Privacy policy

NETARIO Sp. z o.o. (a Polish limited liability company), trading under the Elvonio brand, publisher of Elveno.
ul. Wiślana 3B, 05-092 Łomianki, Poland.
Polish commercial register (KRS): 0000952214 · tax ID: 1182236570 · EU VAT: PL1182236570.
District Court for the Capital City of Warsaw in Warsaw, XIV Commercial Division of the National Court Register. Share capital: PLN 5,000.
Represented by Rafał Kochański, President of the Management Board.
Email: kontakt@netario.pl · phone: +48 533 267 070.

We are the controller for personal data relating to Elveno and these pages. For any privacy question, contact kontakt@netario.pl. This policy covers the app, audio delivery, Premium, optional analytics and correspondence. Elveno is currently being tested; purchase information also covers purchases once sales become available in the relevant store.

Favourites, practice history, completion markers, achievements, playback positions, settings and downloaded files are stored on your device. We do not upload those local lists or your practice history to our own user database. Elveno does not require a named account. Device backups may depend on your Apple or Google settings. Removing the app does not necessarily remove system keychain entries or system backups.

When you download content, the service processes your IP address, request date and time, requested resource, response status and technical connection details. The installation uses a key and a pseudonymous identifier to check access. Cloudflare delivers files, protects the service and limits excessive traffic. The resource requested may identify the selected meditation. We do not record your microphone, read contacts or precise location, or obtain data from Apple Health or Health Connect.

If you use purchases, Apple or Google and RevenueCat process transaction and product identifiers, purchase history, subscription dates and status, renewals, refunds and the installation identifier. This enables access, purchase restoration, entitlement checks and sales analysis. We do not receive your full card number or store password. We do not provide RevenueCat with your name or email as profile attributes. Stores also process account and payment information as independent controllers.

PostHog analytics are off by default. If you enable them in Settings → Usage statistics, we send a random analytics identifier, event time, app openings, session starts or endings, listening duration, completion-marker changes, offer views and purchase starts, meditation identifier and category, and app version. We discard IP addresses from stored events and disable location enrichment. Your IP is technically available when a connection is made. We do not record screens, automatically capture every click, or use this information for advertising.

Refusing analytics does not block practice or purchases. Withdrawing consent stops new events and removes the local queue and analytics identifier. It does not automatically erase events already sent. Enabling analytics again creates a new identifier.

• Delivering content and the access you request: performance of a contract or steps before a contract — Article 6(1)(b) GDPR.
• Optional usage analytics: consent — Article 6(1)(a) GDPR.
• Security, abuse prevention, aggregate sales analysis and legal claims: legitimate interests in protecting and operating the service — Article 6(1)(f) GDPR.
• Questions: steps you request or our legitimate interest in responding; complaints and accounting duties: the applicable legal obligation — Article 6(1)(b), (c) or (f) GDPR, depending on the matter.

Technical information needed to connect and verify access is necessary for those functions. Analytics and optional correspondence are not a condition of basic app use. We do not make decisions with legal effects based solely on automated profiling.

Authorised personnel and providers receive data only as needed: Cloudflare (media and security), RevenueCat (subscriptions), PostHog (consented analytics), SEOHOST (hosting these pages), the email provider handling our contact address and, where needed, advisers and competent authorities. We do not sell data or disclose it to advertising partners.

Audio storage in R2 and our PostHog project are in the EU. This does not mean that every infrastructure or support operation takes place solely in the EEA. RevenueCat and global providers may process information in the United States and other countries. Transfers outside the EEA use appropriate mechanisms, in particular standard contractual clauses or a valid adequacy decision where applicable. Contact us for information about the applicable safeguards and a copy.

• Local data: until cleared, files removed or the app deleted; device backups and keychain entries may remain under system settings.
• Purchase and access records: while needed for entitlement management, restoration and settlement; longer only where law or legal claims require it.
• Analytics: for the period necessary to compare usage and improve the app. Our current PostHog Free plan has a standard one-year retention period; this is not a promise that all copies are erased immediately on the anniversary. Earlier deletion can be requested as described below.
• Server logs: under the provider’s rotation and retention arrangements, as needed for security and troubleshooting; records of a specific incident may remain until it is resolved.
• Correspondence: until the matter is resolved, then as needed for legal obligations or claims. Tax records are kept for the statutory period where such a duty arises.

We do not keep data indefinitely merely because it might become useful. Backups are deleted or overwritten within the relevant provider’s backup cycle.

Subject to the GDPR, you may request access, rectification, erasure, restriction and portability. You may object to processing based on legitimate interests and withdraw consent at any time. Withdrawal does not affect the lawfulness of earlier processing. You may complain to the President of Poland’s Personal Data Protection Office (uodo.gov.pl) or the competent authority where you live.

For access or deletion, email kontakt@netario.pl, preferably with the subject “Elveno — personal data”. Describe your request and provide only what is necessary to locate records, such as the platform, approximate purchase date and a transaction or installation identifier if you have one. Do not send passwords, full card details or an identity-document scan. If we cannot link pseudonymous records to you, we will explain and request only necessary additional information. We normally respond within one month and explain any lawful extension.

Deleting data does not cancel a subscription. Records required by law or for legal claims may remain; we will explain the scope and basis. We cannot erase Apple’s or Google’s independent records on their behalf.

These pages contain no analytics, ads, embedded media or forms, and set no first-party cookies or browser identifiers. Hosting processes connection information, including IP addresses and requested URLs. External links lead to services governed by their own terms. An email reaches us only after you send it from your email program.

Elveno is intended for adults; we do not knowingly collect children’s personal data. If reported, we will investigate and take appropriate action. Material changes will be communicated in the app or when using the service. The current version and date are shown here. Contact: kontakt@netario.pl.