DrinkSmart Privacy Policy

Nuvio Digital Agency ("Company", "we", "us", or "our") operates DrinkSmart, an anonymous-first real-time reminder app for drinking sessions. No account registration required. This Privacy Policy explains how we collect, use, disclose, and safeguard the minimal information needed to provide our service.

1. Information We Collect

A. Automatically Collected (No Sign-up Required)

• Anonymous Identifier: Firebase anonymous UID
• Push Notifications: FCM token (if notifications enabled)
• Device Info: Device type, operating system, app version
• Analytics Data (Firebase Analytics): Screen views, feature usage, session duration
• Error Reports (Sentry): Crash reports, performance metrics

B. Optional Information (User Choice)

• Personality Type: If you choose to take the MBTI test
• Session Data: Drinking session times and types
• Language Preference: English or Korean

C. Premium Subscription

• Subscription status and expiry date (verified through RevenueCat)
• Transaction ID (provided by Apple/Google for subscription verification)
• Payment information is handled directly by Apple/Google and not collected by the app

2. Legal Basis for Processing

We process personal information based on the following legal grounds:

• Consent: By installing and using the app, you consent to this Privacy Policy
• Contract: Processing necessary to provide our services
• Legal Obligation: Compliance with applicable laws
• Legitimate Interests: Service improvement and security enhancement

3. How We Use Your Information

We use the collected information to:

• Provide and maintain the Service
• Personalize your experience based on personality type and drinking patterns
• Send push notifications for session reminders
• Process and manage Premium subscriptions
• Analyze usage patterns to improve the Service
• Communicate important updates and changes
• Ensure legal compliance (age verification)
• Monitor service stability and resolve errors
• Detect and prevent fraud or abuse

4. Information Sharing and Disclosure

We do NOT sell, trade, or rent your personal information. We may share information only in these circumstances:

• Service Providers: With trusted third parties who assist in operating our Service
• Legal Requirements: When required by law or to protect our rights
• Business Transfers: In connection with a merger or acquisition
• Aggregated Data: Non-identifiable aggregated data for analytics
• With Your Consent: When you explicitly agree to sharing

5. Third-Party Services

We use the following third-party services:

6. Data Security

We implement appropriate security measures including:

• Encryption of data in transit (TLS/SSL)
• Encryption of sensitive data at rest
• Regular security audits and updates
• Access controls and authentication
• Secure cloud infrastructure (AWS)
• Security incident monitoring systems

However, no method of transmission over the internet is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.

7. Data Retention

We retain your information for as long as:

• You continue using the app or until you delete your account
• Needed to provide you services
• Required for legal obligations:
  • E-Commerce Act: Payment records for 5 years
  • Communications Privacy Act: Access logs for 3 months
• Necessary to resolve disputes

8. Your Rights and Choices

You have the right to:

• Access: Request a copy of your personal data
• Delete: Delete your account and all associated data directly from the app
• Opt-out: Disable push notifications in app settings
• Restriction: Limit how we process your information
• Data Portability: Request your data in a machine-readable format (GDPR)

For detailed information, visit our Account Deletion page.

For other privacy inquiries, contact us at info@nuviodigital.com

9. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence. These countries may have different data protection laws. By using the Service, you consent to such transfers.

10. Age Restrictions

DrinkSmart is intended for users of legal drinking age in their respective countries (e.g., 21+ in the US, 19+ in Korea, 20+ in Japan, 18+ in Europe). We do not knowingly collect information from users below the legal drinking age. The app is rated 17+ on app stores due to alcohol-related content.

11. California Privacy Rights (CCPA)

California residents have additional rights under the CCPA:

• Right to know what personal information is collected
• Right to know if personal information is sold or disclosed
• Right to opt-out of the sale of personal information (we do not sell your data)
• Right to non-discrimination for exercising privacy rights

12. European Privacy Rights (GDPR)

If you are in the European Economic Area (EEA), you have additional rights under GDPR:

• Right to erasure ("right to be forgotten")
• Right to data portability
• Right to withdraw consent
• Right to lodge a complaint with supervisory authorities
• Automated decision-making disclosure

13. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the new policy in the app and updating the "Last Updated" date. Your continued use of the Service after changes constitutes acceptance.

14. Contact Us