Contents
- Scope
- 18+ Requirement
- Information We Collect
- UGC and Safety Moderation
- How We Use Information
- GDPR Legal Bases
- How We Share Information
- Payments
- International Transfers
- Data Retention
- Security
- Your Rights
- Third-Party Services
- Changes to This Policy
1. Scope
This Privacy Policy explains how Firva gathers, processes, retains, distributes, and safeguards personal data when you use the app, our mobile web pages, customer support channels, and other related services linked to this policy. By using Firva, you acknowledge that you have read this policy and understand how we handle information.
Firva is designed for adults only. It may include account features, communications, user-generated content, community interaction, reporting tools, and moderation functions intended to keep the service safe, lawful, and consistent with platform rules.
2. Adults-Only Service
Firva is not directed to children and may not be used by anyone under the age of 18. By accessing or using the service, you represent that you are at least 18 years old and legally able to agree to this Privacy Policy and the applicable Terms of Use.
If we learn that a person under 18 has provided personal data or is using the service, we may restrict access, remove content, close the account, and delete or minimize associated data unless retention is legally required.
3. Information We Collect
3.1 Information you provide directly
- Registration data, profile details, sign-in credentials, and account preferences.
- Messages, posts, comments, uploads, reports, appeals, support requests, and other content you submit.
- Identity or eligibility confirmations that may be required to enforce our 18+ access rule, platform safety standards, or legal obligations.
- Communications you send to us by email or through in-app support features.
3.2 Information collected automatically
- Device type, operating system, app version, language, time zone, network information, crash data, diagnostic data, unique device or installation identifiers, and approximate location inferred from IP address or device settings where permitted.
- Usage information, such as session activity, interactions with features, preferences, taps, navigation paths, error logs, moderation events, and security signals.
3.3 Information from other sources
- Information from service providers that support authentication, hosting, analytics, moderation, anti-abuse controls, customer support, security, or legal compliance.
- Information from platform providers such as Apple where required to distribute, secure, or support the app.
3.4 Sensitive or special category data
Please do not submit sensitive personal data unless we explicitly request it for a lawful purpose. You must not upload or disclose objectionable content, graphic material, hateful or discriminatory material, or other prohibited content through the service.
4. User-Generated Content and Safety Moderation
Firva may allow users to create, upload, transmit, or display user-generated content, including text, images, profile information, reports, and other materials. Because safety is essential, we may use human review, automated tools, keyword filters, risk scoring, account verification measures, reporting workflows, and other reasonable controls to detect, review, restrict, hide, remove, or preserve content and behavior that may violate our rules or applicable law.
We do not tolerate objectionable, abusive, or unlawful content or conduct. This includes content involving exploitation, disturbing material, harassment, bullying, threats, hate speech, discrimination, extremist advocacy, fraud, impersonation, or any content likely to make the service unsafe or unsuitable for adults using it lawfully.
If you submit content, you understand that it may be reviewed for compliance, may be reported by other users, and may be removed without notice where necessary to protect users, enforce our Terms of Use, respond to complaints, or comply with platform rules and legal obligations.
5. How We Use Information
- To provide, operate, maintain, personalize, and improve Firva and its features.
- To create and manage accounts, authenticate users, remember settings, and deliver requested services.
- To publish, host, transmit, rank, review, or moderate user-generated content and related interactions.
- To detect, investigate, prevent, and respond to spam, fraud, suspicious behavior, security incidents, harmful content, and Terms violations.
- To enforce age restrictions, content standards, community rules, legal rights, and platform requirements.
- To provide support, answer inquiries, process reports and appeals, and communicate service updates.
- To comply with legal, regulatory, tax, accounting, audit, and law-enforcement requirements.
- To create aggregated or de-identified analytics that do not reasonably identify you.
6. GDPR Legal Bases
Where the GDPR or similar laws apply, we rely on one or more of the following legal bases to process personal data:
- Contract: when processing is necessary to provide the service you requested, maintain your account, or perform our agreement with you.
- Legitimate interests: when processing is reasonably necessary for security, service improvement, moderation, fraud prevention, analytics, business operations, and protection of our users, rights, and property, provided those interests are not overridden by your rights.
- Consent: when required by law, such as for certain optional communications, device permissions, or specific data uses. You may withdraw consent where applicable.
- Legal obligation: when we must process or retain information to comply with legal duties, lawful requests, or dispute resolution requirements.
7. How We Share Information
We may share personal data with trusted service providers who assist with hosting, analytics, moderation, anti-abuse controls, customer support, security, and legal compliance. We may also share information with platform operators such as Apple, legal authorities when required by law, and professional advisors.
We do not sell your personal data to third parties for their marketing purposes.
8. App Store In-App Purchases and Payment Data
Firva may offer optional digital goods, subscriptions, or premium features through the Apple App Store in-app purchase system. All in-app purchase transactions are processed by Apple. We may receive transaction confirmations, purchase identifiers, subscription status, and related metadata from Apple to validate entitlements, manage access to paid features, provide support, and maintain accurate records.
We do not directly collect or store your payment card details, billing address, or full financial account information. Apple handles payment processing under its own terms and privacy practices.
We may retain purchase-related records as reasonably necessary for account management, entitlement verification, refund processing, fraud prevention, dispute resolution, financial reporting, and legal compliance.
9. International Data Transfers
Your information may be processed in countries other than the one where you live. When required by law, we use appropriate safeguards for cross-border transfers, such as contractual protections, adequacy decisions, or other lawful transfer mechanisms recognized by applicable data protection law.
10. Data Retention
We retain personal data only for as long as reasonably necessary for the purposes described in this policy, including account administration, service delivery, moderation, safety investigations, dispute handling, recordkeeping, and legal compliance. Retention periods may vary depending on the type of data, the nature of the relationship, security and abuse risks, and applicable legal obligations.
Content removed for policy reasons may be retained for a reasonable period to investigate abuse, process appeals, comply with legal duties, or establish, exercise, or defend legal claims.
11. Security
We use reasonable administrative, technical, and organizational measures intended to protect personal data against unauthorized access, loss, misuse, alteration, or disclosure. No internet or storage system is perfectly secure, so we cannot guarantee absolute security.
12. Your Privacy Rights
Depending on your location and applicable law, you may have rights to request access to personal data, correction of inaccurate data, deletion, restriction of processing, portability, objection to certain processing, and withdrawal of consent where processing is based on consent. You may also have the right to lodge a complaint with a competent supervisory authority.
To exercise rights, please contact us at mengat@firvagat.com. We may request information necessary to verify your identity and evaluate the request. Some rights are subject to legal exceptions and may not apply in all circumstances.
13. Third-Party Services
Firva may integrate or link to third-party services, websites, content, or tools. Their privacy practices are governed by their own terms and policies, not this Privacy Policy. We encourage you to review those materials carefully.
14. Changes to This Policy
We may update this Privacy Policy from time to time to reflect operational, legal, technical, or business changes. The updated version becomes effective when posted, unless a different effective date is stated. Your continued use of the service after the revised policy is posted means that you acknowledge the updated policy.