Privacy Policy

Effective as of: 19 September 2025

TABLE OF CONTENTS

• 1. Personal Data Controller
• 2. Categories of Personal Data We Collect
• 3. Purposes for Which We Process Personal Data
• 4. Legal Bases for Processing (EEA/UK users)
• 5. With Whom We Share Personal Data
• 6. How to Exercise Your Privacy Rights
• 7. Age Limitation
• 8. International Data Transfers
• 9. Security
• 10. Changes to this Privacy Policy
• 11. U.S. States Privacy Notice (incl. California)
• 12. Data Retention
• 13. Contact Us

1. Personal Data Controller

The controller of your personal data is:

Individual Entrepreneur FOP Ruslan Fedotov, registered in Ukraine (ФОП), with registered address Vinnytsa region, Kryzhopil, Olimpiiska X/X.

Contact: support@achievrguru.com.

If you are located in the EEA/UK, we may designate an EU/UK representative if required by law. We will update this section with the representative's details when applicable.

2. Categories of Personal Data We Collect

We collect information in three ways: (a) data you provide; (b) data we receive from third parties (e.g., when you sign in with a provider); and (c) data collected automatically.

2.1. Data you provide to us

Account data: name, email, password hash, profile photo (optional).

Subscription & billing profile: plan, status, invoices, payment method metadata (we do not store full card numbers).

Content you add: goals, tasks, notes, habits, metrics, and other information you choose to input.

Support & communications: messages you send to us and your contact preferences.

Note on special categories: Achievr is not intended for processing special categories of personal data (e.g., health data within the meaning of GDPR). If you voluntarily input wellness or progress metrics (e.g., weight, hours, distance), you do so at your discretion, and we process them only to provide the Service features you use.

2.2. Data from third parties

Single sign‑on (SSO): if you choose to sign in via a provider (e.g., Google), we receive your basic profile identifiers (such as name, email, avatar URL) in line with that provider's permissions and your settings.

Payment processors: confirmation of payment status and limited billing identifiers (we do not receive full card details).

2.3. Data collected automatically (Website)

Device & log data: IP address, device type and OS, browser type and version, locale, time zone, referrer URL, pages viewed, feature usage, session duration, crash logs and diagnostics.

Cookies and similar technologies: web beacons, pixels, local storage, and cookie IDs used for authentication, security, preferences, analytics, and (if enabled) marketing. See our Cookie controls for choices.

3. Purposes for Which We Process Personal Data

We process your personal data for the following purposes:

3.1. To provide and operate the Service

Authenticate you; host and store your content; deliver core features (goals, tasks, habits, notes, metrics, dashboards); ensure availability and performance; fix bugs and errors.

Hosting and infrastructure are provided by Amazon Web Services (and/or comparable cloud providers).

3.2. Customer support and service communications

Respond to your requests and provide notices about the Service (e.g., security, billing, important updates).

We may use a ticketing/email tool to manage inquiries (e.g., Zendesk or an equivalent provider).

3.3. Service communications and account‑related emails

Transactional messages about your account, billing, feature changes, and important notices. You cannot opt out of strictly necessary communications.

3.4. Research, analytics, and product improvement

Understand usage, improve UX, plan features, and run A/B tests.

We may use analytics tools such as Google Analytics/Tag Manager, Amplitude, Hotjar (or similar) to measure interactions and diagnose issues.

3.5. Marketing (optional)

With your consent where required, we may send marketing emails about new features or offers. You can unsubscribe at any time via the link in those emails.

We may run ads on third‑party platforms and measure their effectiveness.

3.6. Personalization and ads (optional)

Where permitted by law and your consent choices, we and partners (e.g., Meta/Facebook, TikTok, Snapchat, Google) may use limited data (e.g., cookie IDs, page events) to tailor or measure advertising. You can manage preferences in our cookie banner and via platform tools (see U.S. States Privacy Notice below).

3.7. Payments and subscriptions

Enable purchases, process payments, manage renewals, and handle billing support via third‑party payment processors. We do not store full payment card details.

3.8. Security, fraud prevention, and enforcement

Protect accounts and the Service (including by using tools like Google reCAPTCHA), prevent abuse, and enforce our Terms.

3.9. Legal compliance

Comply with legal obligations and respond to lawful requests from competent authorities.

4. Legal Bases for Processing (EEA/UK users)

Where GDPR/UK GDPR applies, we process your data on the following legal bases:

• Contract: to provide the Service under our Terms (e.g., account, features, payments, support).
• Legitimate interests: to analyze and improve the Service; to secure the Service; to communicate service updates; to defend legal claims. We balance our interests against your rights. You may object (see Section 6).
• Consent: for optional cookies/analytics/marketing and, where required, for marketing emails and personalized advertising. You may withdraw consent at any time.
• Legal obligation: to comply with applicable law (e.g., tax, accounting, requests from authorities).

5. With Whom We Share Personal Data

We share personal data with:

• Service providers (processors): hosting (e.g., AWS), analytics (e.g., Google Analytics/Tag Manager, Amplitude, Hotjar), communications (e.g., email and ticketing tools), security (e.g., reCAPTCHA), and payments (payment processors). These providers act on our instructions.
• Advertising/measurement partners (if enabled): Meta/Facebook, Google, TikTok, Snapchat and similar platforms for audience measurement and ad personalization subject to your choices.
• Professional advisors & authorities: where necessary for compliance, enforcement, or legal claims.
• Business transfers: in connection with a merger, acquisition, or similar transaction, subject to appropriate safeguards.

We aim to maintain an up‑to‑date list of key subprocessors at https://achievrguru.com/legal/subprocessors (link may be updated).

6. How to Exercise Your Privacy Rights

You may have rights to access, correct, delete, restrict, object to certain processing, and port your data, as well as to withdraw consent (where processing is based on consent). To exercise rights, email support@achievrguru.com.

We will verify requests (e.g., by confirming control of your account/email or asking for limited usage details).

If we decline a request (e.g., due to legal requirements), you may have the right to appeal – instructions will be provided in our response.

EEA/UK users may lodge a complaint with a data protection authority; we encourage contacting us first.

7. Age Limitation

The Service is intended for individuals 18 years and older. We do not knowingly collect personal data from persons under 18. If you believe a minor has provided data to us, contact support@achievrguru.com and we will delete it.

8. International Data Transfers

We may transfer personal data outside your country (e.g., to the EU/EEA, UK, U.S.). Where required, we use appropriate safeguards such as Standard Contractual Clauses (and UK Addendum) and assess partners' data protection measures. If we rely on another legal mechanism (e.g., adequacy decision), we will note it in our records.

9. Security

We implement appropriate technical and organizational measures designed to protect personal data (e.g., encryption in transit, access controls, monitoring). No system is 100% secure; we cannot guarantee absolute security.

10. Changes to this Privacy Policy

We may update this Policy to reflect changes in features, providers, or legal requirements. We will update the Effective as of date and, where legally required, notify you. Continued use of the Service after an update means you accept the revised Policy.

We may publish a summary of significant changes at https://achievrguru.com/legal/changes (link may be updated).

11. U.S. States Privacy Notice (incl. California)

This section applies to residents of U.S. states with comprehensive privacy laws (e.g., CA, CO, CT, DE, IA, MT, NE, NH, NJ, OR, TX, UT, VA). Terms like "Personal Information" follow applicable state law.

11.1 Categories of Personal Information We Collect and Purposes

• Identifiers: name, email, cookie/online IDs, IP address. Purposes: provide the Service; security; communications; analytics; marketing/ads (if enabled).
• Commercial information: subscription status, purchase history. Purposes: billing, account management, analytics.
• Internet/electronic activity: Website interactions, pages viewed, referrers, device/browser data. Purposes: operate, secure, improve the Service; analytics; ads measurement (if enabled).
• Geolocation (approximate): country/region from IP. Purposes: localization, fraud prevention, analytics.
• Inferences: limited insights about feature usage (not used to infer protected characteristics). Purposes: product improvement.

We may process de‑identified data and will not attempt to re‑identify it except to test our de‑identification.

11.2 Disclosures and "Sales/Sharing"

In the past 12 months, we disclosed the categories above to service providers for business purposes (e.g., hosting, analytics, payments, communications).

We do not sell Personal Information for money. Some states treat certain advertising/analytics via cookies as a "sale" or "share." You may opt out of such activities via our cookie banner or by emailing support@achievrguru.com with the subject "Do Not Sell or Share My Personal Information".

11.3 Your State Privacy Rights

Depending on your state, you may have the right to know/access, delete, correct, opt out of "sales/sharing" and targeted advertising, portability, non‑discrimination, and appeal. To exercise rights, email support@achievrguru.com.

11.4 Authorized Agents (CA)

Authorized agents may submit requests with proof of authorization (e.g., power of attorney or signed permission) and subject verification of the consumer's identity.

11.5 California "Shine the Light"

California residents may request information about sharing for third parties' direct marketing by emailing support@achievrguru.com with subject "Request for California Privacy Information".

12. Data Retention

We retain personal data as long as necessary for the purposes described in this Policy, including providing the Service, complying with legal obligations, resolving disputes, and enforcing agreements. Typical examples:

• Account data: retained while your account is active and for a reasonable period afterward.
• Billing records: retained as required by tax/accounting laws.
• Support tickets: retained for audit and quality assurance for a reasonable period.
• Cookies: retained per cookie type (see cookie banner or browser settings).

Where feasible, we will anonymize or aggregate data instead of retaining it in identifiable form.

13. Contact Us

If you have questions about this Policy or your personal data, contact:

support@achievrguru.com

Controller: Individual Entrepreneur Ruslan Fedotov, Ukraine (ФОП)