Privacy Policy
Effective: 2 June 2025
This Privacy Policy explains how Appwheel Ventures – a private company incorporated in 
The Netherlands with its registered address at Gentiaan 26, 2631 VC Nootdorp, The Netherlands ("the Company", "we", "our", or "us") – collects, uses, discloses, and safeguards personal data when you ("you" or "User") use the Floreo mobile application and related services (collectively, the "Service").
By using the Service you acknowledge that you have read and understood this Privacy Policy.
1. Interpretation and Definitions
Interpretation — Headings are for convenience only and do not affect interpretation. Words importing the singular include the plural and vice‑versa.
Definitions
Account: a unique profile created for you to access the Service.Affiliate: any entity that controls, is controlled by, or is under common control with the Company.
App Stores: Apple App Store, Google Play, and any other storefronts through which the App is distributed.
Controller: the natural or legal person who determines the purposes and means of processing Personal Data; here, Appwheel Ventures.
Cookies / SDK Identifiers: small data files or mobile‑SDK identifiers stored on your Device.
Device: any device that can access the Service such as a smartphone or tablet.
Personal Data: any information relating to an identified or identifiable natural person.
Processor / Service Provider: a third party that processes Personal Data on our behalf.
Usage Data: data collected automatically through the Service or its infrastructure (for example, session length, in‑app actions, crash logs).
2. Data Controller
Appwheel Ventures is the data controller responsible for your Personal Data.
Email: privacy@floreo.app
Address: Gentiaan 26, 2631 VC Nootdorp, The Netherlands
3. Personal Data We Collect
Specific items: Email address, name (optional), phone number (optional), in‑app user ID
Why we collect it: Create and secure your Account, personalise communications, authenticate you, send password‑reset or verification codes
Category: Subscription & Transaction Data
Specific items: App‑store purchase receipts, subscription status, product tier, country, currency
Why we collect it: Verify paid access, manage renewals, handle refunds, comply with tax rules
Category: Device & Usage Data
Specific items: Device model, OS version, app version, IP (truncated/hashed), time zone, language, in‑app events (e.g., "entry_saved"), session duration, crash logs
Why we collect it: Maintain and improve the Service, debug issues, detect fraud, compile aggregated statistics
Category: Support Records
Specific items: Contents of support emails, metadata, attachments
Why we collect it: Respond to inquiries, resolve complaints
We do not request your postal address, payment‑card number, sexual orientation, health, or any other special‑category data.
4. Legal Bases for Processing (GDPR)
We process Personal Data on one or more of the following bases:
Contract – to provide and maintain the Service (Art. 6 (1)(b)).
Legitimate Interests – to improve the Service, prevent fraud, and defend legal claims (Art. 6 (1)(f)).
Legal Obligation – to comply with tax, accounting, and consumer‑protection laws (Art. 6 (1)(c)).
Consent – for optional marketing notifications or analytics where required (Art. 6 (1)(a)). You may withdraw consent at any time in the App settings.
5. How We Use Your Data
Provide the Service – authenticate you, sync journal entries, manage subscriptions.
Analytics & Performance – understand feature usage, app health, and user flows.
Payment Administration – verify subscriptions, detect chargebacks, process refunds.
Communications – send transactional emails or push notifications (e.g., payment receipts, security alerts).
Development & Security – debug, prevent abuse, and monitor Service integrity.
Marketing (optional) – send news or promotions similar to your subscription, unless you opt out.
6. Sharing of Personal Data
We only share Personal Data with the following categories of recipients and always under appropriate data‑protection agreements:
Infrastructure & Hosting Providers – cloud platforms that host our databases and servers.
Payment & Subscription Processors (e.g., RevenueCat) – entities that validate in‑app purchases and manage subscription status.
Analytics & Crash‑Reporting Providers – services that help us understand app performance and improve stability.
Customer‑Support Tools – email or ticketing systems used to respond to your requests.
Professional Advisors & Authorities – lawyers, auditors, and regulators when required by law or necessary to protect our rights.
We do not sell or rent your Personal Data, and we do not allow advertising networks to track you across third‑party apps.
7. International Transfers
Some processors are located outside the European Economic Area. When we transfer data internationally we rely on Standard Contractual Clauses or an equivalent lawful mechanism and adopt additional safeguards such as encryption in transit and at rest.
8. Cookies & Tracking Technologies
Floreo is a native mobile app. We use SDK‑level identifiers (analogous to cookies) solely for analytics, crash reporting, and subscription validation. You can reset your mobile advertising identifier or restrict tracking via your Device settings.
9. Data Retention
The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.
10. Your Rights
Subject to verification of identity, you have the right to:
- Access your Personal Data.
- Rectify inaccurate or incomplete data.
- Erase data ("right to be forgotten").
- Restrict processing.
- Data Portability – receive a copy in a machine‑readable format.
- Object to processing based on legitimate interests or direct marketing.
- Withdraw Consent at any time without affecting prior processing.
To exercise any right, use the in‑app Delete Account function or email privacy@floreo.app. We will respond within 30 days.
11. Security
We use industry‑standard technical and organisational measures – TLS encryption in transit, database encryption at rest, least‑privilege access controls, regular security audits – but no system is 100 % secure. You are responsible for keeping your credentials confidential.
12. Children's Privacy
The Service is not directed at children under 16. We do not knowingly collect Personal Data from anyone under 16. If you believe a child has provided us data, contact privacy@floreo.app and we will delete it.
13. Third‑Party Links
The Service may contain links to external sites. We have no control over and are not responsible for their privacy practices. Review their policies before providing data.
14. Changes to This Policy
We may update this Policy periodically. Material changes will be announced via an in‑app banner or email 14 days before they take effect. The "Effective" date above shows the latest revision.
15. Contact
If you have questions about this Privacy Policy or wish to exercise your rights:
Email: privacy@floreo.app
Address: Appwheel Ventures, Gentiaan 26, 2631 VC Nootdorp, The Netherlands