Privacy Policy

Draft — this document must be completed and reviewed before public launch.

This policy covers the AVYNNA website (avynna.app) and its early-access waitlist. The AVYNNA app is not available yet and has its own privacy policy (see “The future app” below).

At a glance

• We collect your email address when you join the waitlist, and, if you choose to share them, your first name and how experienced you are with training. Plus a few technical details (consent record, signup time, optional campaign source).
• We use it only to send waitlist and launch updates about AVYNNA.
• We collect no health or menstrual-cycle data on this website.
• We do not sell your data, share it for advertising, or use analytics, ad pixels, or cookies.
• Your data is stored with Cloudflare in the United States.
• You can unsubscribe or ask us to delete your data anytime by emailing us.

Who is responsible

The operator of this website is [TO COMPLETE BEFORE LAUNCH: legal name of the operator], established in [TO COMPLETE BEFORE LAUNCH: country of establishment].

Address: [TO COMPLETE BEFORE LAUNCH: postal address]

Privacy contact: [TO COMPLETE BEFORE LAUNCH: contact email for privacy requests]

What we collect

When you join the waitlist, we store:

• Your email address (converted to lowercase).
• Your first name, if you enter one.
• Your training experience level (just starting, some experience, or very experienced), if you pick one.
• The time you signed up.
• The wording version of the consent notice you agreed to, and the time you agreed.
• Campaign details from the link you used, if any: utm_source, utm_medium, utm_campaign, utm_content, utm_term, plus the hostname of the website that referred you (or “direct”).

To remember campaign details while you browse, the site uses your browser’s sessionStorage. It is cleared when you close the tab. AVYNNA sets no cookies.

Abuse protection

To block bots and spam, we use Cloudflare Turnstile. It is processed by Cloudflare under its own terms: Turnstile privacy information.

To limit repeated attempts, we store a keyed one-way hash (HMAC) of your IP address with an attempt counter for a 10-minute window. These records are deleted automatically within about 24 hours. We do not store your raw IP address.

Why we use your data

• Waitlist and launch updates (consent). You agree to this when you join. The notice you see reads: “By joining, you agree to receive emails about the AVYNNA waitlist and launch. You can unsubscribe at any time.” We use your email only for updates such as the launch announcement or an early-access invitation. Your first name lets us address you personally, and your experience level helps us understand who is joining and shape the launch accordingly. We do not offer broader promotional marketing.
• Security and abuse prevention (legitimate interest). Bot checks and rate limiting keep the waitlist safe and fair.

Where the GDPR or UK GDPR applies, these are our legal bases.

Emails

We are not sending emails yet. When we start, we will use an email service provider, which we will name here: [TO COMPLETE BEFORE LAUNCH: email service provider]. Every email will include an unsubscribe link.

Who processes your data

• Cloudflare hosts the website and its serverless function (Cloudflare Pages) and stores waitlist records in its database (Cloudflare D1, primary location Eastern North America, USA). Cloudflare acts as our service provider. It may also process technical data, such as your IP address, to deliver and secure the site. See Cloudflare’s privacy policy.
• Our email service provider, once named above.

We do not sell your data and do not share it for advertising.

International transfers

Your data is stored in the United States. If the operator is established outside the US, we rely on these safeguards: [TO COMPLETE BEFORE LAUNCH: transfer safeguards, e.g. standard contractual clauses or equivalent].

How long we keep it

We keep your waitlist record until you unsubscribe or ask us to delete it, or until the waitlist purpose ends. Maximum period: [TO CONFIRM: e.g. 24 months after the last update sent].

Your rights

Depending on where you live, you may have the right to:

• Access the data we hold about you.
• Correct inaccurate data.
• Delete your data.
• Object to processing or withdraw consent at any time. This does not affect what we did before.
• Receive your data in a portable format.
• Complain to a data protection authority (for example in the EU or UK, if applicable).

To use any of these rights, or to unsubscribe, email [TO COMPLETE BEFORE LAUNCH: contact email for privacy requests]. Deletion is manual: we delete your record from the database, with a target of within 30 days. We may need to confirm that the request comes from the email address in question.

California and other US states. We do not sell your personal information or share it for cross-context behavioral advertising. You may have the right to know what we collect and to request deletion. Use the contact above. We will not treat you differently for exercising these rights.

Children

AVYNNA is not directed at children under 16. We do not knowingly collect their data. If you think a child has joined the waitlist, contact us and we will delete the record.

The future app

When the AVYNNA app launches, it will have its own privacy policy covering app data, including any optional health or cycle features. You will see it before you use the app.

Changes

We will update the date at the top when this policy changes. We will tell waitlist members about material changes.