This Privacy Notice explains how Setapphub Development Inc, operating as Reluvia (“Reluvia,” “we,” “us,” or “our”), collects, uses, shares and protects personal data when you use Reluvia and our services.
It should be read together with our Cookie Notice, which explains how we use cookies and similar technologies on our website and in the app.
When you use Reluvia, we collect information that you provide directly, such as onboarding answers, journal entries, mood check-ins and AI Companion messages, as well as information collected automatically, such as usage and device data. This Notice explains what we collect, how we use it and the choices available to you.
We use this information to provide and operate Reluvia, personalize your experience, support AI features, manage subscriptions, respond to requests, maintain security and improve our services.
When you use features such as journaling, mood check-ins or the AI Companion, you may choose to share information about your emotional state, relationships, wellbeing goals, reflections or personal experiences. We use this information to provide and personalize those features.
Reluvia includes AI-supported features, including the AI Companion. When you use these features, your messages and relevant context may be processed to generate responses and other personalized content. AI-generated responses are intended for general self-reflection and emotional wellbeing support only and are not medical, therapeutic, crisis or other professional advice.
We use service providers that help operate Reluvia, including providers of hosting, analytics, payments, customer support, communications, security, app infrastructure and AI technology services.
We do not sell your personal data as that term is defined under applicable U.S. state privacy laws. We also do not use the content of your AI chats, journal entries, mood entries or personal reflections for advertising purposes. In some jurisdictions, certain data sharing for analytics or advertising-related purposes may be considered “sale” or “sharing” under privacy laws, and you may have the right to opt out. More information is available in the U.S. State Privacy Disclosures section below.
Depending on where you live, you may have rights to access, correct, delete, restrict or receive a copy of your personal data, as well as to object to certain processing or withdraw consent where applicable.
Reluvia is operated by Setapphub Development Inc, which is responsible for the processing of personal data described in this Privacy Notice.
Company: Setapphub Development Inc
Email: hello@reluvia.app
Address: 42 Reads Way Suite 42V New Castle, DE 19720
This Privacy Notice applies when you use the Reluvia website or app, including when you create an account, complete onboarding, use the AI Companion or other features such as personal plans, journal entries, mood check-ins, lessons, exercises, audio or video content and guided journeys, manage a subscription, use our website or account-related pages, or contact us for support, billing or privacy-related requests.
It does not apply to third-party websites, platforms or services that we do not control. Their privacy practices are governed by their own notices.
We collect personal data in three main ways: information you provide directly, information generated when you use Reluvia, and limited information received from service providers that help us operate the app, manage subscriptions and provide support.
What we collect depends on how you use Reluvia, which features you choose, your device settings and whether you have a subscription.
When you use Reluvia, we and our service providers may automatically collect technical, usage and diagnostic information. This may include:
We may receive limited information from third parties that help us operate Reluvia. This may include:
We use information received from service providers for the purposes described in this Notice and in accordance with applicable law.
Reluvia provides personalized self-reflection and emotional wellbeing features. To support this, we use information we collect as described in this Notice during onboarding, your app activity, and information you provide or generate through your use of the app, including personalization-related content such as onboarding inputs, interactions, and in-app activity. This helps us deliver personalized plans, guided content, recommendations, reminders and progress tracking within the service.
Reluvia may offer AI-supported features, including the AI Companion. The AI Companion may be included in your subscription, offered as a separate add-on, or made available through another product option depending on the plan or offer you choose.
If you use the AI Companion, we process your messages and related context to generate responses and other personalized content. The AI Companion may use relevant conversation context to provide more helpful and relevant responses. This means the AI Companion may remember things you have shared in previous sessions and use that context when responding to you in future conversations. Depending on the features available in the app, you may be able to delete your chat history, clear AI memory, or request deletion of certain personal data as described in this Notice. Clearing chat history or AI memory removes that information from your active AI Companion experience and may affect conversation continuity, personalization or related contextual features, but does not automatically delete your account or other app data.
The app may also allow you to adjust certain settings that affect how the AI Companion communicates with you. These settings may be used as part of the conversation context to generate responses.
AI-generated responses are intended solely for general self-reflection and emotional wellbeing support. They are not medical, psychological, therapeutic, crisis, legal or other professional advice, and do not create any professional or therapeutic relationship.
To provide AI-supported features, we may use third-party AI technology providers that process information as necessary to provide, maintain and support the feature on our behalf. We do not permit third-party AI providers to use your AI Companion conversations, journal entries, mood data, reflections, or other emotional wellbeing content to train or develop AI models for purposes beyond providing Reluvia to you unless you have explicitly opted in to that specific use after being clearly informed.
We use personal data to provide Reluvia, personalize your experience, support the AI Companion, manage subscriptions, respond to requests, keep the service secure and improve the app over time.
Providing and operating Reluvia. We use personal data to create and manage accounts, keep you logged in, provide app features, save your progress, deliver content, maintain subscriptions and support the general operation of Reluvia. Legal bases, where required: Contract; legitimate interests.
Personalizing your experience. We use information such as your onboarding answers, app activity, preferences and content you choose to enter to personalize your plan, guided content, recommendations, reminders, progress tracking and other parts of Reluvia. Legal bases, where required: Contract; legitimate interests; consent where required.
The AI Companion and AI-supported features. If you use the AI Companion, we use your messages, related context and related information to generate responses, personalize the experience and help ensure safe and appropriate use of the service. The AI Companion may be included in a subscription, offered as an add-on, or made available through another product option. Legal bases, where required: Contract; legitimate interests for safety, service quality and misuse prevention; consent where required.
Journal, mood and reflection features. If you use journaling, mood check-ins, reflection prompts or similar features, we use the content you choose to enter to provide those features, display your history, support progress tracking and personalize your experience within the app. Legal bases, where required: Contract; legitimate interests; consent where required.
Subscriptions, payments and billing. We use payment and subscription information to confirm purchases, provide access to paid features or add-ons, manage renewals and cancellations, handle refunds and billing support, prevent fraud and maintain required financial records. We do not store full payment card numbers. Legal bases, where required: Contract; legal obligation; legitimate interests.
Communicating with you (service messages). We use contact information to send you service-related communications, such as account notices, subscription updates, security alerts, changes to our terms and support replies. These messages are necessary to provide the service and cannot be fully opted out of while your account is active. Legal bases, where required: Contract; legitimate interests; legal obligation where applicable.
Marketing communications. If you have signed up for marketing communications or where otherwise permitted by law, we may send you promotional messages, product updates or surveys. You can opt out of marketing communications at any time using the unsubscribe link in our emails or by contacting us. Legal bases, where required: Consent, and where permitted under applicable law, legitimate interests.
Push notifications and reminders. If you enable push notifications, we may send reminders, content prompts, updates or other notifications based on your settings. You can turn them off at any time through your device settings. Legal bases, where required: Consent (for non-essential notifications); legitimate interests (for essential service-related or security-related notices where applicable).
Analytics, diagnostics and product improvement. We use technical, usage and diagnostic information to understand how Reluvia is used, fix issues, monitor performance, improve onboarding, test features and make the app more reliable and useful. Legal bases, where required: Legitimate interests (for essential product performance, security and service improvement); consent where required (for non-essential analytics, cookies or tracking technologies).
Marketing and attribution. We may use attribution and campaign measurement tools to understand how users find Reluvia and whether campaigns are effective. These tools receive technical, usage, attribution and event-level information only. We do not use the content of your AI Companion conversations, journal entries, mood entries or personal reflections to build advertising audiences or for targeted advertising. Legal bases, where required: Consent where required (for cookies, tracking and similar technologies); legitimate interests where permitted (for aggregated attribution and internal analytics); opt-out where applicable.
Security, fraud prevention and misuse prevention. We use technical information, identifiers, logs and activity signals to protect Reluvia, secure accounts, detect fraud, prevent misuse, investigate suspicious activity and maintain service integrity. Legal bases, where required: Legitimate interests; legal obligation.
Legal compliance, disputes and enforcement. We may use personal data to comply with applicable laws, respond to lawful requests, enforce our Terms, handle complaints, manage chargebacks, resolve disputes or defend legal claims. Legal bases, where required: Legal obligation; legitimate interests.
Business transfers. If Reluvia or the company operating it is involved in a merger, acquisition, financing, restructuring or sale of assets, personal data may be transferred as part of that transaction, subject to appropriate safeguards. Where required by law, we will provide notice of relevant changes. Legal bases, where required: Legitimate interests; legal obligation where applicable.
Aggregated and de-identified information. We may use information that cannot reasonably be used to identify you, such as aggregated usage statistics, for analytics, reporting, research, product improvement and business planning.
Reluvia uses automated processing, including personalization systems and AI-supported features, to generate recommendations, responses, insights, reminders, and other personalized content within the app. These outputs, such as plans, recommendations, AI responses, and progress insights, are used solely to support your app experience and are not used to make decisions that produce legal effects or similarly significant effects on you. Reluvia does not engage in solely automated decision-making within the meaning of applicable data protection laws that produces legal or similarly significant effects on users.
Privacy law in some regions requires us to identify a legal reason for each use of personal data. Where that applies, we rely on one or more of the following:
Special category data. Some information processed through Reluvia, including emotional wellbeing information, mood data, reflections, journal entries, and AI Companion conversations, may constitute special category data or data concerning health under applicable data protection laws, including the UK GDPR and EU GDPR.
Where we process special category data, we rely on your explicit consent under Article 9(2)(a) of the UK GDPR / EU GDPR, in addition to an applicable Article 6 legal basis described in this Notice. You provide this consent when you choose to use features that involve this type of information, such as journaling, mood check-ins, onboarding personalization, or AI Companion features.
You may withdraw your consent at any time by discontinuing use of the relevant features, deleting associated content where controls are available, adjusting your settings, or contacting us. Withdrawal of consent does not affect processing carried out before withdrawal.
We share personal data in the ways described in this Notice, including to operate and provide Reluvia, process payments, maintain security, improve our services, comply with legal obligations, or where you instruct or request us to do so. We do not sell your personal data.
Service providers. We work with service providers that help us operate Reluvia, including providers of hosting, infrastructure, analytics, attribution, payments, subscriptions, customer support, communications, security, content delivery, error monitoring and AI technology. These providers process personal data on our behalf to deliver their services to us.
AI technology providers. If you use AI-supported features, we may share your messages, relevant conversation context and related technical information with AI technology providers to generate responses and support the AI Companion. We do not permit these providers to use your personal data to train or develop AI models for purposes beyond providing Reluvia to you unless you have explicitly opted in to that specific use after being clearly informed.
App stores and payment providers. If you purchase a subscription, add-on or other paid feature, app stores and payment providers process payment and transaction information. They may share limited information with us, such as confirmation of your purchase, subscription status, billing details, refunds, cancellations and fraud-prevention signals, to enable access to paid features and manage your account. We do not store full payment card details on our systems.
Analytics, attribution and campaign measurement. We may share technical, usage, attribution and event-level information with analytics and attribution providers to understand how Reluvia is used and measure campaign performance. We do not share the content of your AI Companion conversations, journal entries, mood entries or personal reflections for advertising purposes. Where required, we obtain consent or provide opt-out controls for non-essential analytics and marketing technologies.
Support and communications. If you contact us, we may share information with support, communication and customer service providers to help us respond to your request, send service messages, provide billing assistance or manage privacy-related requests.
Affiliates and corporate group. We may share personal data with companies within our corporate group where necessary to operate, manage, support or improve Reluvia, subject to appropriate safeguards and consistent with this Privacy Notice.
Legal, safety and compliance. We may disclose personal data where reasonably necessary to comply with applicable law or legal process; protect the rights, safety, security or property of users, Reluvia or others; detect, investigate or prevent fraud, misuse or abuse; enforce our Terms; or resolve disputes and defend legal claims.
Business transfers. If Reluvia or the company operating it is involved in a merger, acquisition, financing, restructuring or sale of assets, personal data may be disclosed or transferred as part of that transaction. Where required by law, we will provide notice of such changes and ensure appropriate safeguards for your personal data.
At your direction or with your consent. We may share personal data when you ask us to, give us permission, connect a third-party service, or choose to participate in a promotion or provide a public testimonial.
Aggregated and de-identified information. We may share aggregated or de-identified information that cannot reasonably be used to identify you, for example to report general usage trends or product insights.
Reluvia and the service providers we use may process personal data in countries other than your country of residence, including the United States, the United Kingdom, the European Economic Area and other jurisdictions where we or our providers operate.
Some of our key service providers process data outside the UK and EEA. For example, the AI technology that powers the AI Companion processes data in the United States. Other providers involved in hosting, analytics, attribution, payments, support and communications may also process data in the United States or other countries.
Where personal data is transferred internationally, we put appropriate safeguards in place as required by applicable law. These may include standard contractual clauses (and where applicable, the UK Addendum to the EU Standard Contractual Clauses), the UK International Data Transfer Agreement (IDTA), adequacy decisions, data processing agreements, or other legally recognised transfer mechanisms. These safeguards are designed to ensure that your personal data receives a level of protection equivalent to that required in your country of residence.
If you would like more information about the specific safeguards we use for international transfers, please contact us.
We retain personal data for as long as reasonably necessary to fulfil the purposes described in this Notice, unless a longer retention period is required or permitted by law.
We determine retention periods based on factors including the nature and sensitivity of the data, the purpose for which it was collected, account activity, legal and regulatory requirements, security and fraud prevention needs, dispute resolution and enforcement of our Terms, and technical constraints such as backups and recovery systems.
In general, different types of data are retained for different periods depending on their role in providing and operating Reluvia.
Deleting the app, clearing local data, or removing browser cookies does not delete information stored on Reluvia systems.
When you delete your account or specific content, we remove it from active systems where possible. We may retain limited information only where required for legal, security, fraud prevention, dispute resolution, or technical reasons, including temporary storage in backup systems.
To request deletion of your account or personal data, please refer to the “Your Rights and Choices” section below or contact us at help@reluvia.app. You may also find additional information in our help resources.
We use reasonable technical and organizational measures designed to protect personal data against unauthorized access, loss, misuse, alteration, or disclosure. These measures are applied based on the nature of the data and the risks associated with its processing.
Access to personal data is restricted to authorized personnel and service providers who need it to operate, support, secure, or comply with legal obligations in relation to Reluvia.
These measures include access controls, security policies, confidentiality obligations, and contractual safeguards with service providers. We maintain internal security policies and procedures for personnel handling personal data.
We periodically review and update our security measures to reflect changes in technology and security risks, and we maintain procedures designed to detect, investigate, and respond to suspected security incidents.
While we take appropriate steps to protect personal data, no system can be completely secure. If you believe your account or data has been compromised, please contact us promptly.
In the event of a personal data breach, we will comply with applicable data protection laws. Where required, we will notify the relevant supervisory authority and, where applicable, affected individuals within the timeframes required by law.
Reluvia uses cookies and similar technologies on our website, and comparable technologies in our app, to operate the service, support core functionality, maintain security, remember preferences, understand usage, and improve performance.
Some of these technologies are strictly necessary for the service to function. Others are used only where permitted to help us understand how Reluvia is used, improve features, measure performance and campaign effectiveness, or support notifications and communication features where you have enabled them.
Where required by law, we obtain your consent before using non-essential cookies or similar technologies. You can manage your preferences through our cookie banner or settings tool, and may also adjust certain choices through browser settings, device settings, app permissions, or platform-level privacy controls.
The legal bases for using cookies and similar technologies, as well as available controls and detailed information about providers, are described in our Cookie Notice.
This section explains the privacy rights available to you and how to exercise them. The specific rights that apply to you may vary depending on your location and applicable law.
These rights may include the right to:
To exercise your privacy rights, you may contact us at help@reluvia.app or use any privacy tools or controls made available within Reluvia. Please describe your request in sufficient detail and, where possible, include the email address associated with your account so we can verify and process your request.
Depending on the nature of the request, we may need to verify your identity before taking action. We may request additional information where reasonably necessary to confirm that the request is made by you or an authorized person acting on your behalf.
We aim to respond within the timeframe required by applicable law, which is generally within one month. Where permitted by applicable law, we may extend the response period for complex or high-volume requests. If we do so, we will notify you within the initial response period, explain the reason for the extension, and respond within the additional time permitted by applicable law.
You may also have choices through Reluvia, your device or your browser, including:
Where you withdraw consent, we will stop processing the relevant personal data for that purpose from the time of withdrawal. This does not affect the lawfulness of processing carried out before withdrawal. Depending on the features you use, withdrawal or deletion requests may impact personalization, recommendations, or continuity of your experience within the app. You can contact us at help@reluvia.app if you would like more information about how a specific request may affect your account.
Exercising your privacy rights will not affect your ability to use Reluvia, except where the requested action limits or disables certain features or where the information is necessary to provide the service.
If you believe your privacy rights have not been respected, you may contact us first at help@reluvia.app. You also have the right to lodge a complaint with your local data protection authority, supervisory authority, or other applicable privacy regulator, depending on your location and applicable law.
UK users may contact the Information Commissioner’s Office (ICO).
EEA users may contact their local data protection authority. Information about EEA supervisory authorities is available from the European Data Protection Board (EDPB).
U.S. state residents may have additional rights and disclosures provided in the U.S. State Privacy Disclosures section below. Where required by applicable law, you may also have the right to appeal our decision regarding your request.
Reluvia is intended for users aged 18 or older. Users under 18 are not permitted to use Reluvia or provide personal data through our app, website, or related services, including through AI-supported features.
If we become aware that we have collected personal data from a user under 18 in violation of this requirement, we will take appropriate steps to delete or otherwise handle the information in accordance with applicable law.
If you are a parent or guardian and believe that a child has provided personal data to Reluvia, please contact us at help@reluvia.app.
Reluvia may include links to third-party websites, platforms, or services that are not operated by us. We are not responsible for the privacy practices of these third parties, and this Privacy Notice does not apply to them. We encourage you to review their privacy notices before using their services.
If you have questions about this Privacy Notice, our privacy practices, or if you would like to exercise your privacy rights or submit a data protection request, please contact us at:
Please include sufficient information to help us understand and respond to your request. If your request relates to your Reluvia account, please include the email address associated with your account where possible.
We may update this Privacy Notice from time to time to reflect changes in Reluvia, our data practices, legal requirements or operational needs. When we do, we will update the effective date at the top of this Notice.
For non-material updates, the revised Notice applies from the effective date shown above. Where a change materially affects how we use personal data in a way that requires consent under applicable law, we will provide appropriate notice and, where required, ask for your consent before making that change.
We may notify you of significant updates through the app, our website, by email or through other appropriate communication methods.
This section provides additional information for residents of U.S. states that have comprehensive privacy laws (such as California, Virginia, Colorado, Connecticut, Utah and others). For California residents, this section also serves as our Notice at Collection.
| Category | Examples |
|---|---|
| Identifiers and account information | Email address, account details, IP address, and app or device identifiers used to operate your account and the service. |
| Commercial information | Subscription plan, purchase status, renewal, cancellation, refund, and billing-support information. |
| Internet or electronic activity | App usage, website activity, onboarding steps, feature interactions, logs, and diagnostic information. |
| Approximate location | Approximate location inferred from IP address or device settings, typically at the city or country level. |
| User content and communications | AI Companion messages, journal entries, mood check-ins, reflections, support messages, feedback, and other content you choose to provide. |
| Sensitive personal information | Emotional wellbeing information, mood data, and other sensitive information you choose to provide. |
| Personalization information | Personalized plans, preferences, progress indicators, AI-generated outputs, recommendations, and similar information used to tailor your experience. |
| Audio, visual or media information | Information you choose to provide through Reluvia features or interactions, where such content types are supported. |
| Other voluntary information | Information you provide in surveys, promotions, testimonials, feedback, or support requests. |
We collect this information from you, from your use of Reluvia, from your device, and from service providers that help us operate the service.
How we use these categories. We use these categories to provide, personalize, and improve Reluvia, operate onboarding, personal plans, journal, mood, and AI Companion features, manage accounts, subscriptions, payments, refunds, and billing support, respond to support and privacy requests, send service communications, maintain security and prevent fraud, measure product and campaign performance, comply with legal obligations, and enforce our Terms. We do not sell personal information as that term is defined under applicable U.S. state privacy laws.
How we disclose personal information. We may disclose personal information to service providers and other third parties described in this Notice, including app stores, payment providers, AI technology providers, analytics and attribution providers, support and communication providers, hosting and security providers, affiliates, professional advisers, regulators, legal authorities, and transaction partners in connection with a business transfer.
We disclose personal information for the purposes described in this Notice.
Sale, sharing and targeted advertising. Some U.S. state privacy laws (including but not limited to California, Virginia, Colorado, Connecticut, and others) define “sale,” “sharing,” or “targeted advertising” in a broad manner. Where applicable, certain processing of technical or device information through analytics, attribution, or advertising measurement tools may be considered “sale” or “sharing” under those laws.
We do not sell the content of your AI Companion conversations, journal entries, mood entries, personal reflections, or other sensitive personal content. We also do not use such content to build advertising audiences or personalize third-party advertising.
Where required by applicable law, you have the right to opt out of the sale or sharing of your personal information or targeted advertising. You may exercise this right through our cookie banner / preference tool, device settings, browser signals (where applicable), or by contacting us.
Sensitive personal information. We treat information you choose to share about your emotional wellbeing, mood, relationships, reflections, and similar personal experiences as sensitive personal information. This may include data provided through onboarding, journaling, mood check-ins, guided exercises, AI Companion conversations, or other features within Reluvia.
We use this information to operate and provide Reluvia, personalize your experience, support AI-supported features, maintain security, respond to requests, improve our services, and comply with legal obligations. We do not use this information to build advertising audiences or to personalize advertising for third parties. We do not sell this content. Access to this information is limited to authorized personnel and service providers who need it to operate, support, or improve Reluvia, subject to appropriate safeguards.
Limit use of sensitive personal information. Where applicable under California law, you have the right to request that we limit the use and disclosure of your sensitive personal information to that which is necessary to provide the Reluvia services or as otherwise permitted by law. You may exercise this right by contacting us at help@reluvia.app or through any privacy controls made available within the app.
Retention. We retain personal information in accordance with the retention practices described in the “How Long We Keep Your Data” section of this Privacy Notice.
Your U.S. state privacy rights. Depending on your state, you may have the right to:
We do not offer financial incentives in exchange for personal information.
To exercise your rights, contact us at help@reluvia.app or use any privacy request tools available in Reluvia. We may need to verify your identity before responding. If you use an authorized agent, we may also request proof of authorization and, where permitted, ask you to verify your identity directly.
We will respond within the timeframe required by applicable law. If we are unable to fulfill your request, we will explain why and provide appeal information where required.
Reluvia is intended for users aged 18 or older. We do not knowingly sell or share personal information of users under 18.