for users 18-21 in some jurisdictions
- ๐ฅ Parental notification systems where legally required
- ๐ Regular audits to ensure compliance
๐ Privacy Policy Updates
๐ How we handle policy changes:
- ๐ 30-day notice for material changes via email and in-app notification
- ๐ฑ Version control with clear change logs
- โฐ Historical versions available upon request
- โ Re-consent required for significant changes affecting your rights
- ๐ Multiple channels for important updates (email, SMS, push notifications)
๐ Contact Us
๐ฌ Privacy and Data Protection Contacts
๐ Privacy Team:
๐ง Email: [email protected]
โฐ Privacy inquiries responded to within 24 hours
๐ฌ General Support:
๐ง Email: [email protected]
โฐ Hours: Monday-Friday, 9 AM - 6 PM GMT
๐ Website: drydays.me/privacy
๐ Summary of Key Privacy Points
- ๐ก๏ธ Your data is never sold - we're committed to your privacy
- ๐ Bank-level security with AES-256 encryption
- โ๏ธ Full compliance with GDPR, CCPA, and other privacy laws
- ๐ฏ Transparent processing - you always know how your data is used
- ๐ซ Easy opt-out from any data processing activities
- ๐ค Data portability - take your goal data with you anytime
- ๐ฌ Responsive support - we answer privacy questions within 24 hours
- ๐ Regular audits - third-party security and privacy assessments
- ๐ฏ Multi-goal support - comprehensive behavior change tracking
- ๐ฌ Evidence-based - built on validated behavior change research
CyberLiver Limited
๐ First Floor, Burnells, 5 Garland Road
Stanmore, Middlesex, HA7 1NR, United Kingdom
Data Protection Officer: [email protected]
This policy was last updated on the 28th of July 2025. We may update it at any time.
Please find the previous version of this with last updated date below
- Version 1.0
(31 Oct 2018)