Privacy Policy · NALYVA

In short

We collect as little as NALYVA needs to work. Nothing is used for advertising, and we never sell data.
Adults and children can create an account with Apple, Google, or an email address and a password. With Apple or Google we receive a name, an email address (or an Apple relay address) and a sign-in ID, and never see your Apple or Google password. With email, we store your password only in a scrambled form (a hash) that nobody can read.
A child profile holds a name, an age range, an avatar and progress. No photo and no date of birth. A child who creates their own account also has the email address or the Apple or Google sign-in they used.
A child who creates their own account gives only a name, an age range, an avatar and the email address or sign-in they chose.
No ads, no third-party tracking, no stored location. SOS works on your phone and never sends your position.
You can export your data and delete your account in the App, or at nalyva.com/delete-account.

1. Who we are and how to contact us

This policy explains how TERRE M'AIR PROD handles personal data in the NALYVA mobile app for iOS and Android (the "App") and on the website at nalyva.com (the "Website"). Together they are the "Service".

TERRE M'AIR PROD is a business registered in the Monaco Trade and Industry Register (RCI) under number 15P08582, with its registered office at 14 Rue Honoré Labande, 98000 Monaco ("NALYVA", "we", "us"). We are the controller of the personal data described here.

Privacy questions and requests: support@nalyva.com, or by post to the address above, marked "Data protection".
Help with the App: support@nalyva.com.
Our representative in the European Union: TERRE M'AIR PROD (M. PEROUMAL SYLVAIN), 14 Rue Honoré Labande, 98000 Monaco, support@nalyva.com.
Our representative in the United Kingdom: TERRE M'AIR PROD (M. PEROUMAL SYLVAIN), 14 Rue Honoré Labande, 98000 Monaco, support@nalyva.com.

You can contact our representatives about any data-protection matter.

2. Who this policy covers

This policy covers adults and children who create an account, children who use a profile on a parent's phone, children who use a linked phone, people who write to us, and visitors to the Website.

It does not cover what Apple or Google do with data on their side, for example when you sign in with them or buy through their store. Their own privacy policies apply to that.

3. The data we collect, by type of user

We collect only the data in this table. We never ask a child for an email address, a phone number, a photo or a date of birth.

Data	Why we use it	Legal basis	How long we keep it
Account (an adult, or a child who creates their own account)
If you sign in with Apple or Google: your name, your email address (or an Apple private relay address) and a sign-in ID. We never receive your Apple or Google password. If you sign up with email: the name you type, your email address and your password, which we store only as a hash that nobody can read. We send a 6-digit code to confirm the address or reset the password. A code works for 15 minutes.	To create your account, keep you signed in and send you the few emails the Service needs (section 10).	Performance of our contract with you (the Terms of Use).	While your account exists. Deleted as soon as the account is deleted, and from backups within 30 days.
What you choose in About you: how you would like to be named, an optional family name and an avatar (a sea animal or your initials).	To greet you and show your family, for example "The Duran family".	Performance of the contract.	As above.
Account details: country, language, the date the account was created and the version of the Terms you accepted.	To show content in your language and to know which Terms apply.	Performance of the contract. Legitimate interest in keeping a record of accepted Terms.	As above.
Your own learning: lessons, quiz answers, 30 seconds to save tries, points, streak and badges. Parents earn points too.	To show your progress.	Performance of the contract.	As above.
Child profile on the parent's phone
Entered by the parent: the child's name (any name, a nickname is fine), age range (4 to 6, 7 to 9 or 10 to 13) and avatar.	To let the child learn with their own profile and let the parent follow their progress.	Performance of our contract with the parent. Legitimate interest of the parent and the child in the child's water-safety learning.	While the profile exists. Deleted when the parent removes the child or deletes the account, and from backups within 30 days.
The child's learning: lessons, quiz answers, 30 seconds to save tries, points, streak, badges, missions and the Water Passport.	To show progress, award badges and give the right 30 seconds to save situation each day.	As above.	As above.
A record that the safety promise was accepted on the phone (date and version), saved when the child profile is created.	To show that the family accepted how NALYVA is meant to be used.	Legitimate interest in keeping this record.	While the child profile exists.
Child using a linked phone
The same child profile as above, plus a device token that ties the phone to the profile, the type of phone, the date it was linked and when it was last active. The 6-digit or QR link code is used once and expires after 10 minutes.	To let the child use their family profile on their own phone, and let the parent see and unlink the phone.	Performance of our contract with the parent. Legitimate interest.	Until the parent unlinks the phone, removes the child or deletes the account. Link codes are deleted when they expire.
Before signing in
A random ID, a device token and progress (lessons, quiz answers, 30 seconds to save tries, points, streak and badges). No name, no contact details.	To let someone learn before they create an account, and to move that progress into their profile when they do.	Legitimate interest in learning water safety, with the smallest possible data.	Deleted when the person signs in or joins a family (the progress moves to their profile). A random ID with no activity for 12 months is deleted.
Everyone who uses the App
Country detection: your IP address is used once to find your country (section 6). Only the country is kept, on your phone.	To show the right emergency number and content for your country.	Legitimate interest in showing the right emergency number.	The IP address is not kept for this purpose. The country stays on the phone.
Notifications: a push token and your notification settings.	To send the notifications you allow (section 8).	Consent, given through your phone's permission and the App settings.	Until you turn notifications off, the token changes, or the profile is deleted.
Search: the words you type in Search. Recent searches stay on your phone.	To find answers in NALYVA's own content.	Performance of the contract.	Not kept after the answer is returned.
Technical data: IP address, type of phone, operating system, app version, language, time of requests, and error reports.	To run the Service securely, stop abuse and fix problems.	Legitimate interest in a secure, working service.	90 days.
Purchases and messages
NALYVA+ status from Apple or Google: product, period, renewal date, store transaction ID and whether the subscription is active, in grace or ended.	To open NALYVA+ for the whole family and help with purchase questions.	Performance of the contract. Legal obligation for accounting records.	While the account exists, then for the period accounting law requires (10 years in Monaco).
Messages you send us through the contact form or by email: topic, your email address, your message and any story you choose to share.	To answer you, and to publish a story only if you agree.	Legitimate interest in answering you. Consent for publishing a story.	12 months after the last message. A published story stays until you ask us to remove it.
Data export and deletion requests: the date of the request and the address we sent the email to.	To deliver your export and show that we handled your request.	Legal obligation.	12 months. The export link works for 7 days.

What you must give us. To open an account, you give an email address and a password, or Apple or Google share your name and an email address with us. An adult then chooses a name to be shown. A child who creates their own account gives a name, an age range and an avatar. To create a child profile, you give a name, an age range and an avatar. Everything else is optional, and saying no only turns off the feature that needs it. Without an account you can still use SOS and the safety information.

4. What we never do

No advertising of any kind, and no advertising identifiers (IDFA or Android advertising ID).
No third-party tracking or analytics tools, and no tracking across other apps or websites.
No selling or renting of personal data.
No photos, videos or voice recordings of children.
No stored location.
No hardware identifiers such as IMEI, serial number or MAC address.
No contacts, no health data, no card details.
No chat, no messaging between users, no public profiles, and no posting in the App.
No profiling and no automated decisions with legal or similar effects. Children are never ranked.

5. Children

NALYVA is made for children of about 4 to 13 and their families. We designed it so that children share as little as possible.

A child can create their own account, in the same way as an adult: with Apple, Google, or an email address and a password. They then choose a name, an age range and an avatar. We ask for nothing else.
On the parent's phone, a child uses the profile the parent created.
On a linked phone, the child types or scans a one-time code from the parent's phone. The phone then uses the same profile. The parent can unlink it at any time in Family.
Before signing in, the App keeps progress under a random ID, with no name and no contact details. When the child signs in or joins a family, that progress moves into their profile and the random ID is deleted.

No consent screen, no age question. The App does not ask for anyone's age and does not show a parental consent screen. Instead, before anyone uses the App, it shows our safety promise: NALYVA teaches and never replaces a lifeguard or a teacher, children go near water only with an adult watching, and in an emergency you call first. When a parent creates a child profile, we record that the promise was accepted. Because we do not know who uses the App, we treat everyone the same way: no ads, no tracking and minimal data for all.

What parents can do. In the App, a parent can see and change each child's name, age range and avatar, remove a child, unlink a child's phone, export the family's data and delete the whole family. You can also write to support@nalyva.com.

Purchases. A child can see the NALYVA+ screen. Any purchase goes through the Apple or Google account on the phone, where the store's family controls apply, such as Ask to Buy. We never receive payment details.

No pressure. Points, streaks and badges only show learning. Missing a day never removes progress, and our notifications are designed not to nag.

6. How we find your country

NALYVA needs your country to show the right emergency number. It tries these sources in order and stops at the first one that works:

the country of your mobile network, read on the phone
the country of your internet connection, found from your IP address with the DB-IP database
your phone's time zone
your phone's region setting

For step 2, the IP address is used only to find the country and is not kept for this purpose. We credit DB-IP (db-ip.com) in About NALYVA, as its licence requires. The country is saved on your phone. You can change it at any time on the safety promise screen or in Settings, Country.

7. SOS and location

SOS works without an internet connection. The emergency numbers are built into the App and refreshed from our server when you are online. SOS never calls anyone by itself. Call opens your phone's call screen and you press call.

Where SOS offers to show your position, it asks for location permission first, only while you use it. Your position is read on your phone and shown on your screen, so you can read it out to the emergency operator, copy it or share it yourself. It is never stored and never sent to us, to the emergency services or to anyone else by the App. If you refuse the permission, SOS still shows the number.

We do not record who opened SOS, when or where.

8. Notifications and camera

Notifications. The App asks before sending notifications. NALYVA Watch asks the first time you start a Watch. The kinds of notifications are:

NALYVA Watch: "2 minutes left" and the end alarm. These are set on your phone. Nothing about a Watch is sent to us or kept after it ends.
The daily 30 seconds to save reminder, set on your phone, only if today's try is not done.
A live stream starting (NALYVA+ members), a badge earned, new content (off unless you turn it on) and a NALYVA+ payment problem. These are sent from our server using a push token, through Apple's and Google's push services.

You can turn each kind on or off in the App (Settings, Notifications) or in your phone settings. Emergency features never depend on notifications.

Camera. A child's phone can scan the QR code on the parent's phone to join the family. The camera is asked for only then, and only reads the code. No picture is kept or sent. Typing the 6 digits works just as well.

Microphone. The App does not use the microphone. Search works by typing.

Live streams. When you open a live stream, it opens on the platform that hosts it (for example YouTube) in the in-app browser. We do not send that platform any data about you or your family. What the platform collects while you watch is covered by its own privacy policy. The stream link, the champions and the partners shown in the App come from our content and contain no personal data.

9. Purchases

NALYVA+ is sold only through Apple In-App Purchase and Google Play Billing. Apple or Google take the payment. We receive only the subscription status from the store: which plan, when it renews, the store transaction ID and whether it is active, in its 3-day grace period or ended. We never receive your card or bank details. Apple and Google handle your payment data under their own privacy policies.

10. Emails

We send only emails the Service needs, to your account's email address: the codes that confirm your address or reset your password, your data export link, the confirmation that your account was deleted, and our answers to your messages. We send no marketing emails. Our emails load no remote images and contain no tracking pixels.

11. Who processes data for us, and transfers

We share personal data only with these service providers, and only what each one needs. Each is bound by contract to protect it at least as well as this policy does and to use it only on our instructions. We do not share personal data with anyone for their own marketing.

Provider	What they receive	Why	Where
DigitalOcean	All data we store (section 3), encrypted	To run our servers and database	Frankfurt, Germany (EU)
DigitalOcean Spaces and its CDN	IP address and the picture or file requested	To deliver lessons and pictures quickly	Stored in Frankfurt, Germany (EU). Delivered from the CDN location nearest to you
Resend	Your email address and the email content	To send sign-in codes and export, deletion and support emails	Ireland (EU)
Sentry	Technical data and error reports, with no name or email address	To fix crashes	European Union
Apple and Google	Sign-in, purchase and push notification data	Sign-in, payments, notifications and app distribution	Under their own terms and privacy policies, as independent controllers
Authorities	Only what the law requires	To meet a legal obligation or protect someone's life	Assessed case by case
A company that takes over NALYVA	The data needed to continue the Service	If the Service is transferred	We will tell you first. The new operator must follow this policy.

Transfers. NALYVA is established in Monaco, outside the European Economic Area and the United Kingdom. Our data is hosted in the European Union. When our team in Monaco accesses it, or when a provider processes data outside the EU or UK, we use the safeguards the law requires, such as the European Commission's standard contractual clauses and the UK addendum. Transfers from Monaco follow Monaco Law no. 1.565. You can ask for a copy of these safeguards at support@nalyva.com.

12. How long we keep data

We keep data only as long as we need it. The periods for each type of data are in the table in section 3. In summary:

Account, child profiles and progress: while they exist. After deletion, removed from our servers straight away and from backups within 30 days.
Progress kept before signing in: deleted when the person signs in or joins a family, or after 12 months without activity.
Technical data: 90 days.
Subscription records: for the period accounting law requires (10 years in Monaco).
Messages to us: 12 months after the last message.
NALYVA Watch: nothing is kept after a Watch ends.

13. Security

Data is encrypted in transit (TLS) and at rest. Only the people who need access for their work have it, and their access is logged. Link codes work once and for 10 minutes, a new code cancels the old one, and the number of codes a phone can request is limited. We keep backups and test them. When you delete your account, we also revoke NALYVA's access to your Apple or Google sign-in. Passwords are stored only as a hash. Email codes work for 15 minutes and for a limited number of tries. No system is perfectly secure. If a breach is likely to put you or your children at risk, we will tell you without undue delay and notify the competent authority within 72 hours where the law requires it.

14. Your rights

Under Monaco Law no. 1.565, the EU GDPR and the UK GDPR, you have the right to:

see the data we hold about you and your children
have it corrected
have it deleted
receive it in a portable format
object to processing based on legitimate interest, or ask us to restrict it
withdraw consent at any time, for example by turning off notifications, without affecting what happened before

How to use them. The quickest way is in the App:

Change your name, family name or avatar: Account, then Edit your profile.
Change or remove a child: Family, then the child, then Edit.
Export your family's data: Account, then Export my family's data. We email a download link to your account address within 24 hours. It works for 7 days.
Delete your data: see section 15.

You can also write to support@nalyva.com. We answer within one month. For complex requests we may extend this by two more months and will tell you why. To protect your family, we may ask you to confirm your identity by signing in, or with a code sent to your account's email address.

15. Delete your data

Delete your account in the App

Open NALYVA on the phone where you signed in.
Go to Account, then Delete account.
Confirm who you are: with Apple or Google, or with your password if you signed up with email.
Tap Delete everything.

This deletes your adult account and every child profile in your family, with their progress, points, badges and Water Passports. Linked children's phones stop working. We email you a confirmation. You need an internet connection to delete your account.

Deleting your account does not cancel NALYVA+. Cancel it first in your Apple account or Google Play subscriptions. The delete screen has a link to do this.

Remove a single child

Go to Family, open the child, tap Edit, then Remove. The child's profile, progress, badges and Water Passport are deleted at once, and any linked phone is unlinked.

A child with their own account

A child's own account is deleted in the same way as any account, in the App or by writing to support@nalyva.com from the account's email address. A parent can also ask us to delete it.

If you no longer have the App

Go to nalyva.com/delete-account and follow the steps, or email support@nalyva.com from the email address of your account. If you used Apple's "Hide My Email", give us the relay address. We confirm the request with you at that address before we delete anything, then delete the account and all its child profiles.

What we keep, and for how long

Deleted data is removed from our servers straight away and from backups within 30 days. After that, we keep only:

subscription records, for the period accounting law requires (10 years in Monaco)
a record of your deletion request, for 12 months, to show we handled it
messages you sent us, for 12 months after the last one

We keep nothing that could be used to rebuild a profile.

16. Website and cookies

The Website sets no cookies and uses no analytics, advertising or social media trackers, so it shows no cookie banner. Like any web server, our hosting provider records standard access logs (IP address, time and page requested) for security. We keep them for 30 days.

17. Changes to this policy

We may update this policy. The version and effective date are at the top. For important changes, we tell you in the App before they apply. Earlier versions are available on request at support@nalyva.com.

18. Complaints

If you are not happy with how we handle your data, please write to us first at support@nalyva.com. You can also complain to a data-protection authority:

Monaco: Autorité de Protection des Données Personnelles (APDP), which replaced the Commission de Contrôle des Informations Nominatives (CCIN), Le Concorde, 11 rue du Gabian, 98000 Monaco, apdp.mc
France: CNIL (cnil.fr)
Italy: Garante per la protezione dei dati personali (garanteprivacy.it)
Spain: Agencia Española de Protección de Datos (aepd.es)
Portugal: Comissão Nacional de Proteção de Dados (cnpd.pt)
United Kingdom: Information Commissioner's Office (ico.org.uk)
Other EU countries: the data-protection authority where you live or work

19. Contact

TERRE M'AIR PROD, 14 Rue Honoré Labande, 98000 Monaco. Registered in the Monaco Trade and Industry Register (RCI) under number 15P08582.

Email, for privacy, support and legal questions: support@nalyva.com
EU representative: TERRE M'AIR PROD (M. PEROUMAL SYLVAIN), 14 Rue Honoré Labande, 98000 Monaco, support@nalyva.com
UK representative: TERRE M'AIR PROD (M. PEROUMAL SYLVAIN), 14 Rue Honoré Labande, 98000 Monaco, support@nalyva.com