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Privacy Policy

Last updated: 1 January 2025

Libreta Limited ("Libreta," "we," "us," or "our") is committed to protecting the personal data of everyone who uses our products. This Privacy Policy sets out what information we collect, why we collect it, how we use and share it, and what rights you hold over your data. It applies to all digital products and services operated by Libreta Limited, a company registered in Cyprus.

01 Who We Are

The data controller for your personal information is Libreta Limited, registered at Ezekia Papaioannou, 14 Office 101, 1075, Nicosia, Cyprus. For all privacy-related matters, please refer to the contact information available on our website.

02 Information We Collect

We collect information through the following means:

  • Information you provide: name, email address, date of birth, and payment details when you register or subscribe;
  • Automatically collected data: device identifiers, IP addresses, browser type, OS, pages visited, features used, and session duration;
  • Health or wellness preferences: where applicable to our product, and only with your explicit consent;
  • Third-party sources: analytics providers, advertising platforms, and payment processors, subject to their own policies.

03 How We Use Your Information

Your personal data may be used to:

  • Deliver, maintain, and continuously improve our products;
  • Process payments and administer subscription accounts;
  • Communicate with you about updates, account matters, and — where opted in — promotions;
  • Personalize your in-app experience and surface relevant recommendations;
  • Conduct analytics and understand how our products are used;
  • Detect, investigate, and prevent unauthorized or fraudulent activity;
  • Comply with applicable legal and regulatory obligations.

04 Legal Bases for Processing

Where GDPR or equivalent data protection legislation applies, we rely on the following legal bases:

  • Contractual necessity: to deliver the services you have subscribed to;
  • Legitimate interests: for fraud prevention, product improvement, and analytics, where such interests are not overridden by your rights;
  • Consent: for marketing communications, sensitive data categories, and non-essential cookies;
  • Legal obligation: where processing is required by law.

05 Cookies and Tracking Technologies

Our products use cookies, pixels, and similar technologies to support functionality and analyze usage. We distinguish between essential cookies — necessary for the product to operate — and non-essential cookies used for analytics and personalization. You may manage your preferences through the consent mechanism presented within our products. Declining non-essential cookies does not affect core product functionality.

06 Data Sharing and Disclosure

We do not sell your personal data. We may disclose your information to:

  • Service providers: cloud infrastructure, payment processors, support platforms, and analytics tools operating under contractual data protection obligations;
  • Business partners: only where your consent has been obtained and in accordance with applicable law;
  • Legal and regulatory bodies: where required by law, court order, or to protect rights, property, or safety;
  • Successors: in the context of a merger, acquisition, or restructuring, with appropriate user notice.

07 International Data Transfers

Your data may be processed in countries outside your jurisdiction, including those that may not offer equivalent data protection standards. Where such transfers occur, we implement appropriate safeguards — including Standard Contractual Clauses approved by the European Commission — to ensure your data remains protected.

08 Data Retention

We retain personal data for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. Account information is generally held for the duration of your subscription and for a reasonable period thereafter. Anonymized or aggregated data may be retained indefinitely for analytical purposes.

09 Your Rights

Depending on your jurisdiction, you may hold the following rights over your personal data:

  • Access: to obtain a copy of the data we hold about you;
  • Rectification: to correct inaccurate or incomplete data;
  • Erasure: to request deletion where no legitimate ground for retention exists;
  • Restriction: to limit processing in certain circumstances;
  • Portability: to receive your data in a structured, machine-readable format;
  • Objection: to processing based on legitimate interests, including direct marketing;
  • Withdrawal of consent: at any time, without affecting the lawfulness of prior processing.

To exercise any of the above rights, please refer to the contact information available on our website. We will respond within the timeframes required by applicable law.

10 Security

We apply technical and organizational measures proportionate to the risks involved, including encryption in transit and at rest, access controls, and regular security reviews. No transmission over the internet is entirely secure; while we take every reasonable step to protect your data, we cannot guarantee absolute security.

11 Children's Privacy

Our products are not directed at individuals under the age of 16, or the applicable minimum age in your jurisdiction. We do not knowingly collect personal data from minors. If you believe such data has been inadvertently collected, please contact us via the contact information available on our website and we will take prompt corrective action.

12 Changes to This Policy

This Privacy Policy may be revised periodically to reflect changes in our practices, products, or applicable law. Material changes will be communicated through the relevant product interface or via registered contact channels. The revision date at the top of this document indicates when it was last updated. Continued use of our products following notice of changes constitutes acceptance of the revised Policy.

13 Complaints

If your privacy concern is not resolved to your satisfaction, you have the right to lodge a complaint with the competent supervisory authority in your jurisdiction. In Cyprus, this is the Office of the Commissioner for Personal Data Protection.

14 Contact

For all privacy-related questions, data requests, or concerns, please refer to the contact information available on our website.

Libreta Limited
Ezekia Papaioannou, 14 Office 101
1075, Nicosia, Cyprus

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