PERSONAL DATA CONTROLLER

Irator Limited, a company registered under the laws of the Republic of Cyprus, having its registered office at Florinis 7, Greg Tower, 2nd Floor, 1065, Nicosia, Cyprus, will be the controller of your personal data.

CATEGORIES OF PERSONAL DATA WE COLLECT

We collect data you give us voluntarily (for example, email address). We also may receive data about you from third parties (for example, when you sign in via Facebook). We also collect data automatically (for example, your IP address).

Data you give us

Account-related data: We will ask you to provide identifiers, including name and email address, for account-related purposes.

Quiz-related data: Through our quiz, we will ask you to provide personal information that may include sensitive personal information/special category data (such as information concerning your health). The data we collect through our quiz may include: (i) Personal characteristics — date of birth, gender; (ii) Movement & physical safety — frequency of intentional exercise, average daily walking volume (step range), seat belt usage, phone usage while driving, motorcycle usage; (iii) Sleep & recovery — subjective sleep quality, average sleep duration, self-reported blood pressure status, self-reported resting heart rate category; (iv) Mental, social & life context — perceived stress level, overall life satisfaction, perceived social connection, relationship status, relationship quality; (v) Habits & substances — smoking status, alcohol consumption frequency, frequency of processed meat consumption; (vi) Body & metabolic — height, weight, self-reported history of blood sugar issues, self-reported history of cholesterol issues; (vii) Genetics, history & environment — family longevity (relatives living to age 90 or older), personal history of selected health conditions, family history of selected health conditions, type of country environment lived in over the last 10 years, expected future living environment.

Any sensitive personal data is processed in accordance with Article 9 GDPR and is used solely for providing you with the requested services (calculating your biological age, life expectancy etc.). Processing is based on your consent, which you may withdraw at any time with effect for the future. Please note that providing this information is voluntary. Without it, we cannot offer you personalized services.

Data provided by third parties

When you use sign in with Apple to register an account in the Service, we get personal data from your Apple ID account. This data may include, in particular, your name and verified email address. You may choose to share your real email address or an anonymous one that uses the private email relay service. Apple will show you their detailed privacy information on the sign in with Apple screen. Find more about sign with Apple here.

When you decide to log in using Facebook, we get personal data from your Facebook account. This includes your profile image, name, and Facebook ID. Unless you opt out on the Facebook Login screen, we will also collect other data, such as email address.

For more information, please refer to the Facebook Permissions Reference (describes the categories of information, which Facebook may share with third parties and the set of requirements) and to the Facebook Data policy. In addition, Facebook lets you control the choices you made when connecting your Facebook profile to the Website on their Apps and Websites page.

When you decide to log in using Google, we receive personal data from your Google Account: name, email address, profile picture associated with your Google Account. You can revoke access provided to us on Apps Permissions page. To know more about how Google processes your data, visit its Privacy Policy.

Data we collect automatically:

Data about how you found us: We collect data about your referring app or URL (that is, the app or place on the Web where you were when you tapped/clicked on our ad).

Device and Location data: We collect data from your device. Examples of such data include: language settings, IP address, time zone, type and model of a device, device settings, operating system, Internet service provider, mobile carrier, hardware ID, and Facebook ID.

Usage data: We record how you interact with our Service. For example, we log what pages you have viewed, the features and content you interact with, how often you use the Service, how long you are on the Service, your purchases.

Advertising IDs: We collect your Apple Identifier for Advertising ("IDFA"), Identifier for Vendor ("IDFV") or Google Advertising ID ("AAID") (depending on the operating system of your device) when you access our App or Website from a mobile device. You can typically reset these numbers through the settings of your device's operating system (but we do not control this).

Transaction data: When you make payments through the Service, you need to provide financial account data, such as your credit card number, to our third-party service providers. We do not collect or store full credit card number data, though we may receive credit card-related data, data about the transaction, including: date, time and amount of the transaction, the type of payment method used.

Cookies: A cookie is a small text file that is stored on a user's computer for record-keeping purposes. Cookies can be either session cookies or persistent cookies. A session cookie expires when you close your browser and is used to make it easier for you to navigate our Service. A persistent cookie remains on your hard drive for an extended period of time. We also use tracking pixels that set cookies to assist with delivering online advertising.

Cookies are used, in particular, to automatically recognize you the next time you visit our website. As a result, the information, which you have earlier entered in certain fields on the website may automatically appear the next time when you use our Service. Cookie data will be stored on your device and most of the times only for a limited time period.

FOR WHAT PURPOSES WE PROCESS YOUR PERSONAL DATA

We process your personal data:

To provide our Service: This includes enabling you to use the Service in a seamless manner and preventing or addressing Service errors or technical issues, as well provide you with personalized services.

Creating and maintaining your account: We will use your name to display it in your profile and personalize your Service experience. We will use your email address to create and manage your account, provide access to the Service, communicate with you, and respond to support requests.

Providing core features of the Service: We will use the data obtained through our quiz to provide you the core features of our Service, such as calculating your biological age, energy score, and longevity score, as well as identifying relevant focus areas.

Technical maintenance of the Service: To host personal data and enable our Service to operate and be distributed we use Amazon Web Services, which is a hosting and backend service provided by Amazon, and Digital Ocean, which is a hosting and backend service. We use Firebase Performance Monitoring and Firebase Crash Reporting, which are monitoring services provided by Google. To monitor infrastructure and the Service's performance, we use Crashlytics, which is a monitoring service provided by Google. To store data, we may also use Firestorage.

To customize your experience: We process your personal data, such as age, gender, to adjust the content of the Service and provide content tailored to your personal preferences. For example, we will use the information provided by you during the quiz to provide you with tailored advice on your longevity journey.

To provide you with customer support: We process your personal data to respond to your requests for technical support, Service information or to any other communication you initiate. For this purpose, we may send you, for example, notifications or emails about, the performance of our Service, security, payment transactions, notices regarding our Terms and Conditions of Use or this Privacy Policy.

To communicate with you regarding your use of our Service: We communicate with you, for example, by push notifications or by emails. These may include reminders or other information about the Service. As a result, you will, for example, receive a push notification that a new feature has been deployed in the Service. To opt out of receiving push notifications, you need to change the settings on your device. To opt-out of receiving emails, you should click unsubscribe link in the footer of each email.

The services that we use for these purposes may collect data concerning the date and time when the message was viewed by our Service's users, as well as when they interacted with it, such as by tapping/clicking on links included in the message.

To communicate with you we also use Firebase Cloud Messaging, which is message sending service provided by Google. Firebase Cloud Messaging allows us to send messages and notifications to users of our Service across platforms such as Android and iOS when you access our Service from a mobile device or across your internet browser when you access our Service from a laptop. We integrate Firebase Notifications with Firebase Analytics to create analytics-based audiences and track opening and conversion events. As a result, we can, for example, send reminders only to users who used the Service more frequently.

We use Apple Push Notification service ("APNs"), that is a notifications service provided by Apple. APNs allows us to send information to iOS devices.

To research and analyze your use of the Service: This helps us to better understand our business, analyze our operations, maintain, improve, innovate, plan, design, and develop the Service and our new products. We also use such data for statistical analysis purposes, to test and improve our offers. This enables us to better understand what categories of users use our Services. As a consequence, we often decide how to improve the Service based on the results obtained from this processing.

To perform research and analysis about how users interact with our Service we use Appsflyer. Appsflyer enables us to understand, in particular, how users find us (for example, who was the advertiser that delivered an ad to users, which led you to our Website). Appsflyer also provides us with different analytics tools that enable us to research and analyze your use of the Service. Appsflyer allows you to Opt Out of having data from my device sent to Appsflyer's servers for apps usage collection.

To perform our Website analysis, we also use Tableau, a company providing interactive data visualization products focused on business intelligence. We use Google Tag Manager to manage tags on the Website for conversion tracking and Website analytics. We also use Hotjar, a behavior analytics tool that analyses Service use, providing feedback through tools such as heatmaps, session recordings, and surveys.

We use Facebook Analytics, which is a service provided by Facebook that allows us to use different analytical tools. On Facebook Analytics we get, in particular, aggregated demographics and insights on how many people visit our Service, how often users make purchases, and other interactions.

To analyse how visitors use our Service and to measure effectiveness of some ads we use Google Analytics, a web analysis program of Google. In order to provide us with analytics, Google Analytics places cookies on your device. On Google Analytics we get, in particular, aggregated information on the data you enter on our Services and users' interactions within the Services. Google allows you to influence the collection and processing of information generated by the Google, in particular, by installing a browser plug-in.

To track and analyze behavior of our Service's users (in particular, how they react to changes of the Service structure, text or any other component), we use Firebase Remote Config. Firebase Remote Config is an A/B testing and configuration service provided by Google, which also enables us to tailor the content that our Service's users see (for example, it allows us to show different onboarding screens to different users).

Amplitude is an analytics service provided by Amplitude Inc. We use this tool to understand how customers use our Service. Amplitude collects various technical information, in particular, time zone, type of device (phone, tablet or laptop), unique identifiers (including advertising identifiers). Amplitude also allows us to track various interactions that occur in our Service. As a result, Amplitude helps us to decide what features we should focus on.

We also use Firebase Analytics, which is an analytics service provided by Google.

To send you marketing communications: We process your personal data for our marketing campaigns. As a result, you will receive information about our products, such as, for example, special offers or new features and products available on the Service. We may send you emails for marketing purposes. If you do not want to receive marketing emails from us, you can unsubscribe following instructions in the footer of the marketing emails.

To personalize our ads: We and our partners use your personal data to tailor ads and possibly even show them to you at the relevant time. For example, if you visited our Website or installed the App, you might see ads of our products in your Facebook's feed.

How to opt out or influence personalized advertising — iOS: On your iPhone or iPad, go to Settings > Privacy > Apple Advertising and deselect Personalized Ads. Android: To opt-out of ads on an Android device, go to Settings > Privacy > Ads and enable Opt out of Ads personalization. In addition, you can reset your advertising identifier in the same section. macOS: On your MacBook, you can disable personalized ads: go to System Preferences > Security & Privacy > Privacy, select Apple Advertising, and deselect Personalized Ads. Windows: On your laptop running Windows 10, you shall select Start > Settings > Privacy and then turn off the setting for Let apps use advertising ID to make ads more interesting to you based on your app activity.

In addition, you may get useful information and opt out of some interest-based advertising, by visiting the following links: Network Advertising Initiative – http://optout.networkadvertising.org/ | Digital Advertising Alliance – http://optout.aboutads.info/ | Digital Advertising Alliance (Canada) – http://youradchoices.ca/choices | Digital Advertising Alliance (EU) – http://www.youronlinechoices.com/ | DAA AppChoices page – http://www.aboutads.info/appchoices

It is also may be possible to stop your browser from accepting cookies altogether by changing your browser's cookie settings. You can usually find these settings in the "options" or "preferences" menu of your browser.

Google allows its users to opt out of Google's personalized ads and to prevent their data from being used by Google Analytics.

We use Facebook pixel on the Service. Facebook pixel is a code placed on the Service collecting data that helps us track conversions from Facebook ads, build targeted audience and remarket to people who have taken some action on the Service (for example, made a purchase).

We also use Facebook Audience Network SDK, Facebook Advanced Matching, Facebook Ads Manager, and Facebook Custom Audience. These tools allow us to deliver personalized and relevant advertisements, measure and optimize ad performance, and understand user preferences. Facebook Audience Network SDK helps us show ads tailored to your interests based on your online activities while also providing advertisers with aggregated insights. Facebook Advanced Matching enables us to securely match certain data, such as email addresses, with Facebook to track conversions and optimize ads for users who have previously engaged with our Service. Additionally, through Facebook Ads Manager and Facebook Custom Audience, we can create targeted lists of users based on specific criteria, such as device identifiers or interactions within our service, to ensure that our advertisements reach relevant audiences on Facebook, Instagram, and other Facebook products. As a result, you may see more of our ads while using these platforms. You have control over how your data is used, and you can manage your ad preferences via Facebook's settings.

Google Ads is an ad delivery service provided by Google that can deliver ads to users. In particular, Google allows us to tailor the ads in a way that they will appear, for example, only to users that have conducted certain actions with our Service (for example, show our ads to users who have made a purchase). Some other examples of events that may be used for tailoring ads include, in particular, visiting our Website.

Google AdSense is an ad delivery service provided by Google. Google AdSense enables publishers to monetize content online. AdSense selects ads based on the content of the website and the website's audience.

To allow you to share our content on your social media: Our Service may integrate the Facebook Sharing SDK to enable users to share content directly from our platform to their Facebook accounts. When you choose to share content using the Facebook Sharing SDK, the tool may collect certain data, such as your Facebook user ID, shared content details, and interaction metrics, in accordance with Facebook's Data Policy. We do not store or process your Facebook login credentials. Your use of this feature is subject to Facebook's privacy terms and settings, and we encourage you to review Facebook's Privacy Policy for more information on how your data is handled.

To process your payments: We provide paid products and/or services within the Service. For this purpose, we use third-party services for payment processing (for example, payment processors). As a result of this processing, you will be able to make a payment and we will be notified that the payment has been made. We will not store or collect your payment card details ourselves. This information will be provided directly to our third-party payment processors. To enable the purchase and to process your payments we use Solidgate, which is a payment gateway service provider. Also, we may use PayPal to process your payments.

To enforce our Terms and Conditions of Use and to prevent and combat fraud: We use personal data to enforce our agreements and contractual commitments, to detect, prevent, and combat fraud. As a result of such processing, we may share your information with others, including law enforcement agencies (in particular, if a dispute arises in connection with our Terms and Conditions of Use).

To comply with legal obligations: We may process, use, or share your data when the law requires it, in particular, if a law enforcement agency requests your data by available legal means.

UNDER WHAT LEGAL BASES WE PROCESS YOUR PERSONAL DATA

In this section, we are letting you know what legal basis we use for each particular purpose of processing. For more information on a particular purpose, please refer to Section 3. This section applies only to EEA-based users.

We process your personal data under the following legal bases:

Your consent: We rely on your explicit consent to process your sensitive personal data (such as information concerning your health). Please do not share any sensitive personal data unless you are comfortable doing so. You have the right to withdraw your consent at any time by contacting our support team at Support@longetic.com. We will promptly cease processing the data for which consent has been withdrawn. Please note that some functionality of our Service depends on the processing of sensitive personal data, which may include sensitive information you've provided. Therefore, withdrawing consent to process certain types of data may result in: reduced accuracy and personalization of Service and/or limited functionality of certain Service features.

If you are a resident of the European Union, under this legal basis we will also send you marketing communications. You have the right to withdraw your consent any time by using the unsubscribe link in the footer of our emails. We will also send you push notifications if you allow us to. You can disable notifications any time in the settings of your device.

To perform our contract with you: Under this legal basis we provide our Service (in accordance with our Terms and Conditions of Use), customize your experience, provide you with customer support, communicate with you regarding your use of our Service, and process your payments.

For our (or others') legitimate interests, unless those interests are overridden by your interests or fundamental rights and freedoms that require protection of personal data: We rely on legitimate interests to communicate with you regarding your use of our Service (our interest to encourage you to use our Service more often), to research and analyze your use of the Service (our interest in improving our Service so that we understand users' preferences and are able to provide you with a better experience), to send you marketing communications if you are not a resident of the European Union (our interest to promote our Service, including new products and special offers, in a measured and appropriate way), to personalize our ads (our interest to promote our Service in a reasonably targeted way), and to enforce our Terms and Conditions of Use and to prevent and combat fraud (enforcing our legal rights, preventing and addressing fraud and unauthorised use of the Service).

To comply with legal obligations.

WITH WHOM WE SHARE YOUR PERSONAL DATA

We share information with third parties that help us operate, provide, improve, integrate, customize, support, and market our Service. We may share some sets of personal data, in particular, for purposes and with parties indicated in Section 3 of this Privacy Policy. The types of third parties we share information with include, in particular:

Service providers: We share personal data with third parties that we hire to provide services or perform business functions on our behalf, based on our instructions. We may share your personal information with the following types of service providers: cloud storage providers (Amazon, Google, Digital Ocean, Firestorage); data analytics providers (Facebook, Firebase, Appsflyer, Amplitude, Crashlytics); measurement partners; communication service providers (Firebase); marketing partners (in particular, social media networks, marketing agencies, email delivery services; Facebook, Google); payment service providers (PayPal, Solidgate).

Law enforcement agencies and other public authorities: We may use and disclose personal data to enforce our Terms and Conditions of Use, to protect our rights, privacy, safety, or property, and/or that of our affiliates, you or others, and to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, or in other cases provided for by law.

Third parties as part of a merger or acquisition: As we develop our business, we may buy or sell assets or business offerings. Customers' information is generally one of the transferred business assets in these types of transactions. We may also share such information with any affiliated entity (e.g. parent company or subsidiary) and may transfer such information in the course of a corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

HOW YOU CAN EXERCISE YOUR PRIVACY RIGHTS

To be in control of your personal data, you have the following rights:

Accessing / reviewing / updating / correcting your personal data: You may review, edit, or change the personal data that you had previously provided on the Service.

Deleting your personal data: You can request erasure of your personal data as permitted by law. When you request deletion of your personal data, we will use reasonable efforts to honor your request. In some cases, we may be legally required to keep some of the data for a certain time; in such event, we will fulfill your request after we have complied with our obligations.

Objecting to or restricting the use of your personal data: You can ask us to stop using all or some of your personal data or limit our use thereof.

Additional information for EEA-based users: If you are based in the EEA, you have the following rights in addition to the above: The right to lodge a complaint with supervisory authority — we would love you to contact us directly, so we could address your concerns. Nevertheless, you have the right to lodge a complaint with a competent data protection supervisory authority, in particular in the EU Member State where you reside, work or where the alleged infringement has taken place. The right to data portability — if you wish to receive your personal data in a machine-readable format, you can send respective request to us as described below.

To exercise any of your privacy rights, please send a request to Support@longetic.com.

AGE LIMITATION

We do not knowingly process personal data from persons under 18 years of age. If you learn that anyone younger than 18 has provided us with personal data, please contact us.

INTERNATIONAL DATA TRANSFERS

We may transfer personal data to countries other than the country in which the data was originally collected in order to provide the Service set forth in the Terms and Conditions of Use and for purposes indicated in this Privacy Policy. If these countries do not have the same data protection laws as the country in which you initially provided the information, we deploy special safeguards.

In particular, if we transfer personal data originating from the EEA to countries with not adequate level of data protection, we use one of the following legal bases: (i) Standard Contractual Clauses approved by the European Commission (details available here), or (ii) the European Commission adequacy decisions about certain countries (details available here).

CHANGES TO THIS PRIVACY POLICY

We may modify this Privacy Policy from time to time. If we decide to make material changes to this Privacy Policy, you will be notified by available means such as email and will have an opportunity to review the revised Privacy Policy. By continuing to access or use the Service after those changes become effective, you agree to be bound by the revised Privacy Policy.

U.S. STATES PRIVACY NOTICE

If you reside in a state of the USA that has enacted consumer privacy laws, our U.S. States Privacy Notice applies to you. It supplements our Privacy Policy and provides disclosures required by laws in states such as California, Colorado, Connecticut, Delaware, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, Utah, and Virginia.

DATA RETENTION

We will store your personal data for as long as it is reasonably necessary for achieving the purposes set forth in this Privacy Policy (including providing the Service to you). We will also retain and use your personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

HOW "DO NOT TRACK" REQUESTS ARE HANDLED

Various browsers (including Internet Explorer, Firefox, and Safari) offer a DNT option that relies on a technology known as a DNT header that sends a signal to websites visited by the browser user about the user's DNT preference. You can usually access your browser's DNT option in your browser's preferences.

We currently do not support "Do Not Track" requests because no DNT standard has been adopted.

Our third-party services may collect information about you and your online activities over time and across our Services and other online properties. These third parties may not change their tracking practices in response to DNT settings in your web browser and we do not obligate these parties to honor DNT settings. To determine whether any of the third-party services honor the "Do Not Track" requests, please read their privacy policies.

CONTACT US

You may contact us at any time for details regarding this Privacy Policy and its previous versions. For any questions concerning your account or your personal data please contact us at Support@longetic.com.

Effective as of: July 8, 2026