Privacy Policy

EGNAFLEX INC. – PRIVACY POLICY

Effective Date: 2025

Company: EgnaFlex Inc.

Address: 131 Continental Dr, Suite 305, Newark, DE, 19713, United States

Email: info@egnaflex.com

Phone: +1 302 600 2720

This Privacy Policy explains how EgnaFlex Inc. ("EgnaFlex", "Company", "we", "us", "our") collects, uses, stores, and protects personal data in connection with all EgnaFlex services, including the ReglFit mobile applications, EgnaFlex and ReglFit websites (such as egnaflex.com, reglfit.com, egnaflex.online, reglfit.online), and the ReglFit Hub e-commerce store.

We are committed to handling your data in a transparent and secure way, with a special focus on protecting your health and daily tracking data.

1. SCOPE AND DEFINITIONS

This policy covers the processing of:

  • Account and profile data
  • Health and daily tracking data
  • Device and usage data
  • E-commerce and payment data
  • Data obtained via cookies and similar technologies

"Personal data" means any information that identifies or can be used to identify you, directly or indirectly. Health and daily tracking data may qualify as "special category" or "sensitive" personal data under applicable laws.

2. DATA WE COLLECT

2.1. Account Information

We may collect:

  • Email address
  • Password (stored using secure hashing)
  • User ID (UID)
  • Third-party login tokens (e.g., Google Sign-In), if you choose to use them

This information is used to create and maintain your account, authenticate you, and communicate with you.

2.2. Profile Information

Depending on the features you use, we may collect:

  • Date of birth (day/month/year)
  • Time of birth (for certain features, such as astrology or advanced cycle analysis)
  • Gender (optional)
  • Country
  • City
  • District

Profile information is used to personalize your experience, improve predictions, and tailor insights.

2.3. Health and Daily Tracking Data (Sensitive Data)

Our apps allow you to manually enter a wide range of health and daily tracking data. All of these entries are optional. You are not required to provide health data, but not providing it may reduce the accuracy of certain predictions and insights.

Examples of data you may choose to enter include:

Menstrual & Reproductive Health

  • Period days and cycle start/end dates
  • Flow intensity and spotting
  • Cycle length
  • Ovulation days and fertile window
  • PMS periods and related symptoms
  • Sexual activity and protection status, as entered by you
  • Pregnancy test information and pregnancy symptoms
  • Perimenopause or menopause-related signs

Symptoms & Emotional State

  • Daily symptoms (e.g., cramps, migraines, headaches)
  • Mood and emotional state
  • Energy level
  • Stress and anxiety level

Physical and Biometric Data

  • Sleep duration and related information
  • Weight
  • Basal body temperature (BBT)
  • Physical activity and exercise
  • Body measurements, if you choose to enter them

Digestive and Urinary Data

  • Bloating, gas, nausea
  • Bowel movement patterns (e.g., diarrhea, constipation)
  • Urine characteristics, as entered by you

Mental, Social, and Lifestyle Data

  • Meditation duration and other mental wellbeing activities
  • Daily notes (free-form text you write)
  • Custom tags you assign to your days or entries
  • Social activities and how you felt during the day
  • Skin, hair, or acne-related observations

Medical, Medication, and Condition Data

  • Conditions you manually enter (e.g., migraines, PCOS, endometriosis, thyroid issues)
  • Doctor appointments
  • Medication usage (prescription or over-the-counter)
  • Supplements and vitamins
  • Summaries of test results, if you choose to record them

All such data is provided directly by you. We do not automatically import health data from third-party sources unless you explicitly authorize such a connection (and where such functionality exists).

2.4. E-Commerce and Payment Data (ReglFit Hub)

When you purchase products through ReglFit Hub, we may collect:

  • Name and surname
  • Shipping address
  • Billing address
  • Order details and order history
  • Payment status and method (card data is processed by the payment provider; we do not see full card numbers)
  • Shipping and tracking information

This data is used to process your orders, fulfill deliveries, issue invoices, and provide customer support.

2.5. Device and Technical Data

When you use our apps or websites, we may receive:

  • Device model and operating system
  • App version
  • Language and region settings
  • IP address (for security, fraud detection, and localization)
  • Crash logs and error reports
  • Performance and usage statistics

This information helps us ensure stability, improve performance, and troubleshoot issues.

2.6. Analytics and Cookies

We use analytics tools to better understand how our apps and websites are used and to improve our services.

We currently use:

  • Google Analytics
  • Firebase Analytics

These tools may collect information such as page views, clicks, session duration, device type, and similar usage data. You may adjust your browser or device settings to limit certain types of tracking.

3. HOW WE USE YOUR DATA

We process personal data for one or more of the following purposes:

  • Creating, managing, and securing user accounts
  • Providing menstrual cycle, PMS, ovulation, and related predictions
  • Offering features for trying to conceive (TTC), pregnancy tracking, general health tracking, and perimenopause monitoring
  • Generating personalized insights, statistics, and summaries based on your daily entries
  • Enabling AI-driven assistant features (such as "Raya")
  • Personalizing your experience and content
  • Monitoring performance, detecting bugs, and improving app stability
  • Processing and fulfilling orders placed via ReglFit Hub
  • Preventing fraud, abuse, or security incidents
  • Complying with legal obligations and responding to law enforcement or regulatory requests

4. LEGAL BASES FOR PROCESSING

We process your data under various legal bases, depending on applicable law and the specific processing activity, including:

  • Consent: Especially for health and other sensitive data, we rely on your explicit consent.
  • Contractual necessity: To provide you with the services you sign up for and to fulfill our contractual obligations.
  • Legitimate interests: For example, to improve our services, ensure security, and prevent abuse, provided that these interests do not override your fundamental rights and freedoms.
  • Legal obligations: To comply with tax, accounting, or regulatory requirements.

5. SECURITY AND ENCRYPTION

We implement strong security measures to protect your data, particularly your health information:

  • Sensitive data is protected with end-to-end encryption (E2EE).
  • We use robust encryption algorithms such as AES-GCM.
  • Data Encryption Keys (DEKs) are protected using Key Encryption Keys (KEKs) at the device level.
  • Our servers operate under a zero-knowledge model for encrypted health data; we are not able to decrypt your end-to-end encrypted content.
  • Local storage (e.g., via Hive) is encrypted.
  • Access to systems and data is strictly controlled and monitored.
  • We regularly review our security practices and may engage third-party providers for audits and testing.

6. CHILDREN'S PRIVACY

Our services are primarily designed for adults but may be accessible to users in different age groups depending on local laws and parental guidance. Certain features that involve sensitive health data may be restricted or may require meeting age thresholds defined by applicable regulations.

If we become aware that a user under the age required by applicable law has created an account or entered sensitive data without verifiable parental consent:

  • We will, upon notice or discovery, permanently delete the account and all associated data.
  • This deletion will apply across our systems, including backups, making the data unrecoverable.
  • Parents or legal guardians who believe that their child is using our services without appropriate consent may contact us to request account deletion.

7. DATA DELETION AND ACCOUNT CLOSURE

You may request deletion of your account and data through in-app settings (where available) or by contacting us via email.

When you initiate account deletion:

  • We may ask you to complete several confirmation steps (for example, password or email verification).
  • Once confirmed, we will irreversibly delete your personal and health data from our systems.
  • Deleted data is not retained in backups and cannot be restored.
  • Certain transaction and billing records (e.g., for purchases made through ReglFit Hub) may be retained as required by law, but will no longer be associated with an active user profile for regular use.

8. DATA SHARING AND THIRD PARTIES

We do not sell your personal data or share it with third parties for their own direct marketing purposes.

We may share data with trusted third-party service providers solely for the purposes of providing and improving our services, such as:

  • Authentication and database providers (Firebase Authentication, Firestore, Firebase Storage)
  • Cloud infrastructure providers (e.g., Google Cloud)
  • Payment processors (e.g., Stripe, Shopify Payments)
  • E-commerce platforms (Shopify, for ReglFit Hub)
  • Analytics providers (Google Analytics, Firebase Analytics)
  • Error monitoring and performance tools

These providers act as data processors under our instructions and are required to implement appropriate security measures and comply with applicable data protection laws.

We may also disclose data if required to do so by law or in response to valid requests by public authorities, courts, or regulators.

9. INTERNATIONAL DATA TRANSFERS

EgnaFlex Inc. is based in the United States, and your data may be stored and processed on servers located in the U.S. and other countries.

For users in the European Economic Area (EEA), the United Kingdom, and similar jurisdictions, we may rely on appropriate safeguards such as Standard Contractual Clauses (SCCs) or equivalent mechanisms for data transfers.

10. YOUR RIGHTS

Depending on your jurisdiction, you may have some or all of the following rights:

  • Right of access: obtain confirmation whether we process your data and receive a copy.
  • Right to rectification: request correction of inaccurate or incomplete data.
  • Right to erasure: request deletion of your personal data (subject to legal exceptions).
  • Right to restrict processing: request limited processing under certain circumstances.
  • Right to data portability: receive your data in a structured, commonly used, machine-readable format and transmit it to another controller where technically feasible.
  • Right to withdraw consent: withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
  • Right to lodge a complaint: with a competent data protection authority.

To exercise these rights, you may contact us at info@egnaflex.com. We may need to verify your identity before processing certain requests.

11. DATA RETENTION

We retain data only for as long as necessary to fulfill the purposes described in this policy or as required by applicable law. In particular:

  • Account data is retained for the lifetime of the account.
  • Health and daily tracking data is stored until you delete it or delete your account.
  • E-commerce and billing records may be retained for up to 7 years or as required by tax and accounting regulations.
  • Analytics data is retained for a reasonable period and may be stored in anonymized or pseudonymized form where possible.

When data is no longer needed, we will delete, anonymize, or aggregate it in accordance with our data retention and deletion procedures.

12. CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time. When we do, we will revise the "Effective Date" at the top of the policy and may notify you through the app, website, or email when appropriate.

We encourage you to review this policy periodically to stay informed about how we handle your data.

13. CONTACT US

If you have any questions, concerns, or requests related to this Privacy Policy or our data practices, you may contact us at:

EgnaFlex Inc.

131 Continental Dr, Suite 305

Newark, DE, 19713

United States

Email: info@egnaflex.com

Phone: +1 302 600 2720