Our Data Protection Policy
Apparent Group Limited (“we,” “our,” or “us”) respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application, Daily Grace (the “App”).
Please read this Privacy Policy carefully. By using the App, you consent to the data practices described in this policy.
1. Data Controller
Apparent Group Limited is the data controller responsible for your personal data. If you have any questions about this Privacy Policy or our data practices, please contact us using the details in Section 12.
2. Information We Collect
We collect information to provide you with a personalized motivational experience, tailored to your goals and preferences.
A. Personal Data You Provide to Us
We may collect personal information that you voluntarily provide to us when you:
- Create an Account: Name, email address, and password or social login credentials (e.g., Apple, Google, Facebook).
- Complete Onboarding: Information about your goals, challenges, current mindset, age range, gender, and specific areas of life you wish to improve (e.g., wealth, fitness, career).
- Contact Support: Information contained in your correspondence with us.
B. Usage and Device Data
When you access the App, our servers automatically collect certain information, including:
- Device Information: Device model, operating system version, unique device identifiers, and mobile network information.
- Usage Data: Details of your visits to the App, such as the “Power Talks” you listen to, playlists you create, streak data, time spent on the App, and features used.
- Log Data: IP address, browser type, and system activity.
3. How We Use Your Information
We use the collected information for the following purposes:
- Service Delivery: To provide and maintain the App, including managing your account and processing subscriptions.
- Personalization: To curate “Power Talks,” quotes, and motivational content that aligns with your stated goals and challenges.
- Improvement: To analyze usage patterns and improve the functionality, content, and user experience of the App.
- Communication: To send you administrative information, such as updates, security alerts, and support messages.
- Marketing (with consent): To send you newsletters or promotional materials, which you can opt-out of at any time.
- Compliance: To enforce our Terms of Service and comply with legal obligations.
4. Legal Basis for Processing (GDPR)
If you are located in the European Economic Area (EEA), our legal basis for collecting and using your personal data depends on the specific context:
- Performance of a Contract: We process your data to provide the App’s services as agreed in our Terms of Service.
- Legitimate Interests: We process your data for our legitimate business interests, such as improving the App and ensuring security, provided these interests are not overridden by your rights.
- Consent: We may ask for your consent for specific processing activities, such as sending marketing emails or collecting sensitive data. You can withdraw consent at any time.
- Legal Obligation: We may process data to comply with applicable laws.
5. Data Sharing and Disclosure
We do not sell your personal data. We may share your information with:
- Service Providers: Third-party vendors who perform services on our behalf, such as cloud hosting, analytics, payment processing, and customer support. These providers are bound by confidentiality agreements.
- Business Transfers: In connection with any merger, sale of company assets, financing, or acquisition of all or a portion of our business.
- Legal Requirements: If required to do so by law or in the good faith belief that such action is necessary to comply with a legal obligation, protect our rights, or investigate fraud.
6. International Data Transfers
The App is operated by Apparent Group Limited, based in Hong Kong. Your information may be transferred to, stored, and processed in Hong Kong or other countries where our servers or service providers are located.
If you are accessing the App from the EEA, please note that your data may be transferred outside the EEA. We take appropriate measures to ensure your data remains protected, such as relying on adequacy decisions or implementing Standard Contractual Clauses approved by the European Commission.
7. Data Retention
We retain your personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. We will retain and use your information to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our policies.
8. Your Data Protection Rights (GDPR)
If you are a resident of the EEA, you have the following rights regarding your personal data:
- Right of Access: Request copies of your personal data.
- Right to Rectification: Request correction of any information you believe is inaccurate or incomplete.
- Right to Erasure: Request that we delete your personal data (“Right to be Forgotten”).
- Right to Restrict Processing: Request that we restrict the processing of your personal data.
- Right to Object: Object to our processing of your personal data.
- Right to Data Portability: Request that we transfer the data that we have collected to another organization, or directly to you.
To exercise these rights, please contact us at hello@apparentgroup.co. We will respond to your request within one month.
9. Security
We use administrative, technical, and physical security measures to help protect your personal information. However, please be aware that no electronic transmission or storage method is 100% secure. While we strive to protect your personal information, we cannot guarantee its absolute security.
10. Children’s Privacy
The App is not intended for use by children under the age of 16 (or the age of digital consent in your jurisdiction). We do not knowingly collect personal data from children. If we become aware that we have collected personal data from a child without parental consent, we will take steps to remove that information.
11. Changes to This Privacy Policy
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the “Last Updated” date. You are advised to review this Privacy Policy periodically for any changes.
12. Contact Us
If you have any questions or concerns about this Privacy Policy, please contact us at:
Apparent Group Limited
FLAT/RM 05-06, 18/F, HOLLYWOOD PLAZA
610 NATHAN ROAD, KL
Hong Kong
Email: hello@apparentgroup.co