Privacy Policy

1. What this policy covers

This policy applies when you:

• visit the Anka website;
• join the Anka waitlist;
• create or use an Anka account;
• create a goal, habit or challenge;
• invite or interact with supporters;
• send, receive or interact with messages, check-ins, reminders or encouragement;
• take part in research, testing, interviews, surveys or feedback;
• contact us directly.

Anka is an early-stage product. Some features may change over time. If our use of personal data changes significantly, we will update this Privacy Policy.

2. Age requirement

Anka is intended for people aged 18 or over.

You must not use Anka or provide personal data to us if you are under 18.

If we become aware that we have collected personal data from someone under 18, we may delete it and close any related account.

3. Personal data we collect

We may collect the following types of personal data.

Account and contact information

This may include:

• your name;
• email address;
• login details;
• account settings;
• communication preferences.

Waitlist and early access information

If you join the waitlist, request early access, complete a form or answer onboarding questions, we may collect:

• your email address;
• your name, if provided;
• your answers to questions;
• goals, habits or challenges you are interested in;
• information about how you heard about Anka;
• whether you want to take part in testing, interviews or research.

Challenge and supporter information

If you use Anka to create or take part in a challenge, we may collect:

• the goal, habit or challenge you create;
• check-ins, progress updates and reflections;
• messages, reactions, encouragement or comments sent through Anka;
• information about who is involved in a challenge;
• supporter names, email addresses, phone numbers or other contact details, where provided;
• invitation status and interaction data.

You should only provide another person’s contact details if you have a reasonable basis to believe they would be comfortable receiving an invitation from Anka.

Supporter information

If someone invites you to support them on Anka, we may collect:

• your name;
• your email address, phone number or other contact details;
• your invitation status;
• messages, reactions, encouragement or other interactions you provide through Anka.

Research, testing and feedback information

If you take part in user research, testing, interviews, surveys or feedback, we may collect:

• your contact details;
• your responses;
• notes, recordings or transcripts, where we tell you this in advance;
• information about your experience using Anka;
• suggestions, comments or product feedback.

Technical and usage information

When you use Anka or visit the website, we may collect:

• IP address;
• device and browser information;
• approximate location based on IP address;
• pages viewed;
• links clicked;
• referral source;
• dates and times of visits;
• app or website usage data;
• diagnostic, error and performance data;
• cookie and similar technology information.

Communications with us

If you contact us, we may collect:

• your name and contact details;
• the content of your message;
• any information needed to respond to your request.

4. Sensitive information

Some goals, challenges, messages or check-ins may reveal sensitive personal data. This may include information about health, mental health, disability, race or ethnic origin, religious or philosophical beliefs, sex life, sexual orientation, political opinions, or other protected characteristics.

You do not need to provide sensitive personal data to use Anka unless a specific feature clearly asks for it.

Please think carefully before sharing sensitive information in Anka, especially if it will be visible to supporters or other people involved in your challenge.

Where we process special category data under UK data protection law, we will only do so where we have:

• a lawful basis under Article 6 of the UK GDPR; and
• where required, a separate condition under Article 9 of the UK GDPR, such as your explicit consent or another applicable condition.

If we introduce features that intentionally collect sensitive personal data, we will update this Privacy Policy and provide clearer information at the point of collection.

5. How we use personal data

We use personal data to:

• provide, operate and maintain Anka;
• let people join the waitlist;
• provide early access;
• create and manage user accounts;
• let users create goals, habits and challenges;
• let users invite supporters;
• send invitations, check-ins, reminders, encouragement, product updates and service messages;
• show challenge content to the people involved in that challenge;
• respond to questions, feedback and support requests;
• carry out user research and product testing;
• understand whether Anka is useful;
• improve the product, website, onboarding, messaging and user experience;
• analyse usage, performance and conversion;
• monitor, detect, prevent and respond to misuse, abuse, security issues or harmful behaviour;
• comply with legal obligations;
• protect our rights, users, supporters and the service.

6. Lawful bases for using personal data

Under UK data protection law, we need a lawful basis to use personal data. The lawful basis depends on the context.

Contract

We may use personal data where it is necessary to provide Anka to you, including to:

• create and manage your account;
• provide challenge features;
• send service messages;
• enable supporter invitations and interactions;
• provide core product functionality.

Consent

We may rely on consent where you:

• join a marketing or early access mailing list;
• agree to receive optional product updates;
• agree to non-essential cookies or analytics, where required;
• take part in research where consent is appropriate;
• provide special category data where explicit consent is required.

You can withdraw consent at any time by contacting us at anthony.a.paine@gmail.com.

Legitimate interests

We may use personal data where it is necessary for our legitimate interests, provided your rights and interests do not override ours.

This may include:

• improving Anka;
• understanding how people use the website or product;
• analysing signups, usage and product performance;
• responding to feedback and support requests;
• keeping Anka secure;
• preventing misuse, spam, abuse or harmful behaviour;
• maintaining business records;
• developing new features;
• contacting users about similar Anka-related updates, where legally permitted.

Legal obligation

We may use personal data where we need to comply with the law, respond to lawful requests, or meet regulatory, tax, accounting or other legal requirements.

Vital interests

In rare cases, we may use or share personal data where we reasonably believe it is necessary to protect someone’s life or safety.

7. Supporter invitations

Anka may allow users to invite supporters to take part in a challenge.

If a user provides your contact details so that we can invite you, we will use those details to send the invitation and manage your interaction with that challenge.

If you do not want to receive invitations or messages from Anka, you can contact us at anthony.a.paine@gmail.com.

Users must not use Anka to send unwanted, harmful, misleading, harassing or inappropriate invitations or messages.

8. Marketing and product updates

If you join the Anka waitlist or ask for updates, we may send you emails about Anka, including launch updates, early access, product news, research opportunities and testing invitations.

You can unsubscribe or ask us to stop sending marketing emails at any time.

We may still send important service messages, such as account, security, legal or operational updates.

9. Cookies and similar technologies

We may use cookies and similar technologies on the Anka website and product.

Some cookies are necessary for the website or product to work properly. These may be used without consent where legally permitted.

We may also use analytics, performance or marketing cookies to understand usage, improve Anka, and measure campaigns. Where required by law, we will ask for your consent before using non-essential cookies or similar technologies.

You can manage cookies through your browser settings and, where available, through our cookie controls.

10. Who we share personal data with

We may share personal data with trusted service providers who help us operate Anka, such as:

• website hosting providers;
• cloud infrastructure and database providers;
• authentication providers;
• analytics providers;
• email and messaging providers;
• customer support and feedback tools;
• research, survey or interview tools;
• security, monitoring and error-reporting tools;
• professional advisers, where necessary.

These providers may only process personal data for the purposes we authorise and must protect it appropriately.

We may also share personal data:

• if required by law or a lawful request;
• to protect the rights, safety or security of users, supporters, ANAVPA LTD or others;
• to investigate or prevent misuse, abuse, fraud or security issues;
• in connection with a business transfer, investment, merger, acquisition, restructuring or sale of assets, where appropriate safeguards are in place.

We do not sell personal data.

11. International transfers

Some of our service providers may process personal data outside the UK.

Where personal data is transferred outside the UK, we will take steps designed to protect it in accordance with UK data protection law. This may include using countries covered by UK adequacy regulations or approved contractual safeguards.

12. How long we keep personal data

We keep personal data only for as long as reasonably necessary for the purposes described in this Privacy Policy.

As a general guide:

• waitlist and marketing data is kept until you unsubscribe, ask us to delete it, or it is no longer needed;
• account data is kept while your account is active;
• challenge, check-in and message data is kept while needed to provide Anka, unless deleted earlier;
• supporter invitation data is kept while needed to manage invitations, prevent misuse and maintain records;
• research and feedback data may be kept while useful for product development, unless you withdraw from research where applicable;
• support and contact messages may be kept for a reasonable period so we can respond and maintain records;
• technical, diagnostic and security data may be kept for a limited period to protect and improve the service;
• aggregated or anonymised data may be kept for longer, as it does not identify you;
• some data may be kept longer where required for legal, accounting, security, fraud-prevention or dispute-resolution reasons.

You can ask us to delete your personal data by contacting anthony.a.paine@gmail.com.

13. How we protect personal data

We take reasonable technical and organisational steps to protect personal data from loss, misuse, unauthorised access, disclosure, alteration or destruction.

No digital service can be guaranteed to be completely secure. You are responsible for keeping your login details safe and for being careful about what you choose to share.

14. Your rights

Under UK data protection law, you may have the right to:

• ask for a copy of your personal data;
• ask us to correct inaccurate or incomplete personal data;
• ask us to delete your personal data;
• ask us to restrict how we use your personal data;
• object to certain uses of your personal data;
• ask for your personal data to be transferred to another provider;
• withdraw consent, where we rely on consent;
• complain to the UK data protection regulator.

These rights may depend on the circumstances and the lawful basis we rely on.

To exercise your rights, contact us at anthony.a.paine@gmail.com.

We may need to verify your identity before responding to a request.

You also have the right to complain to the Information Commissioner’s Office, the UK data protection regulator. You can find more information at ico.org.uk.

15. Automated decision-making

We do not currently use personal data to make decisions about you that have legal or similarly significant effects using solely automated means.

If this changes, we will update this Privacy Policy.

16. Changes to this Privacy Policy

We may update this Privacy Policy from time to time.

If we make significant changes, we will take reasonable steps to let you know. The latest version will apply when you use Anka.

17. Contact