PRIVACY POLICY
RIVA PSY
RIVA PSY
PRIVACY POLICY
Last updated: July 26, 2026
1. Data Controller
In accordance with Regulation (EU) 2016/679 (GDPR) and Spanish Organic Law 3/2018 on Data Protection and Digital Rights Guarantee (LOPDGDD), the User is informed that personal data will be processed by:
Data Controller: Galina Egorova NIE: Address: Alicante, Spain Email: support@rivapsy.com
Hereinafter, "RIVA," "RIVA PSY," "the App," "the Service," or "we."
2. Scope
This Policy governs the processing of personal data of users of the RIVA PSY mobile app, the official website (rivapsy.com), and any associated digital service.
By using the App or website, the User declares having read and understood this Policy and agrees to the processing of their data under the terms described here. If you disagree, please refrain from using the Service.
3. Definitions
RIVA PSY is designed around the principle of data minimization: we collect only what is strictly necessary to provide the service, and we avoid access to sensitive information by design wherever technically possible. In particular:
When logging in, we may process information from Firebase Authentication, Google Sign-In, or Sign in with Apple. Passwords are never stored by RIVA in plain text; authentication is handled through Firebase Authentication's secure mechanisms.
6. Data We Do NOT Collect
RIVA does not request or collect:
We use Firebase Authentication, Cloud Firestore, Firebase Cloud Messaging (FCM), and Firebase Storage (for recommendation/meditation audio files, not for the User's journal). Firestore stores only the account and subscription data described in Section 5 — never journal content.
Firebase may process: email address, unique identifiers, device identifiers, IP address, technical device information, logs, and push notification tokens.
RIVA does not currently use Firebase Analytics.
9.2 Google Sign-In
When signing in with Google, we only access information the User has authorized (name, email, unique identifier). RIVA never has access to the Google account password.
9.3 Sign in with Apple
Apple may provide a unique identifier, email address (real or private, depending on the User's configuration), and name. This is used solely to manage authentication.
9.4 Google Drive API (Backups)
RIVA lets the User create and restore backups generated and controlled by the User themselves, via their Google Drive account. Access:
9.5 Payments (processed via the website)
Paid subscriptions are purchased and processed through our website (rivapsy.com), via a specialized external payment provider (currently being integrated). RIVA does not collect or store full card numbers, CVV/CVC codes, or financial credentials. RIVA only receives information about payment status, transaction ID, and payment date, in order to activate the corresponding access on the User's account.
10. International Data Transfers
Some technology providers may process data outside the European Economic Area (EEA), including the United States. Where this occurs, RIVA will implement safeguards equivalent to those required by the GDPR (adequacy decisions, Standard Contractual Clauses, and/or additional technical measures including encryption where appropriate).
11. Data Retention
12. Security of Information
We apply appropriate technical and organizational measures, including: encrypted communications via HTTPS/TLS, secure authentication via Firebase Authentication, least-privilege access control, security rules for Cloud Firestore and Firebase Storage, and internal incident management procedures.
In the event of a security breach affecting Users' rights, RIVA will act in accordance with Articles 33 and 34 of the GDPR.
13. Minors
RIVA's services are intended exclusively for individuals over 18 years of age, or the applicable digital age of consent in their country of residence. We do not knowingly collect data from minors. If we become aware that we have collected data from a minor without verifiable parental/guardian consent, we will delete it promptly.
14. Future Use of Artificial Intelligence
RIVA does not currently use generative AI features. In the future, we may introduce an optional conversational AI assistant feature. When available, you will be specifically informed before it is activated, its use will be optional, and it will be governed by a dedicated AI Transparency Notice, available on our website.
15. Cookies
The rivapsy.com website uses cookies. For more information, see our separate Cookie Policy. The mobile App does not use browser cookies, though the third-party SDKs described in Section 9 may use equivalent technical identifiers.
16. User Rights
Under the GDPR, Users may exercise: the right of access, rectification, erasure, restriction of processing, objection, data portability, withdrawal of consent, and the right not to be subject to decisions based solely on automated processing that produce significant legal effects.
Exercising these rights is free of charge. Requests may be sent to support@rivapsy.com. RIVA may request additional information to verify the requester's identity and will respond within a maximum of one (1) month.
17. Right to Lodge a Complaint
Users may file a complaint with the Spanish Data Protection Agency (AEPD), or with the competent data protection authority of their habitual EU country of residence.
18. Changes to This Policy
We may update this Policy periodically. The updated version will be published on this page along with the last-updated date. We recommend reviewing this page periodically.
19. Contact
For any questions regarding this Privacy Policy: support@rivapsy.com
Last updated: July 26, 2026
1. Data Controller
In accordance with Regulation (EU) 2016/679 (GDPR) and Spanish Organic Law 3/2018 on Data Protection and Digital Rights Guarantee (LOPDGDD), the User is informed that personal data will be processed by:
Data Controller: Galina Egorova NIE: Address: Alicante, Spain Email: support@rivapsy.com
Hereinafter, "RIVA," "RIVA PSY," "the App," "the Service," or "we."
2. Scope
This Policy governs the processing of personal data of users of the RIVA PSY mobile app, the official website (rivapsy.com), and any associated digital service.
By using the App or website, the User declares having read and understood this Policy and agrees to the processing of their data under the terms described here. If you disagree, please refrain from using the Service.
3. Definitions
- Personal data: any information relating to an identified or identifiable natural person.
- Processing: any operation performed on personal data (collection, recording, storage, consultation, use, disclosure, erasure, etc.).
- User: any natural person using the App or website.
- Processor: a natural or legal person that processes data on behalf of the Controller.
- Third-party services: technology services from external companies necessary for the Service to operate.
RIVA PSY is designed around the principle of data minimization: we collect only what is strictly necessary to provide the service, and we avoid access to sensitive information by design wherever technically possible. In particular:
- The content of your emotional journal (SMER entries: situation, thoughts, emotions, body, actions) is stored exclusively on your device (local storage), and RIVA never has access to this content.
- Voice recordings (the "Talk it out" feature) are created and stored exclusively on your device. They are never transmitted to, processed by, or stored on our servers.
- Email address
- Username
- Age
- Gender (when the User chooses to provide it)
- Preferred language
- Subscription/plan status
- Information voluntarily submitted when contacting support (suggestions, error reports)
- IP address
- Device identifiers
- Operating system version and device model
- Firebase identifiers
- Technical logs and crash/error data
- Push notification token (Firebase Cloud Messaging)
When logging in, we may process information from Firebase Authentication, Google Sign-In, or Sign in with Apple. Passwords are never stored by RIVA in plain text; authentication is handled through Firebase Authentication's secure mechanisms.
6. Data We Do NOT Collect
RIVA does not request or collect:
- The content of your emotional journal or voice recordings (they remain on your device, see Section 4)
- Biometric or genetic data
- Identity documents
- Full bank account details or card numbers
- Special categories of data under Art. 9 GDPR, unless the User voluntarily enters such information in free-text fields of the App, in which case it will be processed solely to provide the requested service and, if it is journal content, will likewise remain on the User's device.
- Create and manage the User's account
- Authenticate the User and recognize subscription status across devices
- Provide the App's functionality
- Send notifications and reminders when enabled by the User
- Facilitate backups when the User explicitly activates that feature
- Respond to support inquiries
- Improve performance, stability, and security of the App
- Detect technical errors and prevent fraudulent use
- Comply with applicable legal obligations
- Performance of a contract or the requested service (Art. 6(1)(b) GDPR)
- User consent (Art. 6(1)(a) GDPR), revocable at any time
- Compliance with legal obligations (Art. 6(1)(c) GDPR)
- Legitimate interest of the Controller in ensuring security and continuous improvement (Art. 6(1)(f) GDPR)
We use Firebase Authentication, Cloud Firestore, Firebase Cloud Messaging (FCM), and Firebase Storage (for recommendation/meditation audio files, not for the User's journal). Firestore stores only the account and subscription data described in Section 5 — never journal content.
Firebase may process: email address, unique identifiers, device identifiers, IP address, technical device information, logs, and push notification tokens.
RIVA does not currently use Firebase Analytics.
9.2 Google Sign-In
When signing in with Google, we only access information the User has authorized (name, email, unique identifier). RIVA never has access to the Google account password.
9.3 Sign in with Apple
Apple may provide a unique identifier, email address (real or private, depending on the User's configuration), and name. This is used solely to manage authentication.
9.4 Google Drive API (Backups)
RIVA lets the User create and restore backups generated and controlled by the User themselves, via their Google Drive account. Access:
- is only requested after an explicit User action;
- is used solely to create or restore the backup generated by the App;
- does not allow access to, viewing, modification, or deletion of any other files in the User's account.
9.5 Payments (processed via the website)
Paid subscriptions are purchased and processed through our website (rivapsy.com), via a specialized external payment provider (currently being integrated). RIVA does not collect or store full card numbers, CVV/CVC codes, or financial credentials. RIVA only receives information about payment status, transaction ID, and payment date, in order to activate the corresponding access on the User's account.
10. International Data Transfers
Some technology providers may process data outside the European Economic Area (EEA), including the United States. Where this occurs, RIVA will implement safeguards equivalent to those required by the GDPR (adequacy decisions, Standard Contractual Clauses, and/or additional technical measures including encryption where appropriate).
11. Data Retention
Data type | Retention period |
User account (email, subscription) | While the account remains active |
Journal content / voice recordings | Not applicable — stays exclusively on the User's device |
Google Drive backups | Under the User's exclusive control, until deleted by them |
Technical logs | Up to 24 months, unless a longer period is required for security reasons |
Payment information | For the period required by applicable tax and accounting law |
Support inquiries | Up to 24 months from the last communication |
We apply appropriate technical and organizational measures, including: encrypted communications via HTTPS/TLS, secure authentication via Firebase Authentication, least-privilege access control, security rules for Cloud Firestore and Firebase Storage, and internal incident management procedures.
In the event of a security breach affecting Users' rights, RIVA will act in accordance with Articles 33 and 34 of the GDPR.
13. Minors
RIVA's services are intended exclusively for individuals over 18 years of age, or the applicable digital age of consent in their country of residence. We do not knowingly collect data from minors. If we become aware that we have collected data from a minor without verifiable parental/guardian consent, we will delete it promptly.
14. Future Use of Artificial Intelligence
RIVA does not currently use generative AI features. In the future, we may introduce an optional conversational AI assistant feature. When available, you will be specifically informed before it is activated, its use will be optional, and it will be governed by a dedicated AI Transparency Notice, available on our website.
15. Cookies
The rivapsy.com website uses cookies. For more information, see our separate Cookie Policy. The mobile App does not use browser cookies, though the third-party SDKs described in Section 9 may use equivalent technical identifiers.
16. User Rights
Under the GDPR, Users may exercise: the right of access, rectification, erasure, restriction of processing, objection, data portability, withdrawal of consent, and the right not to be subject to decisions based solely on automated processing that produce significant legal effects.
Exercising these rights is free of charge. Requests may be sent to support@rivapsy.com. RIVA may request additional information to verify the requester's identity and will respond within a maximum of one (1) month.
17. Right to Lodge a Complaint
Users may file a complaint with the Spanish Data Protection Agency (AEPD), or with the competent data protection authority of their habitual EU country of residence.
18. Changes to This Policy
We may update this Policy periodically. The updated version will be published on this page along with the last-updated date. We recommend reviewing this page periodically.
19. Contact
For any questions regarding this Privacy Policy: support@rivapsy.com
TERMS OF USE
Last updated: July 26, 2026
TERMS OF USE
1. Acceptance of Terms
These Terms of Use constitute an agreement between the User and Galina Egorova, NIE , resident in Alicante, Spain (hereinafter "RIVA," "RIVA PSY," or "we"), and govern access to and use of the RIVA PSY mobile app, the rivapsy.com website, and any associated service.
Using the App, including creating an account, constitutes full acceptance of these Terms and our Privacy Policy. If you disagree, please do not use the Service.
2. Minimum Age
The services are intended exclusively for individuals over 18 years of age. If you do not meet this requirement, you must not use the App or website.
3. Purpose of the Service
RIVA PSY gives Users access to self-awareness and emotional wellbeing features, including: a personal journal (SMER entries — situation, thoughts, emotions, body, actions), emotional-state charts and analysis, personal voice recordings, psychoeducational recommendations and exercises, and guided audio meditations.
4. Nature of the Service — Important Mental Health Notice
RIVA PSY does not provide professional medical, psychological, or psychiatric services. The App is intended for relatively healthy individuals with no physical or mental health issues posing a life-threatening risk to themselves or others. RIVA does not guarantee any specific therapeutic outcome, and a mismatch between the result obtained and the User's expectations does not constitute grounds for a claim of inadequate service.
If you are experiencing a mental health emergency or having thoughts of self-harm, please contact your local emergency services immediately (in Spain: 112, or the Teléfono de la Esperanza: 717 003 717) or seek help from a qualified professional. RIVA PSY is not a crisis-management tool.
5. Registration
To access certain features, the User must create an account by providing a username and email address, or authenticate via Google or Apple. The User warrants that the information provided is accurate and undertakes to keep it up to date.
6. Subscriptions and Payments
Full access to certain features (including the "Обретение" module and advanced content) requires a paid subscription. Subscriptions are purchased and paid for through our website (rivapsy.com), via an external payment provider. RIVA does not process or store full financial data (see our Privacy Policy).
7. Prohibited Use
The User agrees not to:
All software, content, trademarks, text, graphics, and other elements of the Service are the property of RIVA or its legitimate licensors and are protected by applicable intellectual property law. Any unauthorized use of these elements is prohibited.
If you hold intellectual property rights and believe content in the Service infringes them, contact support@rivapsy.com, identifying yourself and the specific content concerned.
9. Reliance on Published Information
Information provided in the Service is for informational and educational purposes only. We do not guarantee its accuracy, completeness, or suitability for any particular case. The User assumes sole responsibility for any decision based on such information.
10. Links to Third-Party Sites
The Service may contain links to third-party websites. RIVA does not control or take responsibility for the content of such sites, nor for any damages arising from their use.
11. Limitation of Liability
To the extent permitted by applicable law, RIVA shall not be liable for indirect, incidental, or consequential damages arising from use or inability to use the Service. RIVA's total liability to the User shall not, in any case, exceed the amount paid by the User for the subscription during the twelve (12) months preceding the event giving rise to the claim.
Nothing in this clause limits any non-waivable rights granted to the User under Spanish and European Union consumer protection law.
12. Geographic Limitation
The Service may not be available or suitable in all jurisdictions. The User accesses the Service at their own risk and must comply with applicable local law.
13. Indemnification
The User agrees to indemnify RIVA against any claim arising from breach of these Terms or misuse of the Service.
14. Governing Law and Jurisdiction
These Terms are governed by Spanish law. Any dispute shall be submitted to the Courts of Alicante, without prejudice to any rights recognized by consumer protection law allowing the User to bring proceedings in the courts of their own domicile.
15. Refund Policy
For information on cancellations and refunds for your subscription, please refer to the specific terms shown at the time of purchase on our website, or contact support@rivapsy.com. EU residents generally have a 14-day right of withdrawal under consumer protection law, unless that right is lost due to the start of digital content delivery with the User's express consent.
16. Other Conditions
Use while driving: the User must not interact with the App while driving. RIVA is not responsible for accidents or damages resulting from use of the App while driving.
17. Changes to These Terms
We may modify these Terms at any time. The updated version will be published on this page. Continued use of the Service after changes are published constitutes acceptance of those changes.
18. Contact
Galina Egorova NIE: Alicante, Spain Email: support@rivapsy.com
1. Acceptance of Terms
These Terms of Use constitute an agreement between the User and Galina Egorova, NIE , resident in Alicante, Spain (hereinafter "RIVA," "RIVA PSY," or "we"), and govern access to and use of the RIVA PSY mobile app, the rivapsy.com website, and any associated service.
Using the App, including creating an account, constitutes full acceptance of these Terms and our Privacy Policy. If you disagree, please do not use the Service.
2. Minimum Age
The services are intended exclusively for individuals over 18 years of age. If you do not meet this requirement, you must not use the App or website.
3. Purpose of the Service
RIVA PSY gives Users access to self-awareness and emotional wellbeing features, including: a personal journal (SMER entries — situation, thoughts, emotions, body, actions), emotional-state charts and analysis, personal voice recordings, psychoeducational recommendations and exercises, and guided audio meditations.
4. Nature of the Service — Important Mental Health Notice
RIVA PSY does not provide professional medical, psychological, or psychiatric services. The App is intended for relatively healthy individuals with no physical or mental health issues posing a life-threatening risk to themselves or others. RIVA does not guarantee any specific therapeutic outcome, and a mismatch between the result obtained and the User's expectations does not constitute grounds for a claim of inadequate service.
If you are experiencing a mental health emergency or having thoughts of self-harm, please contact your local emergency services immediately (in Spain: 112, or the Teléfono de la Esperanza: 717 003 717) or seek help from a qualified professional. RIVA PSY is not a crisis-management tool.
5. Registration
To access certain features, the User must create an account by providing a username and email address, or authenticate via Google or Apple. The User warrants that the information provided is accurate and undertakes to keep it up to date.
6. Subscriptions and Payments
Full access to certain features (including the "Обретение" module and advanced content) requires a paid subscription. Subscriptions are purchased and paid for through our website (rivapsy.com), via an external payment provider. RIVA does not process or store full financial data (see our Privacy Policy).
7. Prohibited Use
The User agrees not to:
- upload, transmit, or distribute content containing viruses or malicious code;
- interfere with the servers or networks associated with the Service;
- rent, sublicense, adapt, or modify the App or its documentation;
- reverse-engineer, decompile, or disassemble the App;
- impersonate RIVA, its employees, or other users;
- send unsolicited commercial communications or spam through the Service;
- use the Service for market manipulation or any unlawful activity.
All software, content, trademarks, text, graphics, and other elements of the Service are the property of RIVA or its legitimate licensors and are protected by applicable intellectual property law. Any unauthorized use of these elements is prohibited.
If you hold intellectual property rights and believe content in the Service infringes them, contact support@rivapsy.com, identifying yourself and the specific content concerned.
9. Reliance on Published Information
Information provided in the Service is for informational and educational purposes only. We do not guarantee its accuracy, completeness, or suitability for any particular case. The User assumes sole responsibility for any decision based on such information.
10. Links to Third-Party Sites
The Service may contain links to third-party websites. RIVA does not control or take responsibility for the content of such sites, nor for any damages arising from their use.
11. Limitation of Liability
To the extent permitted by applicable law, RIVA shall not be liable for indirect, incidental, or consequential damages arising from use or inability to use the Service. RIVA's total liability to the User shall not, in any case, exceed the amount paid by the User for the subscription during the twelve (12) months preceding the event giving rise to the claim.
Nothing in this clause limits any non-waivable rights granted to the User under Spanish and European Union consumer protection law.
12. Geographic Limitation
The Service may not be available or suitable in all jurisdictions. The User accesses the Service at their own risk and must comply with applicable local law.
13. Indemnification
The User agrees to indemnify RIVA against any claim arising from breach of these Terms or misuse of the Service.
14. Governing Law and Jurisdiction
These Terms are governed by Spanish law. Any dispute shall be submitted to the Courts of Alicante, without prejudice to any rights recognized by consumer protection law allowing the User to bring proceedings in the courts of their own domicile.
15. Refund Policy
For information on cancellations and refunds for your subscription, please refer to the specific terms shown at the time of purchase on our website, or contact support@rivapsy.com. EU residents generally have a 14-day right of withdrawal under consumer protection law, unless that right is lost due to the start of digital content delivery with the User's express consent.
16. Other Conditions
Use while driving: the User must not interact with the App while driving. RIVA is not responsible for accidents or damages resulting from use of the App while driving.
17. Changes to These Terms
We may modify these Terms at any time. The updated version will be published on this page. Continued use of the Service after changes are published constitutes acceptance of those changes.
18. Contact
Galina Egorova NIE: Alicante, Spain Email: support@rivapsy.com
COOKIE POLICY
Last updated: July 26, 2026
COOKIE POLICY
This Cookie Policy applies to the rivapsy.com website, operated by Galina Egorova, NIE , Alicante, Spain. It explains what cookies are, which ones we use, and how you can manage them.
1. What Are Cookies?
Cookies are small text files that a website stores on your device (computer, tablet, phone) when you visit it. They allow the site to remember your actions and preferences over time.
2. Types of Cookies We Use2.1 Necessary/Technical Cookies
Essential for the website to function (for example, keeping you logged in or remembering your language preference). These do not require prior consent under applicable law.
2.2 Preference Cookies
Allow the site to remember information that changes how it behaves or looks, such as your selected language.
2.3 Analytics Cookies (if enabled)
Help us understand how visitors interact with the website, for statistical and improvement purposes. These cookies will only be set after you provide explicit consent through the cookie management panel.
3. Third-Party Cookies
Some services integrated into the site (for example, Google sign-in mechanisms) may set their own cookies or equivalent technical identifiers, in accordance with their own privacy policies.
4. Managing Your Cookie Preferences
When you first visit rivapsy.com, you will be shown a consent management panel where you can accept, reject, or customize non-essential cookies. You can change your preferences at any time via the "Cookie Settings" link in the website footer.
You can also configure your browser to block or delete cookies; note that this may affect the functioning of certain parts of the site.
5. The Mobile App
The RIVA PSY mobile app does not use browser cookies. Third-party SDKs integrated into the app (Firebase, Google Sign-In, Sign in with Apple) may use equivalent technical identifiers; see our Privacy Policy for details.
6. Changes to This Policy
We may update this Cookie Policy periodically. The last-updated date is shown at the top of this document.
7. Contact
For any questions about this Cookie Policy: support@rivapsy.com
This Cookie Policy applies to the rivapsy.com website, operated by Galina Egorova, NIE , Alicante, Spain. It explains what cookies are, which ones we use, and how you can manage them.
1. What Are Cookies?
Cookies are small text files that a website stores on your device (computer, tablet, phone) when you visit it. They allow the site to remember your actions and preferences over time.
2. Types of Cookies We Use2.1 Necessary/Technical Cookies
Essential for the website to function (for example, keeping you logged in or remembering your language preference). These do not require prior consent under applicable law.
2.2 Preference Cookies
Allow the site to remember information that changes how it behaves or looks, such as your selected language.
2.3 Analytics Cookies (if enabled)
Help us understand how visitors interact with the website, for statistical and improvement purposes. These cookies will only be set after you provide explicit consent through the cookie management panel.
3. Third-Party Cookies
Some services integrated into the site (for example, Google sign-in mechanisms) may set their own cookies or equivalent technical identifiers, in accordance with their own privacy policies.
4. Managing Your Cookie Preferences
When you first visit rivapsy.com, you will be shown a consent management panel where you can accept, reject, or customize non-essential cookies. You can change your preferences at any time via the "Cookie Settings" link in the website footer.
You can also configure your browser to block or delete cookies; note that this may affect the functioning of certain parts of the site.
5. The Mobile App
The RIVA PSY mobile app does not use browser cookies. Third-party SDKs integrated into the app (Firebase, Google Sign-In, Sign in with Apple) may use equivalent technical identifiers; see our Privacy Policy for details.
6. Changes to This Policy
We may update this Cookie Policy periodically. The last-updated date is shown at the top of this document.
7. Contact
For any questions about this Cookie Policy: support@rivapsy.com
GDPR DATA PROCESSING INFORMATION
Last updated: July 26, 2026
GDPR DATA PROCESSING INFORMATION
This document supplements the RIVA PSY Privacy Policy and provides additional technical information about our processing activities, in line with the accountability principle under Art. 5(2) GDPR.
1. Controller Identification
Galina Egorova · NIE · Alicante, Spain · support@rivapsy.com
2. Record of Processing Activities (Summary)
Important note: the content of the User's emotional journal (SMER entries) and voice recordings do not appear in this record as a RIVA processing activity, since this data is generated and stored exclusively on the User's device, and RIVA never accesses it.
3. Processors and Sub-processors
This table will be updated as technology providers are added or changed.
4. Automated Decision-Making
RIVA does not make decisions based solely on automated processing that produce significant legal effects on the User.
5. Data Protection Impact Assessment (DPIA)
Given the minimized nature of the processing (journal content never leaves the User's device), RIVA considers the risk to data subjects' rights and freedoms to be limited. Nonetheless, the need for a Data Protection Impact Assessment (Art. 35 GDPR) will be reviewed for any substantial change in processing, particularly if AI features that process journal content are introduced in the future.
6. Exercising Your Rights
See the corresponding section of the Privacy Policy. Requests to: support@rivapsy.com
7. Data Protection Contact
support@rivapsy.com
This document supplements the RIVA PSY Privacy Policy and provides additional technical information about our processing activities, in line with the accountability principle under Art. 5(2) GDPR.
1. Controller Identification
Galina Egorova · NIE · Alicante, Spain · support@rivapsy.com
2. Record of Processing Activities (Summary)
Activity | Data subject categories | Data categories | Purpose | Legal basis | Retention period |
Account management | Registered users | Email, username, age, gender, language | Account creation and administration | Contract performance (Art. 6(1)(b)) | While the account is active |
Authentication | Registered users | Firebase/Google/Apple identifiers | Verify identity and access | Contract performance | While the account is active |
Subscriptions | Paying users | Payment status, transaction ID, date, amount | Activate/manage paid access | Contract performance | Applicable tax/accounting period |
Push notifications | Users with notifications enabled | Device token (FCM) | Send reminders | Consent (Art. 6(1)(a)) | While enabled |
Technical support | Users contacting support | Email, message content | Respond to inquiries, resolve issues | Contract performance / legitimate interest | 24 months |
Backups | Users who enable the feature | Backup file metadata (ID, date, count) in the User's own Google Drive | Enable data recovery by the User | Consent | Until the User deletes the backup |
Security and fraud prevention | All users | IP, technical logs, error information | Detect fraud, maintain security | Legitimate interest (Art. 6(1)(f)) | Up to 24 months |
Important note: the content of the User's emotional journal (SMER entries) and voice recordings do not appear in this record as a RIVA processing activity, since this data is generated and stored exclusively on the User's device, and RIVA never accesses it.
3. Processors and Sub-processors
Provider | Service | Location / International transfer | Function |
Google LLC (Firebase) | Authentication, Cloud Firestore, Cloud Messaging, Storage | US / Standard Contractual Clauses | Authentication, account database, notifications, content audio storage |
Google LLC | Google Sign-In | US / Standard Contractual Clauses | Authentication via Google account |
Google LLC | Google Drive API | US / Standard Contractual Clauses | User-controlled backups |
Apple Inc. | Sign in with Apple | US / Standard Contractual Clauses | Authentication via Apple account |
Payment provider (being integrated) | Web-based payment processing | Depends on the finally contracted provider | Managing paid subscriptions |
This table will be updated as technology providers are added or changed.
4. Automated Decision-Making
RIVA does not make decisions based solely on automated processing that produce significant legal effects on the User.
5. Data Protection Impact Assessment (DPIA)
Given the minimized nature of the processing (journal content never leaves the User's device), RIVA considers the risk to data subjects' rights and freedoms to be limited. Nonetheless, the need for a Data Protection Impact Assessment (Art. 35 GDPR) will be reviewed for any substantial change in processing, particularly if AI features that process journal content are introduced in the future.
6. Exercising Your Rights
See the corresponding section of the Privacy Policy. Requests to: support@rivapsy.com
7. Data Protection Contact
support@rivapsy.com
AI TRANSPARENCY NOTICE
Last updated: July 26, 2026
AI TRANSPARENCY NOTICE
Current Status
RIVA PSY does not currently use generative Artificial Intelligence features. This document is published proactively so Users are aware of our commitment to transparency regarding future AI-based features.
Planned Future Feature
We plan to introduce, in a future version, an optional conversation feature with an Artificial Intelligence assistant, designed to support the User's emotional self-awareness process.
When this feature becomes available, we will apply the following principles:
For any questions about this Notice: support@rivapsy.com
Current Status
RIVA PSY does not currently use generative Artificial Intelligence features. This document is published proactively so Users are aware of our commitment to transparency regarding future AI-based features.
Planned Future Feature
We plan to introduce, in a future version, an optional conversation feature with an Artificial Intelligence assistant, designed to support the User's emotional self-awareness process.
When this feature becomes available, we will apply the following principles:
- Optional use: the User will be free to choose whether or not to use the AI feature; it will not be required to access the rest of the App's functionality.
- Prior disclosure: before enabling the feature, the User will be clearly informed that they are interacting with an AI system, not a human.
- No automated decisions with legal effects: the AI will not make decisions that produce significant legal effects on the User.
- Not a substitute for professional care: the AI will not provide psychological or medical diagnosis or treatment, and Users will be reminded that in a crisis they should contact emergency services or a qualified professional.
- Data minimization: we will assess what information is strictly necessary to share with the AI provider, and will aim, as far as possible, to maintain the same minimization principle that governs the rest of the App.
- Consent and Privacy Policy update: before launching this feature, we will update our Privacy Policy and this Notice with the relevant technical details (AI provider used, data processed, legal basis) and will request User consent where required.
For any questions about this Notice: support@rivapsy.com