Lovon – Privacy Policy

Effective Date: December 12, 2025

BABAYAGA Inc. ("BABAYAGA", "Lovon", "we", "us", "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and protect your information when you use the Lovon mobile applications, websites, and related services (the "Service").

1. Scope and Relationship to the Service

By using the Service, you agree to the collection and use of your information as described in this Privacy Policy. If you do not agree, please do not use the Service.

This Policy applies to all users, including those located in the United States, the European Economic Area (EEA), the United Kingdom, and other regions.

2. Information We Collect

2.1 Information You Provide

  • Account information: email address, username, password, and other registration details.

  • Profile and onboarding information: information about your goals, concerns, relationships, and other context you choose to share.

  • Health-related information: if you choose to share it, information about mental health diagnoses, medications, symptoms, or other health-related details. This may be considered sensitive or "special category" data under some laws.

  • Session content: audio from your calls with the AI, transcripts of those calls, chat messages (if any), reflections, and notes you add in the app.

2.2 Information Collected Automatically

  • Device and technical information: IP address, device type, operating system, app version, unique identifiers, language, and time zone.

  • Usage data: how you use the Service, including session duration, interaction patterns, features you access, performance and crash logs.

2.3 Information from Third Parties

We may receive information from:

  • Payment processors (e.g., Stripe, Paddle): payment status, subscription details, and limited billing information (we do not store full card numbers).

  • Voice and AI providers (e.g., voice interface platforms, large language model providers): technical logs and output needed to operate the Service.

  • Analytics and attribution providers: information about how you discovered the Service and how you interact with it.

3. How We Use Your Information

We use your information to:

  • Provide and maintain the Service, including running AI conversations, generating session summaries, and delivering daily check-ins.

  • Personalize your experience, including tailoring prompts, nudges, and content to your goals and prior usage.

  • Improve and develop the Service, including analyzing usage trends, testing features, and enhancing AI models (for example, by reviewing de-identified or pseudonymized transcripts for quality and training purposes).

  • Communicate with you, including sending important service-related notices, updates, security alerts, and support responses.

  • Process payments and manage subscriptions.

  • Comply with legal obligations, enforce our Terms of Use, and protect our rights, safety, and the rights and safety of others.

If required by law (for example in the EEA/UK), we rely on one or more of the following legal bases:

  • your consent, particularly for processing health-related or other sensitive data;

  • performance of a contract (providing the Service you requested);

  • our legitimate interests (e.g., improving and securing the Service);

  • compliance with legal obligations.

4. Health-Related Information

You are not required to share any health-related information to use the Service, but the Service may be more personalized if you choose to do so.

If you are located in the EEA/UK or another region with similar laws, we will seek your explicit consent before processing health-related data about you for the purposes described in this Policy. You may withdraw your consent at any time by contacting us; however, this may limit your ability to use certain features.

Lovon is not a healthcare provider or a "covered entity" under U.S. HIPAA rules, and the information you share with us is generally not protected by HIPAA as medical records would be. We nonetheless treat your data as sensitive and apply appropriate safeguards.

5. Use of AI and Third-Party Providers

To provide voice and AI features, we may send portions of your audio, transcripts, and related data to third-party service providers that power our voice interface and AI models. These providers process your data on our behalf and are bound by contractual obligations to protect your information and use it only for the purposes we specify.

We may use de-identified or pseudonymized session data to train, fine-tune, and evaluate AI models and to improve the Service. When we do so, we take steps to remove or reduce direct identifiers where feasible.

Where required by law or where reasonably feasible, you may request that your session data not be used to improve our models (beyond what is necessary to provide the Service), by contacting us at support@lovon.app.

6. How We Share Your Information

We do not sell your personal information. We may share your information with:

  • Service providers and processors who help us operate the Service (e.g., hosting, cloud storage, analytics, customer support, voice and AI providers, payment processors).

  • Professional advisors (e.g., legal, accounting) when necessary to protect our business.

  • Authorities, regulators, or law enforcement when we believe disclosure is required by law, regulation, or legal process, or to protect our rights, safety, or the rights and safety of others.

  • Business transferees in connection with a merger, acquisition, financing, or sale of all or part of our business.

If we share de-identified or aggregated data, we will ensure it does not reasonably identify you.

7. International Data Transfers

We are based in the United States, and your information may be stored and processed in the United States and other countries.

For users in the EEA/UK, when we transfer your personal data outside of the EEA/UK, we use appropriate safeguards such as the European Commission's Standard Contractual Clauses or equivalent mechanisms, where required by law.

8. Data Retention

We retain your personal data for as long as reasonably necessary to provide the Service, fulfill the purposes described in this Policy, and comply with legal obligations.

In general, we may retain account-related data while your account is active and delete or de-identify it within 24 months after your account becomes inactive, unless a longer retention period is required or permitted by law.

We may retain de-identified or aggregated data for analytics and service improvement.

9. Your Rights and Choices

Depending on where you live, you may have some or all of the following rights:

  • Access: request a copy of the personal data we hold about you.

  • Correction: request that we correct inaccurate or incomplete data.

  • Deletion: request that we delete your personal data, subject to legal exceptions.

  • Restriction: request that we limit certain types of processing.

  • Portability: request a machine-readable copy of certain data.

  • Withdraw consent: where processing is based on your consent, you may withdraw that consent at any time.

To exercise these rights, contact us at support@lovon.app. We may need to verify your identity before responding.

You may also have the right to lodge a complaint with your local data protection authority.

10. Security

We use reasonable technical and organizational measures to protect your personal data, including encryption in transit and at rest where appropriate. However, no system is completely secure, and we cannot guarantee absolute security.

11. Children's Privacy

The Service is not intended for children under 13 years of age, and we do not knowingly collect personal data from children under 13. If we learn that we have collected such data, we will take steps to delete it.

12. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes, we will notify you by updating the "Effective Date" at the top and, where appropriate, through the Service or by email.

Your continued use of the Service after the updated Policy becomes effective constitutes your acceptance of the changes.

13. Contact Us

BABAYAGA Inc. 221 W 9th St Unit 363 Wilmington, DE 19801 United States Email: support@lovon.app